ML20072F228

Forwards Anl Rept, Element-By-Element Review of Lilco Transition Module of Shoreham Nuclear Power Station Offsite Radiological Emergency Response Plan, in Response to 830601 Request

ML20072F228
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/23/1983
From:	Krimm R Federal Emergency Management Agency
To:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20072F232	List: ML20072F228 ML20072F240
References
NUDOCS 8306270305
Download: ML20072F228 (2)

Text

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np Federal Emergency Managenient Agency I

1. q Washington, D.C. 20472 b, ,#

JUN 2 3 tgg MEMORANDUM FOR: Edward L. Jordan

t. Director, Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U.S. Nucle 3p ulatory Commission fL HA ~~'

FROM: RTFita E N. Krimm..__

Assistant Associate Director Office of Natural and Technological Hazards

SUBJECT:

Findings on the LILCO Transition Plan As Requested by the NRC as Part of NRC Licensing of the Shoreham Nuclear Power Station This is in response to your June 1,1983, memorandum in which you invoked Section II.4 of the November 1,1980, NRC/ FEMA Memorandum of Understanding by requesting the Federal Emergency Management Agency (FEMA) to provide the Nuclear Regulatory Commission (NRC) with findings and determinations as to whether the LILCO-County plan and/or the interim plans for the Shoreham Nuclear Station are adequate and capable of implementation. As a result of an Atomic Safety and Licensing Board (ASLB) order, your subsequent memorandum of June 17, 1983, requested that FEMA provide findings and determinations on the LILCO Transition Plan as a first priority. This Plan, developed wholly by LILCO, proposes to use LILCO l personnel to carry out the offsite preparedness aspects of the plaa (to include the total direction and control function) in the case of an emergency involving an accident at the Shoreham Nuclear Power Station.

First, we would like to indicate how the review process for the LILCO Transition Plan differed from the usual "350" approval process. As you know, under normal processing, the plan review is initiated by a formal request by the Governor of the State in which the nuclear f acility is located, after he/she has received and analyzed plans submitted by the local governments in the emergency planning zone surrounding the facility. The request includes the State plan which is site-specific to the applicable power f acility, appropriate local plans and a statement by the Governor that the State plan, together with the local plans, are l adequate to protect public health and safety of the citizens living

within the emergency planning zones for the nuclear power f acilities included in the submission by providing reasonable assurance that appropriate protective measures can and will be taken in the event of a radiological emergency fcr the site. The FEMA processing of a Governor's submittal l includes extensive review by the relevant Regional Assistance Committee (RAC), a public meeting and most importantly, a drill or exercise, including all appropria

e governments, to test whether the plan can be implemented.

l 8306270305 830623 PDR ADOCK 05000322

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_2-In contrast to the process described above, the LILCO Transition Plan was o submitted, without Suffolk County or New York State endorsement, directly to FEMA Headquarters through the NRC for review under the terms of the NRC/ FEMA Memorandum of Understanding. Because the Plan was not submitted under 44 CFR 350, a RAC review was not undertaken. For this reason, coupled with the fact that the NRC needed a FEMA finding within three weeks, it was necessary to obtain the support of Argonne National Laboratories i to assist and perform a technical review of the plan against the 16 planning standards and criteria (A-P) listed in NUREGM)654/ FEMA-REP-1, Rev. 1. FEMA Headquarters, assisted by FEMA's Region II Regional Director and staff, directed this technical review. t FEMA finds that the LIIf0 Transition Plan has 34 inadequacies in terms of NUREG-0654/ FEMA-REP-1, Rev. 1. Our analysis relating these inadequacies to the various criteria is attached.

There are two preconditions,' identified below, that need to be met for a FEMA finding as to whether the plan is capable of being implemented and whether LILCO has the ability to implement the plan.

(1) A determination of whether LILCO has the appropriate legal authority to assume management and implementation of an offsite emergency response plan.

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(2) A demonstration through a full-scale exercise that LIICO has the ability to implement an offsite plan that has been found to be adequate.

FEMA will continue to review the other plans associated with your June 1 request in anticipation that the ASLB will require FEMA findings on these plans at a later date.

Attachment As Stated f

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