ML20006B793

Responds to to Carr Forwarding Article in New York Times Raising Concerns on Evacuation Plans for Facility.Directors Findings Re Shoreham Emergency Preparedness Encl

ML20006B793
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/29/1990
From:	Murley T Office of Nuclear Reactor Regulation
To:	Holmes L AFFILIATION NOT ASSIGNED
Shared Package
ML20006B794	List: ML20006B793 ML20006B977
References
NUDOCS 9002050360
Download: ML20006B793 (12)

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UNITED STATES.

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NUCLEAR REGULATORY COMMISSION

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f Ms. Linda G. Holmes

,30 Dinah Rock Road.

i Shelter Island, New York 11964

Dear Ms. Holmes:

I have been asked to respond to your letter to Chairman Carr dated January 9, f

1990. - As an enclosure, you' provided a copy of your editorial that appeared-in

the Long Island edition of The New York Times,.

I As you may know, the Commission granted a fuil-power operating license for the' Shoreham plant on April:20, 1989.

It was granted based, in part,.on thousands of inspection hours expended by. our staff, as well as on evaluations of emergency

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. preparedness performed by us and the Federal Emergency Management Agency. (FEMA).

. staff.

In addition, I have personally inspected the facility and the local

.1 m-areas to gain firsthand knowledge before I made my recommendations regarding the license. Enclosed zis a copy of my findings dealing with emergency preparedness at Shoreham.

I:can. assure you that the staff will' continue to monitor and verify the continuing: regulatory compliance of the' licensee of the Shoreham facility.

-1 Sincerely, Tliomas E. Murley, Director Office of Nuclear Reactor-Regulation

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Enclosure:

As stated 1T?

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JAN 2 81990

'. - A-Ms.-Linda G. Holmes 30 Dinah Rock Read Shelter Island, New York 11964

Dear Ms. Holmes:

I' have been asked to respond to your letter to Chairman Carr dated January 9, 1990.

As an enclosure, you provided a copy of your editoriel that appeared in the Long Island edition of The New York Times.

As you may know, the Comission granted a full-power operating license for the L

Shoreham plant on April 20, 1989.

It was granted based, in part, on thousands

-of inspection hours expended by our staff, as well as on evaluations of emergency preparedness performed by us and the Federal Emergency Management Agency (FEMA) staff. In addition, I have personally inspected the facility and the local-

- areas to gain firsthand knowledge before I made my recomendations regarding the license. Enclosed is a copy of my findings dealing with emergency i

preparedness at Shoreham.

I can assure you that the staff will continue to monitor and verify the continuing regulatory compliance of the licensee of the Shoreham facility.

l origYn signea by Thomass.Mur107 Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosure:

As stated DISTRIBUTION UocketF11e;(50'322)

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lQ Ms. Linda G. Holmes j

30 Dinah Rock Road Shelter Island, New York 11964

Dear Hs,

Holmes:

I have been asked to respond to your letter to Chairman arr dated January 9, 1990. As an enclosure, you provided a copy of your ed orial that appeared in the Long Island edition of The New York Times.

As you may know, the Commission granted a full-pow operating license for the Shoreham plant on April 20, 1989.

It was granted ased, in part, on thousands of inspection hours expended by our staff, as we as on evaluations of emergenc preparedness performed by us and the Federal Em rgency Management Agency (FEMA) y staff.

In addition, I have personally inspec d the facility and the local areas to gain firsthand knowledge before I m e any recommendations regarding 1

the license.

I can assure you_that the staff will cont nue to monitor and verify the continuing regulatory compliance of the icensee of the Shoreham facility.

Sincerely, Thomas E. Murley, Director Office of Nuclear Reactor Regulation DISTRIBUTION DocketFile(50-322)

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JAN 2 91990 Ms. Linda G. Holmes i

30 Dinah Rock Road Shelter. Island, New York 11964

Dear Ms. Holmes:

I have been asked to respond to your letter to Chairman Carr dated January 9, 1990.. As an enclosure, you provided a copy of your editorial that appeared in the Long Island edition of The New. York Times.

' As you may know, the Comission granted a full-power operating license for the Shoreham plant on April 20, 1989.

It was granted based, in part, on thousands of inspection hours expended by our staff, as well as on evaluations of emergency preparedness performed by us and the Federal Emergency Management Agency. (FEMA) staff.

In addition, 1.have personally inspected the facility and the local areas to gain firsthand knowledge before I made my recomendations regarding the license. Enclosed is a copy of my findings dealing with emergency preparedness at Shoreham.

I can assure you that the staff will continue to monitor and verify the continuing regulatory compliance of the licensee of the Shoreham facility, origfn alsned W n omasE.EarleY Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosure:

As stated DISTRIBUTION DocketFile(50-322)

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Previously concurred *

[H0LMESLETTER]

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1 ENCLOSURE'1 s

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'0IRECTOR'S FINDINGS REGARDING SHOREHAM EMERGENCY PREPARED 1

The issuence of a full power operating license requires a finding by NRC that 1

2 there is ressenoble assurance the act1vities to be authorized by the issuance of an operating 11 cense can be conducted without endangering the health and safety of the public.

In reaching this overall safety conclusion the NRC must i

make a related finoing of reasonable assurance that adequate protective

'i measures can and will be taken in the event of a radiological emergency. The following discussion outlines the NRC staff's conclusions regarding emergency

.c preparedness et Shoreham.

In oroer to place in perspective the safety finding that must be made regarding'

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emergency planning, it is first useful to describe how emergency planning fits into NRC's regulatory fabric.

The accident at Three Mile Island Unit 2 in 1979 taught an important lesson l

regarding emergency preparedness, it is essential that local emergency oscision-makers have a range of options for protective actions and that they do not have to rely on an ad hoc response to an emergency. Thus in the wake of the TMI-2.accioent NRC emended its regulations to improve emer,gency s

preparecness and thereby strengthen the defense-in-depth safety. philosophy.

Under this guiding philosopny the first level of safety is that NRC requires high Quality 'in the design, materials construction and operation of the plants, in order to reduce the chances, of equipment malfunctions or human errors that coulo lead to an accident.

The second level of safety is to assume that there can be f ailures of equipment p

or numen errors nonetheless, and to require safety systems that terminate the nuclear chain reaction and maintain fuel cooling after shutdown.

The third level of safety 1s to postulate that' fuel damage accidents can happen, in spite of the attention given to levels one and two, and to require a containment structure with associated safety systems-to prevent the release of j

radiotctivity to the environment.

Through the emergency preparedness regulations NRC in effect added a fourth

. level of safety by postulating the possibility of offsite radioactive releases and requiring that there be protective action opt 1uns for local authorities to take tu' reduce the dose to the population living in the vicinity of nuclear power plants in the event of a radiological emergency.

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Emergency preparedness can, therefore, be viewed as the last in a series of four levels in the oefense-in depth safety philosophy guicing NRC's regulations to protect the public. Our regulat1uns do not require perfection in emergency

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planning.

In fact, it is not possible to guarantee that emergency preparedness i

actions will protect all the people in the vicinity of a nuclear plant under all; accident conditions and in all weather conditions.

Our be reasonable assurance that protective actions can and w event of a radiclogical emergency.

f cynamic process. that perfection is not attainable, that deficiencies willW occur from time to time, and that deficiencies in emergency plans can be corrected when they appeer.

Turning now to Shoreham, a comparison of the geography of the Shoreham site with other nuclear plant sites leads tu the tonclusion that the Shoreham site compares favorably with other sites in the U.S. from an emergency planning i

standpoint.

The plant is located on a flat coastal plain, without complex terrain to complicate predictions of plume trajectory, in contrast with other sites set in hilly areas or in river valleys that present more difficult i

geographic conditions.

with other coastal sites having similar populctions within the EPZ.

well-developed transportation network within the EPZ, with several major highways traversing the EPZ in both the east-west and north-south directions, thus making evacuation planning.relatively straightforward. With regard to.

demographics, several nuclear sites in the U.S. have greater populations within theLten mile EPZ than does Shoreham.

Regarding weather, winters are less severe than at many other sites in the U.S.

because of the moderating effect of Shoreham being a coastal site.

Since heavy snows are relatively uncomon ano the surrounding terrain is generally flat, impeciments to evacuation should occur relatively infrequently at the site.

Like other sites along the Atlantic coast Shoreham is subject to hurricanes.

The plant will be required by license conc,ition to shut down in the event of an approaching hurricane. Hence, it is concluded that there are no unique features of the Shoreham site that render emergency planning fundamentally more difficult than for other nuclear sites in the U.S.

A A unique aspect of emergency planning at Shoreham, of course, is that New York and Suffolk County have refused to participate in offsite emergency planning at Shoreham.

This circumstance raises questions whether an effective emergency

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plan can be developed and whether the plan can be executed effectively.

1 LILCO has developed the Local Offsite Radiological Emergency Response Plan, which is implemented by the Local Emergency Response Organization (LER0) for the Shoreham site. LERO is comprised of LILCO and contractor personnel with support from organizations such as the U.S. Department of Energy (00E) located at Brookhaven National Laboratory (BNL) within the 10-mile EPZ.

DOE is an integral part of LERO, with responsibilities for radiological monitoring and dose assessment.

FEMA in coordination with NRC, has reviewed extensively the LERO plan and has found it to be a comprehensive, well integrated approach to emergency planning at the Shoreham site because:

It is well organized and complete.

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The' required LERO' staff under the plan is rostered at 150 per cent uf expected needs.

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- Adequate facilities and equipment are identified and provided.

All supervisory positions in the LERO plan are filled with supervisors or managers ~ in LILCO, who are reachable by pager for rapid response, l

LILCO employees and contractors fill all emergency response positions the utility therefore has the ability to assure that needed training, and occurs.

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The training program for offsite response is comprehensive, and. quarterly training orills are being done and will be required by license conditions.

The LERO plan was extensively litigated during the hearing process, was Llosely reviewed by FEMA's Interagency Regional Assistance Comittee end l

has been found acceptable by FEMA.

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P The LERO plan has provisions to evacuate the families of LERO emergency

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workers in order to relieve those workers of potential conflicting I

concerns between protecting their families ano meeting their-e responsibilities unoer the plan.

For the rec. sons above it is concluded that the LERO plan compares favorably with the emergency plans for many other sites in the U.S., which typically rely on volunteers for many local response functions during an emergency,

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With regard to the question of whether the LERO plan can be executed L

effectively, the staff assumes that State and local authorities will use thetr e

best efforts to protect the health and safety of the public in the event of an

-emergency at Shoreham and that, absent a. superior emergency plan, they will follow the LERO plan. Further, staff review indicates that State and local resources are adequate and available to support implementation of the LERO plan.

There remains the question, however, that if State and local authortties do not participate in preparing and exercising the LERO plan can eleventh hour participation by the State and County in an actual emergency,be effective in achieving the goal of dose savings for the population in the vicinity of Shoreham?

While it would be clearly preferable for the State and County to participate in planning and exercises, the LERO plan is written to accommodate State and County response at the eleventh hour.

LERO officials would activate the LERO Emergency Operations Center (EOC) at the Brentwood District Office at the Alert stage of an_ emergency, where they would set up ther 3nemend, control, and communications center.

There will be a designates LERa/ worker around the clock at the EOC, by license condition, to ensure the loy*vtical arrangements at the EOC can be made with no unoue delays.

If County officials choose to operate from the LERO EOC, there are space, facilities and information to enable them j

to function effectively.

If..on the other hand, County officials choose to operate from the Suffolk County EOC, a casignated LERO official will be available to provide full comunication between the County officials at the

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d County EOC and the LERO emergency managers at the LERO EOC.

A license

-condition requiring that a designated LERO official be dispatched automatically

'at the Alert stage to the County EOC with appropriate information and equipment will assure prompt establ.shment of consnunications.

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- Outside the EOC activities, LERO personnel would be dispatched to their offsite plan positions.

If State or County authorities arrive, the LERO responder is i

trainea to explain the function of the position to the individual with a

authority, anc the LERO responder then either assists or relinquishes control 4

s the situation dictates.

e and radiological precautions and will provide oosimetrLERO personnel are ttein advice to responding State or County representatives. y coverage and protective The presence of these trained LERO incividuals at the various response locations will be available to provide atiect support and shoulo result in enhanced performance of Stste and local authorities in their emergency response duties.

New York State has a well-ceveloped State emergency plan, has participated in numerous exercises with the other nuclear power plants in New York and has dlWdys performed Competently.

The LERO plan was developed to be compatible with the New York State Plan, and the stoff finds no serious impediments to implementing the LERO plan at the State level. Furthermore, although the State l

and County may not have formally participated in planning, some key officials are in f act very familiar with the LERO plan.

They have reviewed, comented upon and participated in the litigation of many issues concerning the LERO plan.

Therefore it is concluded, while acknowledging it would be clearly preferable

.for the State and County to participate in planning and in exercises, that the comprehensive LERO plan and the demonstrated ability of LERO to rapidly mobilize well-trained personnel provides assurance of effective emergency response actions even.in the event of eleventh hour participation by State anc County authorities in an actual emergency at Shoreham.

The adequacy of the LERO plan was tested in a February 13, 1986, exercise and most recently in a June 7-9, 1988, exercise. FEMA has advised NRC that the June 1988 exercise demonstrated adequate overall preparedness on the part of 1

LERO personnel. Based on their review of the LERO plan as well as the June 1988 exercise results, FEMA reached an overall fincing of adequacy regarding Shoreham offsite emergency preparedness.

With respect to onsite emergency preparedness the NRC staff has observed onsite drills ano exercises at Shoreham and has conducted inspections of LILCO's onsite emergency preparedness program. The staff concludes that the onsite-plan is adecuate and that there is reasonable assurance that it can and will be implemented in the event of an emergency at Shoreham.

In aedition to the broad issues discussed above, there are a number of outstanding emergency planning contentions that have arisen in the Shoreham hearings. Each of these contentions has been reviewed and has been found to be satisfacturily resolved. The evaluation of each contention is documented in a Director's Fir. dings report which has been provided to the Comission.

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l' In sumary, the following conclusions-have been reached:

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The Shoreham site compares favorably with other nuclear plant sites in the U.S.

There are no unique features of the site that render emergency planning;at Shoreham fundamentally more difficult than for other nuclear.

sites.

2.

The Shoreham offsite emergency plan as implemented by LER0 results in a response capability that is equivalent to or better than the response capability for many other sites in the U.S.

3.

Because of the thoroughness of the LERO plan and the demonstratec abilit of LERO to rapidly niobilize well trained personnel, effective energency'.y response actions can and will be taken in conjunction with the best i

efforts of State and County emergency response organizations.

4 The LERO plan has been found by FEMA to be edequate based on a thorough-review of the plan as well as an evaluation of a full-participation exercise at Shoreham on June 7-9, 1988.

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Each of the outstanding emergency planning contentions has been

-satisfactorily resolved, l

L lt is concluded, therefore, that there is reasonable assurance that adequate L

protective actions can and will be taken in the event of a radiological emergency at Shoreham.

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': FORWARDS NEWS ARTICLEiCONCERNING-THE SAFETY AND

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EVACUATION'PLANSzFOR'SHOREHAM N_

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SPECIALTINSTRUCTIONS OR REMARKS:.

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. PAPER NUMBER.

CRC-90-0049-LOGGING DATE: Jan'16 90-p

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Linda G.-Holmes AFFIL ATION::

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accident were fueled primer 9y by.the dis 4 by boat - if it's summertime and enough By LINDA GOETZ HOLMES closures of exp

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a the,mm. n.erts involved in construction -

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vessels are in the water.

NG ISLANDERS who opposed the op-The Atomic Energy Commission'(prede- - Three Md.

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.ymewadsp= * *nt At*= =pe,*new n= =ma=M had seven escape routes, all leading away eration of Iong Island Lighting Com-cessor to the Nucleer' Regulatory Commis-and ChernO 1are' fm W plant. Eastern Long Islanders de peny's nuclear plant at Shoreham ston) conducted pubHc hearings on Shore-not have that luxury, and we know M. -

i have been taken to task several ham when the plant was still in its blueprint -

7 times during the last year in the pages of. stage in the early 1970's. Suffolk County was alway 5 On'Our minds

• c..'."a,", m'd " ""d " " pbM Mal M M of the Brookhaven National Lab '

y newspapers.

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j representedatthosehearingsbyIrving Like, oretories (Shoreham is part of the Town of, We have le told that scrappind Sho[rd palawyerandnowatrusteeof theIsngIsland

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Brookhaven).

ham is fo*1y, that our fears of tatsafe operal ~

tion and evacuation. A..;areemangerat-) Power Atrthority,It is a matterof pedilic record that Mr. Like

• are afraid d Shorehem?She told me how,in the wake of Three Mlle; i

Around the thne Mr. B.O. "_

" made Island, the management at Brookh&ven Labs r

l ed aM that the' plant is'not unsafe. *11te? raised the spuestion;of feasible evacuation i

decommissioning of Sherehnen, now tmder, j pescedures at that time, but the A.E.C. re-? his public comments,~ a local newspaper. had decided te conduct an evacuation drHL sige,gst of articles based on docu-

"rm stlH shaking" she said. "I am usuelty!

I may, was termed vindictive by White HouseT sponded that it would not consider that sub-E olitained'fmet an engineer who had home frown work in 30 minutes. The day of the [

Chief of Staff John Sununu, who suggested ' Ject smtff after treeplant was buGLTo me,this that Shoreham be mothbelled besteed, a view: decistort by the A.E.C.iwas the trisly historic @Ztpdt die M'M taken his mites to.drill, it took me 20 minutes just to get out of supported by Federsi energy officials. And. s folly. There Shoreham stands:'a bilHon-dst-M die Soudeoid letra dump, and phonM a re-.

the parking lot. My knuckles were white,i portw;who N h *

, gripping the steering wheel, as I wondered j some members of Congress see the abandon-lar monument to unresolved questions.

So what k would be like if this were real" ment of Shoreham as a sernwapes weste of As a tempsyer,'I share the dismty ex-;.,,.rm EastMWs fond die engl2 -

s mates hard is Aprget diey descrHiM No press releases were issued about that !

pressed by some members of Congrass, but " p,ipes ~lnetaBed'upsidC h M bein[' Brookhaven la taxpayers' money.,

rill, and according to my travel ca..,-...-, ;

However, tro key factors about Shoreham

, all Federal agencies exist with our tsmes; J are consistently being overlooked by our and when tfwy blunder, we au pay.

• covered rev'er/ad' edter ~ h e"

.../.,,,a were instructed :

not to diseass it.

Wavethn N seassurances critics. First, consideration of evacuation in May 1976, at a sneeting in Riverhead r Sure fan upset at the thought of guaran $

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[*" I"P"**U'I" e teed annual hikes in my electricity bens for i plans has c6me at the end of the licensing (about 18 miles east of Shorehoin). Dale y "*""'

g process because of a ruling by Atomic Ener-BC 1

f. a former engineer friGeneral,,

Fy Commission officials, not as a last-ditch Electric (which sold the core containment -

"W M Wred W the seext 19 years; Tm still reeling from a 29 ;

effort by Shoreham opponents.

system to Luce for instanetira at Shore-M what %imants us, not our " percent increase in this year's local tames.

1 Second, public fears about the safety of ham), told a capacity crewd that the system - exaggwated $sers d the unkunm.

It's bizarre that higher utility rates sud i Shoncham and theincreased likelihood of an", had design cerects which ceukt lead to a.

AnymewhoMesen eeskrnIengIslandis denly seem like the lesser of two evils. In 4

% steam explosion or a fuel meltdown. Three painfuny aware that most W us have just two fact, the Shoreham situation is beginning to ;

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Linda Goetz Holmes is a former member ; years later, we had Three Mile Island. Is it opens fwimme travelin die event of a. remind me of the old comedy routine:

of the Shelter Island Town Planning Board.

any wonder that some isngisland residents nistlear mishop: by land, past Shorchem, or "Why do you let them hit you on the head?" !

"It feels so goM when they stop.**

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