ML20050B929

Response to ASLB Request in 820315 Memorandum & Order. Filing & Litigation on Onsite Emergency Planning Should Not Proceed Prior to Submittal of & Opportunity to Analyze Offsite Emergency Plan.Certificate of Svc Encl

ML20050B929
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/26/1982
From:	Shapiro R, Sharpiro R Cammer & Shapiro, NORTH SHORE COMMITTEE AGAINST NUCLEAR & THERMAL POLLU
To:	NRC COMMISSION (OCM)
References
ISSUANCES-OL, NUDOCS 8204070567
Download: ML20050B929 (5)

Text

.. _ _ . _ _ __. . ._ _ _ _ _ _ _

. s .>

c c ,< - - ~

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '82 PR -1 R0 39 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 7

______________x In the Matter of LONG ISLAND LIGHTING COMPANY 6 2hE 4 22-OL-4 I (Shoreham Nuclear Power [ y/

Station Unit 1) 9 C g  %

m h' , D %g% ~

- ------------x r ~.

k. 9 2 8

RESPONSE OF INTERVENOR NORTH SHORE ~

AGAINST NUCLEAR AND THERMAL POLLUTION"("NSC")

TO BOARD'S REQUEST IN ITS MARCH 15, 1982 MEMORANDUM AND ORDER The Board's March 15, 1982 Order requested the parties, among other things, to = state their positions if the filings and litigation of on-site emergency planning issues should be scheduled in advance of off-site emergency planning. The i Board further directed NSC to. contact the parties if it wished to participate ~in the h' earings on those contentions (Memorandum and Order, March 15, 1982, pp. 25-26).

~

i 1

Responding to the Board's direction, counsel-for'the i NSC conferred separately by phone with counsel for SOC and SC.

NSC believes th'at its views stated below are: compatible with l

' the p.ositions of both SOC . and SC. y

{

J ID i

8204070567 8E0326 l PDR ADOCK 05000322

- O PDR l I

. ' 1

,~

The filings, litigation, and other matters relating to on-site emergency planning should not proceed prior to the submission of and opportunity to analyze the off-site emergency plan.

NUREG-0654 (FEMA-REP-1), Rev. 1, dated November 1980, clearly points to the interrelated and coordinated review of on-site and off-site emergency plans. For example, the cited NUREG establishes a planning standard which requires

~

interfacing among various on-site and off-site emergency responses when an on-site emergency occurs. (Id. , II(B) (2) (6) ,

pp. 34, 36.) See also the requirements of the cited NUREG concerning Emergency Response Support and Resources 1

(id. , II(C)(1)(2), p. 40), Notification Methods and Procedures (id., II(E), pp. 43-46), and Emergency Communi-cations (id., II(F), pp. 47-48).

LILCO recognized the interrelationship between on-site

-and off-site emergency planning in its Permanent Emergency Response Facilities, Design Criteria and Description (SNRC-643, 12/11/ 81) , responding to SOC contention 7A(4)#3.

As but one example, to meet one of the criteria of NUREG 0696 its EOF will be located about nineteen miles from the plant with the capacity to coordinate emergency response activities with federal, state, and local agencies. Obviously, such coordination will require consideration of the off-site emergency plan.

^

]

l l

In summary, NSC concludes that, apart from the applicable regulations, the obvious need to coordinate on-site and off-site emergency planning mandates joint consideration of the issues relating to both plans and that it is neither feasible nor desirable to consider one in isolation from the other.

Respectfully submitted, NORTH SHORE COMMITTEE AGAINST NUCLEAR AND THERMAL POLLUTION By: CAMMER & SHAPIRO, P. C.

A ~

u RalpdV6h'apiro /'

Attorneys for NSC 9 East 40th Street New York, N. Y. 10016 (212) 683-6790 Dated: March 26, 1982 i

s l

l 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

)

(Shoreham Nuclear Power )

Station, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that a copy of Response of Intervenor North Shore Committee Against Nuclear and Thermal Pollution

("NSC") To Board's Request in its March 15, 1982 Memorandum and Order was duly served on March 26, 1982 on each of the parties named below by first-class postpaid mail, except that asterisked parties were served by Federal Express.

. Iawrence Brenner, Chairman

• Atomic Safety & Licensing Board Administrative Judge ,

U. S. Nuclear Regulatory Comission Atomic Safety & Licensing Board Washington, D. C. 20555 U. S. Nuclear Regulatory Comission Washington, D. C. 20555 Howard L. Blau, Esq.

217 Newbridge Road Dr. Peter A. Morris

• Hicksville, New York 11801 Atomic Safety & Licensing Board Panel -

U. S. Nuclear Regulatory Comission Sa:ruel J. Chilk, Secretary Washington, D. C. 20555 Docketing and Service Station U. S. Nuclear Regulatory Comission Dr. James L. Carpenter, Member

• Washington, D. C. 20555 Atomic Safety & Licensing Board U. S. Nuclear Regulatory Comission W. Taylor Reveley, III, Esq.*

Washington, D. C. 20555 Daniel 0. Flanagan, Esq.*

Hunton & Williams Edaard M. Barrett, Esq. P. O. Box 1535 General Cotnsel Richnond, Virginia 23212 Iong Island Lighting Cocpany 250 Old Cotntry Road Mineola, New York 11501

t s *

. b 7

~ ..

c- Jeffrey C6 hen, Esq. Herbert H. Brown, Esq.*

Mr. Jay Dunkleberger Lawrence Coe Lanpher, Esq.*

New York State Energy Office Karla J. I.atsche, Esq.*

Agency Building 2 Kirkpatrick,Iockhart, Hill,

_ Enpire State Plaza Christopher & Phillips

~~

Albany, New York 12223 1900 M Street, N. W. (8th Floor)

Washington, D. C. 20036 Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Ccenission Brian McCaffrey Washington, D. C. 20555 Iong Island Lighting Company 175 East Old Cotnticy Road David J. Gilmartin, Esq. Hicksville, New York 11801 County Attorney, Suffolk Cotnty Department of law Mr. Mark W. Goldsmith Att'n.: Patricia Dempsey, Esq. Energy Research-Group, Inc.

Veterans Menorial Highway 400-1 Totten Pond Road Hauppauge, New York 11787 Waltham, Massachusetts.02154 MHB Technical Associates Bernard M. Bordenick, Esq.*

1723 Hamilton Avenue (Suite K) David A. Repka, Esq.*

San Jose, California 95125 Co'nsel for NRC Staff U. S. Nuclear Regulatory Conmission Jeffrey L. Futter Washington, D. C. 20555 Iong Island Lighting Company 250 Old Country Road Stephen B. Latham, Esq.*

Mineola, New York 11501 Twomey, Latham & Shea 33 West Second Street

. Nora Bredes P. O. Box 398 SOC Coordinator Riverhead, New York 11901 195 East Main Street Smithtown, New York, 11787 I

~

4. 4 n.

4-