ML20237E691

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Affidavit of Jd Leonard in Support of Lilco Motions for Summary Disposition of Contentions 1-10.*
ML20237E691
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 12/10/1987
From: Leonard J
LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20237E542 List:
References
OL-3, NUDOCS 8712290129
Download: ML20237E691 (7)
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LILCO, December 10,1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinst Board i

In the Matter of )

)

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

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

AFFIDAVIT OF JOHN D. LEONARD, JR.

IN SUPPORT OF LILCO'S MOTIONS FOR

SUMMARY

DISPOSITION OF CONTENTIONS 1-10 John D. Leonard, Jr., being duly sworn, deposes and says as follows:

1. My name is John D. Leonard, Jr. My business address is Long Island Lighting Company, Shoreham Nuclear Power Station, Wading River, New York 11792.
2. I am currently Vice President, Nuclear Operations, for the Long Island Lighting Company. I have been employed in that capacity at the Long Island Lighting Company since May 1984. My combined civilian and naval nuclear experience amounts to 25 years.
3. In September 1974, I retired with the rank of Commander from the United States Navy, having commanded two nuclear powered submarines in a career that spanned twenty years in various Navy duties. From September 1974 to January 1976, I organized the Operational Quality Assurance Division of the Virginia Electric Power Compan'/ . From January 1976 to April 1980, I served as a Resident Manager of the New York Power Authority's James A. FitzPatrick Nuclear Power Plant, a sister plant to Shoreham. During this time, the FitzPatrick faellity was judged by the Nuclear hb G

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Regulatory Commission to be one of the twelve best-managed plants with respect to re-actor safety. From April 1980 to May 1984. I was the Vice President and Assistant Chief Engineer for Design & Analysis in the New York Power Authority's Engineering Department. My staff supported two operating nuclear power plants, Indian Point 3 l

and the Jankes A. FitzPatrick Nuclear Power Plant, as well as the engineering for the construction of new Power Authority facilities. During an interim period from August 1981 through December 1981 the New York Power Authority's president, Mr. George T.

Berry, asked me to return to the FitzPatrick piant in order to solve some serious man-agement problems that had developeh there. I voluntarily complied with this request.

4. .I graduated with a Bachelor of Science degree from Duke University in 1953 L and earned a Master of Science degree in Physics from a nuclear engineering curricu-

-lum from the Naval Post Graduate School. I have also attended the Naval Nuclear .

1 Power School and the Genetal Electric simulator training course on boiling water reac-

. tors at the Dresden Nuclear Power Station.

5. The Indian Point Nuclear Power Station has two operating nuclear units, one operated by the Consolidated Edison Company of New York, Inc. and the other by the New York Power Authority. 'I
6. A portion of Rockland County, New York is within the 10-mile emergency planning zone for the Indian Point facility.
7. In 1982, during the time I was a Vice President at the Power Authority, Rockland County refused to continue planning for a radiological emergency at the Indian Point facility.

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8. As a result, the New York State Disaster Preparedness Commission adopted an' interim emergency response plan for Rockland County called the " Interim Ra-diological Emergency Response Plan for Implementing Compensating Measures for Rockland County."

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9. In support of this interim plan, Consolidated Edison and the Power Authori-ty recruited non-Rockland County emergency workers to be volunteer civil defense workers who would fill various emergency roles in the interim plan.

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10. As Vice President of Engineering for the Power Authority, I was personally Y involved in recruiting Power Authority employees to fill these positions.

- 11. To the best of my knowledge, approximately 600 employbes of the Power Authority and Consolidated Edison were recruited to be volunteer emergency workers in the State's interim plan.

12. These workers, recruited from the employees of Consolidated Edison and the Power Authority, replaced Rockland County personnel as bus drivers, traffic guides, health physics monitors, and relocation center workers according to the procedures in the State's interim plan.
13. In particular, the volunteer traffic guides were recruited to replace Rockland County police who were no longer participating in the planned emergency.re-sponse and to direct evacuation traffic on public streets and roads, according to the in-terim plan, during drills, exercises, and during an actual emergency.
14. All volunteer emergency workers, recruited from the employees of Consoli-

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dated Edison and the Power Authority, were trained in their positions and participated in drills and in a federally graded exercise on August 24-25, 1983 of the State of New L.___._ ____m_.. _ _ _ _ _ _ _.__.___._.________.__.______m.___ _ _ . _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ .______=____._____________________._m_._____________w

York Radiological Emergency Response Interim Plan for Rockland County. For exam-ple, during the August 1983 exercise, the volunteer traffic guides worked with State and local police to man traffic control points according to the State interim plan. See FEMA Post Exercise Assessment Report of September 26,1983 for the New York State Interim Plan for Rockland County, at 33.

15. I also personally participated in the State's interim plan for Rockland Coun-ty as a health physics monitor from early 1982 until May 1984. As a health physics monitor, I participated in training and drills. I also participated in the October 24-25, 1983 exercise. However, sufficient health physics monitors were available from other trained employees so that I could perform engineering tasks during the exercise.
16. All voluilteer emergency workers recruited by Consolidated Edison and the Power Authority were issued a New York State Disaster Preparedness Commission iden-tification card and a " Utility Representative Pass" for military and/or police control points during radiological emergencies Photocopies of my identification card and pass are attached to this affidavit.

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

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NEW YORK STATE DISASTER PREPAFIDNESS COWISSION LTTILITY REPRESENTATIVE PASS for MILITARY and/or POLICE CONTROL POINTS t

during RADIOLOGICAL EERGENCIES --

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