ML20063A192
| ML20063A192 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/20/1982 |
| From: | Sedky C, Shaapiro R, Shapiro R, James Shea Cammer & Shapiro, KIRKPATRICK & LOCKHART, NORTH SHORE COMMITTEE AGAINST NUCLEAR & THERMAL POLLU, SHOREHAM OPPONENTS COALITION, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8208240229 | |
| Download: ML20063A192 (35) | |
Text
-- --
s
' s DOCXETED UWC UNITED STATES OF AMERICA '82 E2 ?0 P 3 :50 NUCLEAR REGULATORY COMMISSION OFFN; .r c ._,,- g a ,
00C!<,'{ il25 6 SEH /iCF
= c. t 1:CH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.
) (Emergency Planning (Shoreham huclear Power i Proceedings)
Station, Unit 1) )
)
)
)
PHASE ONE CONSOLIDATED EMERGENCY PLANNING CONTENTIONS INTRODUCTION Pursuant to the Board's Order of July 27, 1982, Suffolk County, the Shoreham Opponents Coalition (SOC), and the North Shore Committee Against Nuclear and Thermal Pollution (NSC) hereby submit the following contentions with respect to those emergency planning issues that the Board has defined as pres-ently subject to litigation in " Phase One" of the Shoreham operating license proceedings.
820 8240229 q b
t ,
In the July 27, 1982 Order, the Board deferred considera-tion of other contentions of the intervenors, as set forth in the First Amended Consolidated Emergency Planning Contentions filed in the proceeding, all of which continue to be advanced by the'intervenors. In compliance with that Order, and over Suffolk County's objections to such Order, the intervenors set forth below their " Phase One" contentions, without prejudice to any of their rights with respect to other contentions they have advanced but of which the Board has deferred consideration.
The Board and parties to these proceedings should note that the consolidated contentions now contain issues concerning the Technical Support Center (EP 24) and the. iodine monitoring system (EP 14C). The County had reserved the right to file contentions on those issues in its first amended contentions filed on July 6, 1982. Furthermore, based upon its review of the materials provided to it by LILCO, the County has withdrawn its contentions with regard to the permanent Safety Parameter Display System but reserves the right to file a new contention on the SPDS if, upon installation, it does not conform with the specifications and capabilities as set forth by LILCO.
The Board should also be advised that the County and LILCO have reviewed and discussed resolution of several issues. The time and logistical demands of meeting the requirements of the compressed disco ery schedule imposed by the Board has not 1 8 permitted the County to spend substantial amounts of time in settlement discussions. Nevertheless, the County believes that further discussions, when time permits, could prove fruitful with respect to:
- 2. Training of LILCO personnel (EP 7B of July 6 contentions);
- 3. Exercises (EP 17 of July 6 contentions);
While these and other resolution proposals which the County is considering will require further discussion and refinement, the County expects that the above-listed contetions may be capable of resolution but has included those contentions in this plead-ing in order to preserve its rights until final resolution of the issues.
PHASE ONE CONTENTIONS EPl: LILCO'S FAILURE TO ACCOUNT FOR THE SPECIFIC CONDITIONS EXISTING ON LONG ISLAND (SC, joined by SOC and NSC)
The Board should rule that LILCO's plan as a whole is in-adequate under 10 CFR $50.47(a)(1),(a)(2) and (b), in that it does not provide reasonable asurance that adequate protective measures can and will be taken in the event of a r diological t 8 emergency; nor does the plan provide reasonable assurance that it is capable of being implemented.
The basis for this contention is that the LILCO emergency plan cannot " provide reasonable assurance that adequate protec-tive measures can and will be taken" and cannot provide reason-able assurance that it is " capable of'being implemented" unless the plan has accounted for local conditions in the vicinity which directly affect whether adequate protective measures "can and will be taken" and whether the plan is " capable of being implemented."
In developing its emergency plan; LILCO has not determined the types and sizes of radiological releases to be expected from pos'sible accidents at the Shoreham plant; it has not de-termined the physical dispersion of such radiological releases on Long Island and proximate areas; it has not determined the populations at risk from such radiological releases; it has not determined the likely reactions of such populations to notifi-cation that they are at risk; it has not determined what pro-tective actions should be recommended from such notified popu-lations", it has not determined who should give such notifica-tion and how that should be done; and it has not determined what type of education is required for such populations (and for Long Island populations not significantly at risk from ra-diation) and when and how to provide that education.
r e Specifically, the local conditions which LILCO has not taken into. account are the following: l
- 1. Local demographic, socio-economic and social and behavioral characteristics of the population affected by a radiological emergency, including:
i
- 1. Where people live;
- 11. Where people work; l 111. Whether the officials or organizations which will inform Long Island residents of an accident ,
at the Shoreham plant are credible sources of !
information; [
iv. The educational level and nuclear-related know- ;
ledge and predispositions of the residents of '
Long Island, so as to tailor education and noti- ,
fication programs to their needs.
- v. How the residents of Long Island will respond to notification of a radiological emergency, par-ticularly Whether they will obey instructions to take a specific protective action or Whether they will attempt to flee and, if so, how fami-lies separated by work or school will seek to unite or depart individually.
vi. How the location and perception of location of the residents in Long Island (including the East End) would affect their reactions to a radiolog-ical emergency.
vii. Whether role conflicts will reduce the size and reliability of emergency workers Who would be required during an accident at the Shoreham plant.
- 2. What physical access and ease of access people
- actually have to roads, bridges, transportation faci-lities and other means of egress.
I i
4
+ -, , --- , - - - , -
e s
- 3. The types of materials of which local houses and other buildings are constructed and the extent to which those materials would affect the health conse-quences of a radioactive relese in the event that sheltering is the recommended protective action.
EP2: PROMPT NOTIFICATION SYSTEM (SC, joined by NSC and SOC)
LILCO intends that individuals situated within a 10-mile radius of the plant will be alerted to a radiological emergency through 89 sirens and approximately 150 tone alert receivers (Plan at 6-11 through 6-12; Wyle Laboratories Report WR 82-10 at 4-3). LILCO's system,.known as the " Prompt Notification System," is inadequate to effectively notify the population which may be affected by a radiological emergency and thus fails to meet the requirements of 10 CFR If50.47(b)(5) and (6),
10 CFR Part 50, Appendix E, Item D.2 and NUREG 0654, Items II.E and F for the following reasons:
A. LILCO has failed to demonstrate that the siren cover-age will not be constricted significantly during weather conditions such as rain, snow and fog, which
{
t have a tendency to muffle sound, as well as during high winds and thunderstorms vihich may adversely l
affect the ability to hear the siren.
l t
l l
D. LILCO has not adequately demonstrated that in the event of a loss of power to all or part of the sys-tem, it could provide backup power in time to offer timely warning to the population.
C. LILCO's prompt notification system does not provide complete siren coverage of all of the population within the EPZ as shown by the gaps evident on the map appended to the Wyle Report. LILCO has not ade-t quately provided for notification of individuals who may be within the areas not covered by sirens.
D. For notification of large facilities within a 10-mile zone around the Shoreham Plant (including 50 schools, 15 nursery schools, 14 nursing homes, 36 recreational areas, and 11 major employers), LILCO intends to alert a central location within each such facility with a tone alert radio. This places the responsi-bility for notifying the remaining inhabitants of l
! each large facility upon the institution or organiza-tion in question. LILCO's plan is not capaole of being implemented in that:
(1) LILCO has made no inquiry of the affected faci-lities to determine whether each such facility I
has sufficient in-house paging or alerting capa-bilities to carry out the notification task.
1 I
i
Nor has LILCO made any arrangements with each facility for the development of appropriate mes-sages and instructions for dissemination to its personnel, and for the holding of drills to test the adequacy of its internal notification sys-tem.
(2) LILCO has failed to obtain the agreement of each such organization or facility to bear notifica-tion responsibilities and to effectively imple-ment such responsibilities.
E. There is no indication within the LILCO plan that LILCO has in place an effective program to properly verify the operability of the tone alert system.
EP3: MEDICAL AND PUBLIC HEALTH SUPPORT (SC, joined by NSC and SOC)
A. Suffolk County contends that LILCO, by designating Central Suffolk Fospital as the primary medical fa-cility to treat contaminated injured individuals (Plan at 6-16), and further by designating University Hospital in Philadelphia, Pennsylvania for backup medical treatment (Plan at 6-16), has failed to pro-vide adequate medical services for contaminated injured individuals as required by 10 CFR $50.47(b)
(12), 10 CFR Part 50, Appendix E, Items IV.E.5
. i through 7; and NUREG 0654, Items K and L for the following reasons:
(1) LILCO's plan, if implemented, would constitute an emergency response so ineffectual that large number of the public would require hospitaliza-tion for radiation injury. Thus, hundreds of thousands of people will be gridlocked in traf-fic jams for hours in automobiles that furnish virtually no shelter from radiation. In a se-vere radiological accident; many of these indi-viduals are likely to receive radiation injury which would require hospitalization. Central Suffolk Hospital cannot accomodate such a large number of individuals.
(2) Central Suffolk Hospital may itself become sub-ject to radiological exposure and/or evacuation given its location approximately nine miles from the Shoreham site (Plan at 6-16).
(3) University Hospital is too distant to provide timely treatment of contaminated individuals.
(4) Central Suffolk Hospital does not have the ca-
.pacity to treat and/or decontaminate the many contaminated injured persons who are likely to require treatment in the event of a radiological emergency.
_9_
B. Furthermore, LILCO has failed to adequately demon-strate that ground transportation (Plan at 6-16) is adequate for conveyance of those persons Who would require hospitalization for radiation injury and/or of contaminated injured individuals to Central Suffolk Hospital under the congested traffic or radi-ological conditions that are likely to exist during a radiological emergency. Thus, LILCO has failed to satisfy 10 CFR 50.47(b)(12), 10 CFR Part 50, Appendix E, Item IV.E.6, and NUREG 0654, Item II.L.4.
C. The LILCO plan does not contain up-to-date agreements with Central Suffolk Hospital, University Hospital or the Wading River Fire District for emergency medical services to be provided by those facilities.
Moreover, the agreements with Central Suffolk Hospital and the Wading River Fire Department, as described in the LILCO plan at Appendix B, do not provide reasonable assurance that those organizations have the capability to deliver and will deliver nec-essary medical services in the event of a radiologi-cal emergency. Furthermore, the LILCO plan does not contain up-to-date contracts with any other local fire, ambulance, or other such offsite organizations concerning the services Which those organizations
. i will provide in a radiological emergency. Thus, LILCO has failed to satisfy 10 CFR $$50.47 (b)(3). and (12); 10 CFR 50, Appendix E, and NUREG 0654, Items II.C.4 and L.4.
(NSC, joined by SOC; SC will participate as an interested County pursuant to 10 C.F.R. 62.715)
D. The Plan does not assure that off-site medical per-sonnel and equipment, such as ambulances and radiologically-related medical supplies and equip-ment, will be available if an on-site emergency re-quires those services. Therefore the Plan does meet the standards of 10 CFR 50.47(b)(6)(8), 10 CFR 50, Appendix E, IV Para. E(1)(3)(4)(5)(6)(7) and NUREG 0654, II L(1)(2)(3), in the following respects:
(1) The Plan does not provide assurance that off-site medical personnel required for on-site medical assistance have been trained to treat individuals sickened or injured by a radiologi-cal emergency.
(2) If they have so been trained, there is no proce-dure to notify them to report, or if notified, that they will be available.
(3) If properly trained off-site medical and health-related personnel is available, the Plan
. e does not require that route instructions to reach Shoreham shall have been previously furni-shed or that appropriate identification to per-mit ready entry into the plant has been pre-viously issued.
(4) The Plan has no provision to assure that vehi-cles and trained personnel to staff the vehicles will be available to transport persons requiring off-site medical treatment.
(5) There are no procedures to relate the level of medical training and assistance which should be available to the escalating EAL levels in Plan
$4.
EP4: FEDERAL RESOURCES (SC, joined by NSC and SOC)
The LILCO plan (Plan at 5-8) fails to provide for incor-poration of Federal response capabilities into the plan. The plan states that "although no federal assistance is expected" other than that to be provided for in the Suffolk County plan and other non-LILCO plans, the LILCO " Response Manager has the authority to request any and all Federal assistance considered appropriate for'the given situation" (Plan at 5-8; see also 5-10). The plan makes no mention of specific Federal resources expected to arrive at the facility and their estimated time of 12 -
O t arrival, nor does it identify specific utility and local resources available to support the Federal response. In fail-ing to do so; Suffolk County contends, LILCO has not satisfied the requirements of 10.CFR $50.47 (b)(1),(2) and (3), 10 CFP Part 50, Appendix E, Item IV.A.7, and NUREG 0654, Items A.2 and 3, and C.l.
EPS: PROTECTIVE ACTIONS (SC, joined by NSC and SCC)
Suffolk County contends that LILCO has not met the re-quirements of 10 CFR $50.4'(b)(10), 10 CFR Part 50, Appendix E, Item B, or NUREG 0654, Item II.J with respect to development and implementation of a range of protective actions for emer-gency workers and the public within the plume exposure pathway EPZ and with respect to development of guidelines for the choices of such actions in that the LILCO plan and procedures do not adequately discuss the bases for the choice of recom-mended protective actions (i.e., the choice between various rangec of evacuation vs. sheltering vs. other options) for the plume exposure pathway EPZ during emergency conditions. In addition, LILCO has not assessed the relative benefits of var-l ious protective actions under the particular conditions exist-ing in the Shoreham vicinity. Thus; LILCO does not have suffi-cient knowledge or information to. provide reliable, accurate l
protective action recommendations.
l l
l !
l L
/ r e e
, ^
- e .
) ,
{ 't
?
? - ,s /
,EP6: OFFSITE FESPONSE ORGANIZATION'AND
',-GNSITE RESPONSE AUGMENTATION
'l j :j f .
~
I Suffolk County conter;ds that LILCO has failed to provide j/*, l
i-reasonable assurance that onsite assistance from offsite agen-
!< .. j cies .will be Lforthcoming in the event of a radiological emer-
-/
gency ot,the Shoreham site.,(see, e.g.,
Plan at 5-8 dnd 6-15).
LILCO hap)therefore nod met the requirements of 10 CFR
,i _-
$ $ 50. 47 (b) (1 ) , ( 2 )', ( 3 ) , ( 8') ,.(12 ) and (15), 10 CFR Part 50, Appendix E, Item-a,aand NUREG 0654. In addition, LILCO has not
- c. - ?
demonstratep;adequatelyth;at -
t
'it vill be able to augment its onsite-emergency response, staff'i~n a timely manner (see Plan, Ch. 5). LILCO has also, therefore, failed to meet the require- ,
ments of 10 CFR 450.47(b)(1) a'nd (2). Thus:
A. It does no't appear that LILCO has addressed or ana-lyzed the possibility that offsite personnel and/or.
onsite augmenting personnel expected to report to the Shoreham site for emergency duty, would fail to re-port (or report in a timely manner) because of con-flicting family (or other)' duties that would arise in the event of a radiological emergency.
B. LILCO has not adequately demonstrated the possible effects of traffic congestion during evacuation of i the population upon the ability of offsite personnel and/or onsite augmenting personnel to respond promptly to the Shoreham site.
C. LILCO has not developed notification procedures for offsite response organizations and onsite personnel (both those onsite at the time of an emergency and those called to report for duty after an emergency has commenced) in a manner consistent with the emer-gency classification and action level scheme set ,
forth in NUREG 0054, Appendix 1. LILCO has, there-fore, not ensured that sufficient trained personnel will be available when required.
EP7: TRAINING (SC, joined by NSC and SOC)
A. Suffolk County contends that LILCO has failed to meet the training requirements of 10 CFR $650.47(b)(11) and (15), 10 CFR Part 50, Appendix E, Item F, and NUREG 0654, Items II.K and O for all personnel who may be called upon to assist in an emergency in that LILCO has not provided adequate assurance (Plan at 5-8) that fire, ambulance, and other such personnel from offsite agencies in the vicinity of the Shoreham plant which are expected to respond for emergency duty have received adequate radiological emergency response training. Without such training, the County contends that an adequate response as required by f50.47(b).
B. LILCO in Chapter 8 of its Plan, provides inadequate information regarding the training of its own person-nel. Accordingly; there is no assurance that their personnel will have adequate training, as required by 10 CFR f?(b)(11) and (15), to take the steps neces-sary to provide assistance in a radiological emer-gency.
EP8: ONSITE RESPONSE ORGANIZATION (SC, joined by NSC and SOC)
Suffolk County contends that LILCO has not satisfactorily delineated the responsibilities of LILCO response perronnel, nor has it demonstrated adequately that it will be able to aug-ment its emergency response staff in a timely manner. Thus, LILCO's emergency response plan is not in compliance with 10 CFR 50.47(b)(1)(2)(3) and (8), 10 CFR Part 50, Appendix E, Items A and C, and NUREG 0654, Items II.A,B,C and H for the l following reasons:
A. The LILCO plan at 5-4 through 5-8 does not clearly
- define and distinguish between the functions of the Emergency Director and the Response Manager; B. Table 5-1 does not clearly demonstrate LILCO's abi-lity to augment its staff within 30 minutes of decla-ration of an emergency and is not in compliance with l Table B-1 of NUREG 0654.
l l
t EP9: PUBLIC INFORMATION (SC, joined by NSC and SCC)
Suffolk County contends that LILCO has not made clear in its plan that Suffolk County officials should take a major role in determining the form and substance of public statements con-cerning actions occuring and to be taken during a radiological emergency, which role is not apparent from the face of the LILCO plan at 5-25 through 5-26. Therefore, LILCO is not in compliance with 10 CFR $$50.47(b)(~1),(3),(5) and (7), 10 CFR Part 50, Appendix E, and NUREG 0654, Items II.A,C,E and G.
EP10: EMERGENCY OPERATIONS FACILITY (SC, joined by NSC and SOC)
Suffolk County contends that LILCO's plan and procedures for operation of its Emergency Operations Facility is not in conformance with the requirements of 10 CFR {50.47(b)(8), 10 CFR Part 50, Appendix E, Item IV.B.8, and NUREG 0654, Item II.H in that:
A. The LILCO plan at 7-3 states that the EOF shall achieve operational readiness within two hours of declaration of an emergency. Such an activation time violates the one hour requirement of NUREG 0696.
B. There is, as yet, no provision for obtaining at the EOF, or at any other LILCO emergency response facili-ty, information relating to seismic phenomena (Plan at 7-9).
l C. LILCO proposes to activate its EOF only upon declara-tion of a Site Area or General Emergency (Plan at 7-2). The EOF should be activated at an earlier time in an accident to ensure operational readiness in the event that an accident escalates to a more severe classification level.
EPll: MESSAGES TO THE PUBLIC AND TO OFFSITE AUTHORITIES (SC, joined by NSC and SOC)
LILCO's plan does not include written messages intended for dissemination to the public through various media in the event of a radiological emergency, thus failing to meet the requirements of 10 CFR {$50.47(b)(5),(6) and (7), 10 CFR Part 50, Appendix E, Item IV.D, and NUREG 0654, Items II.E,F and G.
Furthermore, the LILCO plan does not provide the contents of I initial and followup messages to offsite authorities.
Therefore, LILCO does not meet the notification requirements of 10 CFR $450.47(b)(1),(2),(3),(4) and (5), 10 CFR Part 50, Appendix E, Item D, and NUREG 0654, Items II.A,B,C,D and E.
EP12: RADIOLOGICAL EXPOSURE (SC, joined by NSC and SOC)
LILCO has failed (Plan at 6-12 through 6-16 and related EPIPs) to demonstrate that it has established the means for controlling radiological exposures to emergency workers (both LILCO personnel and those from offsite agencies). Thus, it has
-not met the requirements of 10 CFR { 50.47(b)(ll) and (15), 10 CFR Part 50, Appendix E; and NUREG 0654, Items II.K and O in that: .
A. The plan inadequately describes provisions for moni-toring individuals evacuated from the site (Plan at 6-12).
B. The plan does not describe action levels for deter-mining the need for decontamination of emergency re-sponse personnel.
C. The plan does not adequately delineate guidelines for emergency workers to follow to ensure that exposures received by such workers are not excessive.
EP13: EMERGENCY CLASSIFICATION SYSTEM l (SC, joined by NSC and SOC)
LILCO, in Chapter 4 of its plan, has failed to establish an adequate Emergency Action Level (EAL) system as required by 10 CFR 50.47(b)(4), 10 CFR Part 50; Appendix E, and NUREG 0654, Items II.D.1 and 2 in that:
A. The system established by LILCO has not been com-pleted, as evidenced by the information missing from many of the EALs , including:
l Unusual Event No. 5; Alert No. 5; General Emergency No. 2- and
General Emergency 6b.
B. For each of the FSAR Chapter 15 initiating conditions set forth below, LILCO has failed to establish a cor-responding emergency action level or to demonstrate adequately that an emergency action level is not nec-essary:
FSAR Initiating Condition 15.1.5 15.1.13 15.1.8 15.1.14 15.1.9 15.1.15 15.1.10 15.1.16 15.1.11 15.1.17 15.1.13 15.1.24 15.1.25 EPl4: ACCIDENT ASSESSMENT AND MONITORING (SC, joined oy NSC and SOC)
Suffolk County contends that LILCO's plan (see Chapter 6) is inadequate with respect to its ability to assess and miti-gate accidents and monitor radiological releases from the l
Shoreham facility in the event of a radiological emergency.
Thus, LILCO has failed to comply with 10 CFR f50.47(b)(2),
(4), (8), (9) and (10), 10 CFR Part 50, Appendix E and NUREG 0654, Items II.B,D,H,I and J in the following respects:
A. LILCO's commitment to only three field monitoring teams (Plan at 6-8) is inadequate given the large area and population that will need to be covered in the event of an accident. Furthermore, LILCO's fail-ure to require deployment of monitoring teams prior to the site emergency stage, and the time necessary (60 minutes) for such deployment, are inadequate for timely monitoring of potential radiological releases.
B. LILCO does not intend to use real time monitors at fixed locations that can be remotely interrogated.
C. The equipment intended for use by LILCO to monitor plant effluent does not provide timely and accurate information as to the actual value of the quantity of iodine released to the environment in the case of a radiological accident. In the absence of such timely and accurate information, LILCO is unable to initiate an adequate response to the release of iodine to the environment in the case of such an accident.
D. The LILCO plan (Plan, Ch. 4) does not furnish specif-ic identification of the effluent radiation monitors and process radiation monitors to be used in deter-I mining accident classification for the various l Emergency Action Levels described in the LILCO plans.
i I
I
~
EP 15: COMMUNICATIONS WITH OFF-SITE RESPONSE ORGANIZATIONS (NSC, joined by SOC, SC will participate as an interested County pursuant to 10 CFR $2.715)
The Plan relies completely for communication with off-site national, state, and local response organizations upon tele-phone communications (e.g. 7.2.1 through 7.2.8) and on a low powered UHF Radio Based Station and a VHF Radio Based Station (7.2.10).1! It fails to meet the criteria of 10 CFR 50.47(b)(2)(5)(6), 10 CFR 50 Appendix E, IV Paras D(3) and E(9) and NUREG 0654, Appendix 3, Para C(l), in the following re-spects:
A. In so far as the Plan relies on telephone communica-tions (7.2.1 through 7.2.8), it does not take into account the possibility of (1) a power outage, (2) sabotage and (3) overload. This omission is espe-cially significant b;cause the Plan describes the Hotline ! as the " primary means for notification of the State and County of emergency conditions at Shoreham." (7.2.1; see also 5.4).
-l/ In this connection NSC notes that the Plan refers to the Suffolk County Radiological Emergency Response Plan (e.g.
5.3, 7.2.4). In view of the County's oft stated position that no such plan is now in existence and that its plan will not be filed until October, NSC requests a reserva-tion for additional contentions if the County's Plan, as q filed, should so require.
2/ Hotline (s) are " dedicated phone lines, made operational upon pick-up of the receiver and selection of desired location . . ." (7.2.1).
i
! l , . _ , - - - - .
. o i
B. Assuming that the telephone communications depend upon overhead, outdoor lines (there is nothing to the contrary in the Plan), the telephone communication network is vulnerable to extreme weather conditions, especially to sleet and ice formations on its lines and poles.
C. The Hotline communications network is inadequate be-cause (1) it is not connected to the NRC Bethesda office and its King of Prussia Regional Office (cf.
7.2.2), and (2) does not give titles and alternates of the personnel at both ends of the Hotline.
D. The Plan relies on commercial telephone lines as "the primary communication link" for hospitals, Coast Guard, and DOE (7.2.4). These lines will become overloaded in an emergency, thus preventing communi-cation with these vital offsite organizations.
E. The Plan does not describe the " redundant power sup-plies" (7.2) which purportedly insure communications with off-site facilities.3/ NSC understands a " power supply" to mean the source of the power to maintain the communications systems and not the different communication modes and systems.
3/ The back-up power source relates only to intra- and on-site communication (7.2.7).
. o F. The personnel to whom beepers are issued have varying responsibilities to notify response organizations.
However, the beeper requires them only to call in to predetermined numbers (7.2.9), using commercial tele-phone lines.
G. The Plan presents insufficient data about the cover-age and load capacity of the UHF and VHF Radio Based Stations (7.2.10) to assess their capabilities as reliable communications facilities with the response organizations and the Emergency News Center (7.1.5).
H. The Plan describes the National Ale'rt Warning System (NAWAS) as the " primary back-up communications link i
between the Shoreham site and off-site officia'is."
1 (7.2.3) It does not otherwise describe NAWAS and therefore it is impossible to determine if it can perform its assigned task. For example, there is no description of its load capacity, coverage, or tech-nical configuration; nor does it name the "off-site officials" and their agencies who are linked to NAWAS.
EP 16: STRESS ON COMMUNICATIONS / NOTIFICATIONS PERSONNEL (NSC, joined by SOC. SC will participate as an interested County pursuant to 10 CFR $2.715).
I The Plan training procedures (8.1.1 et seq.) for 1
i
- - = - - . - , . . .- .-
. o communications / notifications personnel (510) are flawed because they neither recognize nor respond to the need for special training of the LILCO personnel who are assigned to implement the communications and notifications procedures Plan $$5 and 7.A/ Therefore the Plan does not meet the criteria of 10 CFR 50.47(b)(1)(2)(4)(5)(7), 10 CFR 50, Appendix E, IV, Para.
D(1)(3) and NUREG 0654, Appendix A 3(c)(2), as follows:
A. The psychological and mental stress to which person-nel, both on site and off site, will be subjected when a radiologicil emergency occurs is not ad-dressed.
B. The training fails to include programs to motivate of f-site personnel (1) to leave their homes and fami-lies to report for duty at the plant, (2) to overcome a natural reluctance to respond to a hazardous situa-tion and (3) in any case, to subordinate considera-tions of family and personel safety. Thus, there is no assurance that personnel assigned to communication and notification will report to their stations and be sufficiently trained.
4/ This contention is not intended to litigate and specifi-cally excludes TMI-related issues considered in People v.
Nuclear Energy v. NRC, (DC. Cir., May 14, 1982, No.
81-1131) which is the subject of a Regulation.
. s C. The Plan (5.2.8, 5.2.9) assigns various personnel as communicators, but they do not appear to be included in the training program described in 8.1.1.
EPl7: PERSONNEL ~ ASSIGNMENTS TO COMMUNICATION / NOTIFICATION (NSC, joined by SOC. SC will participate as an interested County pursuant to CFR $2.715)
The Plan's assignment of personnel to communications and notification responsibility is inadequate, both in the number of personnel assigned and because it overburdens those assigned with too many tasks. It thus does not meet the standards of 10 CFR 50.47(b)(1) and (7), and 10 CFR Appendix E, IV Para D (1)(3) and (9), in the following respects:
A. The Plan at 5.2.1 assigns immediate responsibility and authority to react to the emergency to the Emergency Director who may be the on-shift Watch Engineer and who must at once shoulder the additional duties thrust upon him. There is no assurance that one person can perform these manifold non-delegable i tasks especially since it is impossible to foretell, with any precision, the length of time during which l
the Watch Engineer may be required to function in that dual capacity.
B. An insufficient number of personnel is assigned to i
the EOF to assure proper notification to off-site l
[
. 5 emergency support and response organizations (5.2.8, 5.5.1, 7.1.3)
C. The Plan has no safeguards against the possibility that the Emergency Director or the Response Manager may make communications / notifications decisions which conflict with State or County actions.
EP18: MEDICAL AND PUBLIC HEALTH FACILITIES SUPPORT The Plan does not assure that off-site medical personnel and equipment, such as ambulances and radiologically-related medical supplies and equipment, will be available if an on-site emergency requires those services. Therefore the Plan does not meet the standards .of 10 CFR 50.47(b)(6) and (8), 10 CFR 50, Appendix E, IV Para. E(1)(3)(4)(5)(6)(7) and NUREG 0654, II L(1)(2)(3), in the following respects:
A. The Plan does not provide assurance that off-site medical personnel required for on-site medical assis-tance have been trained to treat individuals sickened or injured by a radiological emergency.
B. If they have so been trained, there is no procedure to notify them to report, or if notified, that they will be available.
C. If properly trained off-site medical and health-related personnel are available, the Plan does o 4 2
l not require that route instructions to reach Shoreham shall have been previously furnished or that appro-priate identification to permit ready entry into the plant has been previously issued.
D. The Plan has no provision to assure that vehicles and trained personnel to staff the vehicles will be available to transport persons requiring off-site medical treatment.
E. There are no procedures to relate the level of medi-cal training and assistance which should be available to the escalating EAL levels in the Plan at Chapter 4.
EP19: RECOVERY AND REENTRY (SOC, joined by SC and NSC)
The applicant has failed to develop adequate procedures pursuant to 10 CFR $50.47(b)(13) and NUREG 0654 criteria that i address plant recovery and the determination of population doses, including procedures that describe when, how, under what conditions, and at what risk to the public, recovery will take place.
EP20: Interim Safety Parameter Display System (SPDS)
Suffolk County contends that the interim SPDS that LILCO proposes to utilize until the installation of a permanent SPDS is deficient because it does not meet minimum requirements for such a system. Specifically, the interim SPDS does not:
A. provide all required parameters INUREG 0696 at 26);
B. provide for data verification [NUREG 0696 at 24];
C. provide trending capability fNUREG 0696 at 25-262; D. provide information to the TSC and EOF [NUREG 0696 at 25]; and E. provide the function of aiding the operator in the interpretation of transients and accidents, nor does it provide this function during and following all events expected to occur during the life of the plant, including earthquakes [NUREG 0696 at 27].
l Thus, the interim SPDS does not meet the requirements of l
l 10 CFR { 50.47(b)(4), (8), and (9), 10 CFR Part 50, Appendix E, I
Items IV.E.2 and 8, 10 CFR Part 50, Appendix A, GDC 13, and NUREGs 0696, 0737 and 0654, Item I.
s i o EP21: EMERGENCY IMPLEMENTING PROCEDURES (SC, joined by SOC and NSC)
Suffolk County contends that LILCO's emergency plan imple-menting procedures (EPIPs) contain numerous blanks and missing information and that they are not complete and approved.
Therefore, they fail to meet the requirements of 10 CFR
$50.47(b), 10 CFR Part 50, Appendix E, Item V, and NUREG 0654, Item II.P.7.
EP22: ACCIDENT ASSESSMENT EQUIPMENT (SC, joined by SOC and NSC)
LILCO has failed to identify in its Emergency Action Level scheme (Plan Chapter 4; EPIP SP 69.010) the extent, if any, to which non-safety-related instruments and equipment will be re-lied upon. To the extent that non-safety-related instruments and equipment are relied upon in LILCO's Emergency Action Level scheme, LILCO has failed to demonstrate that such instruments and equipment are capable of providing accurate information during the course of an accident.
i Suffolk County contends that neither the LILCO plan, nor
- its EPIPs include information necessary to identify the class-ification or qualification of equipment to be used in assessing an accident condition or mitigating the results of an accident.
Thus, LILCO has not met the requirements of 10 CFR
- $$50.47(b)(8) and (9), 10 CFR Part 50, Appendix E and NUREG 0654, Items II.I.
O B EP23: ACCIDENT ~ ASSESSMENT AND DOSE ASSESSMENT MODELS (SC, joined by SOC and NSC)
LILCO's plan fails to provide reasonable assurance that adequate methods, systems and equipment for assessing and moni-toring actaal or potential off-site consequences of a radiolog-ical emergency condition are in use, and therefore does not comply with 10 C.F.R. 50.47(b)(9).
EP 24: TECHNICAL SUPPORT CENTER The LILCO plan (Plan at 7-2) states that the Technical Support Center ("TSC") will be functional at fuel load, pres-ently scheduled for September 20, 1982. Suffolk County con-tends that a TSC meeting the requirements of NUREG 0696 will not be functional by that date, thereby violating the provi-sions of 10 CFR 50.47 (b)(8) and (9), 10 CFR Part 50, Appendix E, Item IV.E and NUREG 0696.
. . i Respectfully submitted, David J. Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788
/
- l. -
HerberY Cherif SedW y rowd-[
Christopher M. McMurray KIRKPATRICK, LOCKHART, HILL,
, CHRISTOPHER & PHILLIPS 1900 M Street, N.W., 8th Floor Washington, D.C. 20036 Attorneys for Suffolk County f '
Ralph Shapiro AF /
CAMMER & SHAPIRO 9 East 40th Street New York, New York 10016 Attorney for the North Shore Committee Against Nuclear and j Thermal Pollution.
l l
e
- a John F. Shea, III J'/d
~ ' /7 -
Stephen B. Latham TWOMEY, LATHAM & SHEA P.O. Box 398
- Riverhead, N.Y. 11901 Attorneys for the Shoreham opponents Coalition Dated
- August 20, 1982
.I l
l
. _ _ _ _ . . _ m._. _
_.__,y . . _ - . . - ._. _ _ _ . _
o % o i
4 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
4
)
In the Matter of )
)
i LONG ISLAND LIGHTING COMPANY )
) Docket No. 50-322 (O.L.)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
CERTIFICATE OF SERVICE i
i I hereby certify that copies of " Phase One Consolidated
- Emergency Planning Contentions" was sent on August 20, 1982 by first class mail, except where otherwise noted, to the follow-1 ing
)
Lawrence Brenner, Esq.* Ralph Shapiro, Esq.
Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New York, New York 10016 Washington, D.C. 20555 i Howard L. Blau, Esq.
Dr. James L. Carpenter
- 217 Newbridge Road
- Administrative Judge Hicksville, New York 11801 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission W. Taylor Reveley III, Esq.**
Washington, D.C. 20555 Hunton & Williams P.O. Box 1535
' 707 East Main St.
Mr. Peter A. Morris
- Richmond, Virginia 23212 Administrative Judge i Atomic Safety and Licensing Board l U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger Washington, D.C. 20555 New York State Energy Office Agency Building 2 j Edward M. Barrett, Esq. Empire State Plaza l General Counsel Albany, New York 12223 Long Island Lighting Company l
250 Old Country Road Mineola, New York 11501 Stephen B. Latham, Esq.
Twomey, Latham & Shea Mr. Brian McCaffrey Attorneys at Law Long Island Lighting Company P.O. Box 398 175 East Old Country Road 33 West Second Street Hicksville, New York 11801 Riverhead, New York 11901
- By Hand **By Federal Express I
kae. .e Marc W. Goldsmith Mr. Jeff Smith Energy Research Group, Inc. Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O. Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq. MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A. Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter Cohalan Suffolk County Executive David H. Gilmartin, Esq. County Executive / Legislative Suffolk County Attorney Building County Executive / Legislative Bldg. Veterans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Ezra I. Bialik, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission New York State Department of Washington, D.C. 20555 Law 2 World Trade Center Docketing and Service Section New York, New York 10047 Office of the Secretary U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. Nuclear Pegulatory Bernard M. Bordenick, Esq.* Commission David A. Repka, Esq. Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Matthew J. Kelly, Esq.
Staff Counsel, New York Stuart Diamond State Public Service Comm.
Environment / Energy Writer 3 Rockefeller Plaza NEWSDAY Albany, New York 12223 Long Island, New York 11747 Cherif Sedky, Esq.
Kirkpatrick, Lockhart, Johnson & Hutchison 1500 Oliver Building Pittsburgh, Pennsylvania 15222 Cheriffedky /
KIRKPMRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS DATE: [/' M) !b 1900 M Street, Washington, D.C.
N.W., 8th Floor 20036