CLI-87-12, Forwards App to CLI-87-12 Omitted from Text of Order as Served

Forwards App to CLI-87-12 Omitted from Text of Order as Served

ML20149L030
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/19/1988
From:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
To:	LONG ISLAND LIGHTING CO., Atomic Safety and Licensing Board Panel, NRC OFFICE OF THE GENERAL COUNSEL (OGC), SUFFOLK COUNTY, NY
References
CON-#188-5637 CLI-87-12, OL-3, NUDOCS 8802240078
Download: ML20149L030 (4)

Text

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SERVED FEB 221988 l

SLS.TECP: APPDOIX 'IO CLI-87-12 REFERDCE: DCCET No. 50-322-OL-3 Pecently, it was discovered that the three page appendix cited on page 3, footnote 1 of CLI-87-12 was not included with the text of the Order as served.

A copy of the appendix is attached.

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. Hoyle /

J Secretary of the Ccanission cc: Service List 8802240078 880219 PDR ADOCK 05000322 O PDR

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APPENDIX Contention 22.8.

l Che NRC has recognized that in the event of certain serious accidents, protective actions would need to be taken beyond a 10-mile EPZ. See NUREG 0654,Section I.D.2 at 11 and 12.

The site specific characteristics and consequences of a severe accident at Shoreham would make such protective actions essential to comply with the Federal PAG guidance and 10 CFR Section 50.47(b)(10).

The area of Long Island which surrounds Shoreham, particularly the area which lies eest of LILCO's proposed EPZ (including the towns of East Hampton, Southold, Shelter Island, most of Riverhead and virtually all of Southampton),

possesses a number of distinguishing characteristics, which taken together, contribute to the need to plan beyond the 10-mile EPZ proposed by LILCO. Among these distinguishing characteristics are the following:

l. A sigaificant seasonal increase in population, particularly during the five months of May through September;

2. A highly transient, dispersed seasonal population, much of which depends upon limited public transportation; ,

3. A road network which is inadequate to accommodate this seasonal population and which is heavily congested '

during ordinary seasonal conditions;

4. Due to Long Island's configuration, the inadequate road network on the north and south forks connects to two principal east-west arteries, the Long Island Expressway and Sunrise Highway, both of.which pass through or very close to LILCO's proposed EPZ;

5. The area east of the EPZ provides no means of i

exodus to the east, meaning that persons deciding to evacuate must travel toward and through LILCO's EPZ.

Studies show that large numbers of people in this area vill  ;

spontaneously evacuate toward the EPZ; i

6. The governmental resources available to control, communicate with, direct, shelter, provide security and otherwise accommodate this seasonal population are inadequate. Further, as noted in part A, no governmental resources will be available and thus all response is a LILCO responsibility.

LILCO's LERO lacks capability to expand response to an emergency from the 10-mile EPZ to a larger (This area unless detailed advance planning is in place.  ;

i might be different if governmental entities hav(ing) greater l

a

2 i

resources and experience than LILCO were participating in the response)  !

7. One of the five towns east of the EP3 (Shelter Island) is itself an island, which further aggravates its i

traffic and transportation concernst and, ,

8. In addition to the complications caused by .

seasonal population, transportation east of the EPI is I

affected by flooding and snow storms at various times during i the year. i Intervenors. contend that these site specific characteristics '

which exist for Shoreham demonstrate that local emergency i response needs and capabilities require planning andSuch j preparedness beyond LILCO's proposed 10-mile EP3.  !

planning and preparedness are necessary to assure theel i response efforts which may be required in the event of a serious accident. LILCO has failed to provide planning or

a. '

preparedness for any area beyond 10 miles from the plant, i

despite the site specific consequences which Thus, thecould LILCOresult Plan ,

from a severe accident at Shoreham. l does not provide a substantial base for the expansion of l' response efforts which is likely to prove necessary and such

- efforts could not be developed during This the is contrary course of to anthe <

accident based on LILCO's Plan.

. guidance of NUREG 0654, cection II.D.2 and 10 CFR l l'

section 50.47(b)(10).  ;

)  ;

Contention 22.C.

i An EP2 larger than 10 miles is required for the additional '

reason that people from outside the 10-mile EPZWithout will attempt  ;

to evacuate, whether ordered to do so or not. l l planning and preparedness for an area beyond 10 miles, which j I

takes local conditions (see (B) above) and voluntary ,

evacuation into account, the voluntary evacuation will ,

impede the evacuation of persons within the 10-mile EPs and l in inadequate protection for persons both inside '

will result Thus, in light of local

! and outside the 10-mile EP2.

conditions and the voluntary evacuation which will exacerbate the effects of such local conditions, LILCO's plan an EP1 that l is larger than 10 miles is required.  ;

essentially ignores any planning for voluntary evacuees and this is inadequate.

(For a detailed discussion of voluntary i see evacuation (the ' evacuation shadow

• phenomenon), l i

! Contention 23).  !

i An EPs intger than 10 miles is further necessary to provide planning and preparedness for the education, notification, 4 .

l l \

a a I 3

and safe movement and relocation of the large number of people likely to be on the roads in the event of a shoreham i emergency. A high proportion of the voluntary evacuees will 4

be from the eastern end of Long Island. Due to their perception that they would be trapped if the wind blew to the east, many East End residents will chcose to evacuate in In voluntarily the event of an emergency at Shoreham.

evacuating, they will move to the west, in some cases entering the 10-mile EP3. In order to protect these people, and to ensure that their voluntary evacuation does not adversely affect people within 10 miles of the plant, the i EP2 must be extended so that detailed planning encompasses

' the people to the east of the plant.

Further, large numbers of people to the west of the plant may also voluntarily evacuate, creating congestion for those attempting to leave the 10-mile EPZ proposed by LILCO and also affecting the safety of those people east of the plant who may also voluntarily evacuate. Extension of the EP2 to the west to encompass those persons who may be involved in protective actions is essential.

LILCO has not adequately provided for communications, security, blockades, relocation centers, medical facilities or any other protective actions for the area outside the proposed 10-mile EP2 in order to mitigate the impact of i

spontaneous evacuation on the adequacy of implementability of protective actions in LILCO's proposed 10-mile EPI, or to Failurd to develop at i prevent any such impact altogether.

1 this time emergency planning measures for the area outside the 10-m11e EPZ will result in uncontrolled, chaotic I evacuation should a serious accident occur at Shoreham, j

thereby affecting LILCO's efforts to manage the evacuation l

of persons within its EPZ and causing fear, panic, r accidents, looting, possible violence and other phenomena beyond the control of the officials in the area east of the EP3. Thus, an EPZ of larger than 10 miles is necessary to achieve compliance with 10 CFR Section 50.47(a)(1).

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