ML20042C530

Response to ASLB 820315 Memorandum & Order Re Positions If Filings & Litigation of Onsite Emergency Planning Issues Scheduled in Advance of Offsite Emergency Planning Isues. Certification of Svc Encl

ML20042C530
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/26/1982
From:	Shapiro R Cammer & Shapiro, NORTH SHORE COMMITTEE AGAINST NUCLEAR & THERMAL POLLU
To:
References
ISSUANCES-OL, NUDOCS 8203310489
Download: ML20042C530 (5)

Text

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.. t T'.ET UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIOf /

• j BEFORE THE ATOMIC SAFETY u .. '

AND LICENSING BOARD

---

x In the Matter of LONG ISLAND LIGHTING COMPANY Docket No. 50-322-OL (Shoreham Nuclear Power Station Unit 1)

-.____________x RESPONSE OF INTERVENOR NORTH SHORE COMMITTEE 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 Board further directed NSC to contact the parties if it wished to participate in the hearings on those contentions (Memorandum ,.

and Order, March 15, 1982, pp. 25-26).

Responding to the Board's direction, couds'el for che ..

NSC conferred separately by phone with counsel, for SOC and SC. -

NSC believes that its views stated below are compatib m m the positions of both SOC and SC. g 7 n2CEWED [

MAR 3 01982* To a g t. s em ra4xt nuc l

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j B203310489 820326 PDR ADOCK 05000322 .

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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 (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 f (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.,

l l such coordination will require consideration of the off-site l emergency plan.

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

hARal W 6h'apiro /'

/

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

l

'"h UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'82 M;.R 29 R2:54 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IY . i In the Matter of ) Ncii

)

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 Comittee Against Nuclear and Thermal Pollution l

("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. j Iawrence Brenner, Cbaiman* Atomic Safety & Licensing Board

• Administrative Judge .

U. S. Nuclear Regulatory ra=d=sion  !

Atomic Safety & Licensing Board Washington, D. C 20555 U. S. Nuclear Regulatory Camd asion 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 C-insion Sanuel J. Chilk,. Secretary Washington, D. C. 20555-Docketing and Service Station '

l U. S. Nuclear Regulatory C 4asion  ;

Dr. James L. Carpenter, Member

• Washington, D. C. 20555 .

Atomic Safety & Licensing Board 4 U. S. Nuclear Regulatory Camdssion W. Taylor Reveley, III, Esq.*

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

Htuton & Williams [

Edward M. Barrett, Esq. P. O. Box 1535 '

l General Counsel Richnond, Virginia 23212 '

long Island Lighting Capany .

250 Cid Cotntry Road Mineola, New York 11501 I

I

Jeffrey Cohen, Esq. Herbert H. Brom, Esq.*

Lawrence Coe Lanpher, Es

• Mr. Jay Dtnkleberger New York State Energy Office Karla J. Ietsche, Esq.* q.

Agency Building 2 Kirkpatrick, Inckhart, Hill, Empire State Plaza Christopher & Phillips ,

Al may, New York 12223 -

1900 M Street, N. W. (8th Flocr)

Washington, D. C. 20036 Atomte Safety & Licensing Appeal Board U. S. Nuclear Regulatory enmission Brian McCaffrey

- Washington, D. C. 20555 Iong Island Lighting Company 175 East Old Cotntry Road David J. Gihnartin, Esq. Hicksville, New York 11801 County Attorney, Suffolk Cotnty Department of law Mr. Mark W. Goldsmith Att'n.: Patricia Decpsey, 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 Cotnsel for NRC Staff U. S.' Nuclear Regulatory Comntssion Jeffrey L.'Futter Washington, D. C. 20555 s Iong Island Lighting Coupany 250 Old Cotntry Road Stephen B. Iatham, Esq.*

Mineola, New York 11501 Itr.xney, 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 9

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