ML20072G718

Draft Emergency Planning Contentions of Town of Southampton. Certificate of Svc Encl

ML20072G718
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/22/1983
From:	James Shea SOUTHAMPTON, NY, TWOMEY, LATHAM & SHEA
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20072G705	List: ML20072G697 ML20072G718
References
NUDOCS 8306280608
Download: ML20072G718 (8)

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UNITED STATES OF AMERICA $4 $N 72 k g p $,te-NUCLEAR REGULATORY COMMISSION f c4# /

BUFORE THE ATOMIC SAFETY AND LICENSING BOARD i lj In the Matter ot )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322

) (Emergency Planning)

(Snoreham Nuclear Power Station,)

Unit 1) )

DRAFT CONTENTIONS OF THE TOWN OF SOUTHAMPTON REGARDING EMBRGENCY PLANNING The Town of Southampton has attempted to coordinate its emer-gency planning contentions with the other intervenors. Due to last minute dirticulties arising from the distance between the parties and*the limitations ot the equipment available to some or the parties, not all of Southampton's contentions have been inte-grated into the document being prepared by Sutfolk County.

Accordingly, Southampton is submitting the annexed additional emergency planning contentions.

TW EY & SHEA b_ .'

J hr F. Sh5Ea , III At c rneys for the TowM of Southampton 33 West becond Street Post urtice Box 398 Rivernead, New York 11901 Dated: Riverhead, New York June 22, 1983 8306280608 830623 PDR ADOCK 05000322 PDR g

Town et Southampton, Contention 1 Actual surveys of people living outside and to the east at the proposed 10 mile EPZ demonstrate that substantial numbers of people will attempt to evacuate even it told not to do so. In cases or individuals who live east or the SPZ, their evacuation will take them through a portion of the EPZ and thereby adversely effect LILCO's erforts to evacuate people and otherwise respond to an emergency witnin the EPZ. LILCO has made no plans for this attect and assumes that randon, uncontrolled evacuation trom east of the zone will not aftect evacuation and emergency response from witnin'the zone. LILCO's plan does not provide for the adequate perimeter, traffic, and security controls and other lesources necessary to solve this problem.

Town of Southampton, Contention 2 LILCO's Emergency Plan is detective in that it fails to plan l

for the contingency in wnicn evacuation or otner emergency responses beyond 10 miles and to the east may be required . The regulations and supporting documents (i.e., NURSG-06S4 at pp. 10 -

i 12, and NUREG-0396 at p. 15, and Appendex 1-37 ) confirm that dose levels greater tnan the PAG's may be reached beyond tne 10 mile EPZ and suggest that in some cases emergency planning beyond 10 miles may have to be implemented on an ad hoc basis using the same criteria for the 10 mile EPZ if necessary (ie., by simple "expan-

sion" of EP response). However, due to eastern Long Island's unique geographic characteristics, its lano use, limitec road network, and heavy seasonal population Ilows, such an ad hoc response woulo not be possible. LILCO's plan must provice for this contingency.

Town of Southampton Contention 3 Actual surveys of people living east (or outside) of the pro-posed 10 mile SPZ demonstrate that signiricant numbers or people will attempt to evacuate even if told not to do so. This

" evacuation shadow phenomena" will not only have an aaverse ertect on LILCO's attempt to evacuate the 10 mile EPZ, but it will also create an unmanageable crisis east ot-the EPZ in that:

A) During peak tourist season (May - Sept.) and poor weather periods, the existing roadwork cannot nandle anticipated traffic; B) Fear, panic, accidents and possible violence cannot be controlled by limited police, fire, emergency personnel and emergency vehicles; C) Topulation is highly transient, dislocated, and many are without transportation; D) The plan provides inadequate EP communications to Southampton.

Thus, LILCO's plan is inadequate because it contains no adequate EP measures to deal witn evacuation phenomena outsice ot the EPZ.

Town of Southampton Contention 4 Actual surveys of population response to evacuation, trattic surveys, and modeling rereal that significant congestion will occur outside the 10 mile EPZ. This pnanomenon will result in exposure or large numbers or people to dose levels greater than thJ PAG's outside tne zone. LILCO has tailed to take into account and plan tor this pnenomena as required by 10 C.F.R., S50.47.

Town of Soutnampton Contention S 10 C.F.R., SSO.47(b)(1) requires the applicant to show that it "has statt to respond to ano to augment its initial response on a continuous basis". LILCO assumes that local police will provide security during the course of an evacuation, and that all local enforcment agencies and tire departments within the 10 mile EPZ will continue to carry out their normal response tunctions. (p.

2.2-4). However, there is clearly no assurance of assistance trom buttolk County police, nor is there any assurance or assistance trom other local police forces. As a result, there may be serious looting in the evacuated neignDorhoods and inettective traftic and perimeter control both within and Deyond the 10 mile EPZ.

Moreover, as to all such services, A) Some local ofricials will decline to implement any plan which is not tne plan of the local government (i.e.,

Suffolk County); and

8) as revealed by an actual survey by S.uffolk County, many individuals wil not respond as planned in a radiological emergency.

Theretore, the plan does not satisty the requirements at 10 C.F.k. 50.47.

- Town of Southampton Contention 6 10 C.F.R., S50.47(D)(1), (9), (10) requires that protective actions for the approximate 50 mile ingestion exposure pathway be developed. LILCO's describes measures at OPIP 3.6.6, Attacnments 7 and 8, which it purports to be adequate for this particular EPZ.

The Town of Southampton submits that these actions are infeasible and/or inadequate in that a) they assume without basis that facilities and equipment exist or will be available to process, store and control toods according to the measures; and D) the plan is based on tne further assumptions tnat, upon direction:

(i) wells can be identified and isolated, (ii) truits and vegetables will be washed, brusned, l

scrubbed or peeled, (iii) livestock can be isolated, (iv) all local farmstands can be found and con-trolled, (v) the diet of all residents and visitors can be restricteo, (vi) the exports trom Sutfolk County to other parts of the country can be controlled or stopped.

a o-However, the plan does not provide for personnel, facilities, equipment or even a communications network to implement these tar reacning actions. Thus, LILCO has not developed adequate plans tor the 50 mile ingestion exposure pathway.

Town of Southampton Contention 7 LILCO's plan calls for the relocation of patients at Central Long Island Hospital to Eastern Long Islanc dospital (Greenport) and Southampton Hospital. Southampton contends that this relocation plan will not work in tnat:

a) these hospitals do not have either the individual or combined capacity to handle Central Long Island's patients; and b) traffic flow / congestion east to west will prevent this relocation; and c) tnere are inadequate numbers of emergency personnel to handle relocation, and inadequate statt at Eastern Long Island and Soutnampton Hospitals to handle patients.

[iQf i

UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

' , , h;I s7. U ,

)

In the Matter of ) [*1h<\@ '

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of " Consolidated Draft Emer-gency Planning Contentions" and " Draft Contentions of the Town of Southampton Regarding Emergency Planning" were served to the following this 23 day of June, 1983 by first class mail, except where otherwise noted:

James A. Laurenson, Chairman

• Ralph Shapiro, Esq.**

Atomic Safety and Licensing Board Cammer & Shapiro U.S. Nuclear' Regulatory Commission 9 East 40th Street Washington, D.C. 20555 New York, New York 10016 Dr. Jerry R. Kline* Howard L. Blau, Esq.

Atomic Safety and Licensing Board 217 Newbridge Road U.S. Nuclear Regulatory Commission Hicksville, New York 11801 Washington, D.C. 20555 W. Taylor Reveley, III, Esq.***

Dr. M. Stanley Livingston** Hunton & Williams 1005 Calle Largo P.O. Box 1535 Santa Fe, New Mexico 87501 707 East Main Street Richmond, Virginia 23212 Edward M. Barrett, Esq.

General Counsel Mr. Jay Dunkleberger Long Island Lighting Company New York State Energy Office i

250 Old Country Road Agency Building 2 Mineola, New York 11501 Empire State Plaza Albany, New York 12223 Mr. Brian McCaffrey Long Island Lighting Company Stephen B. Latham, Esq.**

, 175 East Old Country Road Twomey, Latham & Shea i Hicksville, New York 11801 33 West Second Street Riverhead, New York 11901

. . Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.

195 East Main Street Washington, D.C. 20555 Smithtown, New York 11787 Hon. Peter Cobalan Marc W. Goldsmith Suffolk County Executive Energy Research Group, Inc. H. Lee Dennison Building 400-1 Totten Pond Road Veterans Memorial Highway Waltham, Massachusetts 02154 Hauppauge, New York 11788 MHB Technical Associates Eleanor L. Frucci, Esq.

• 1723 Hamilton Avenue Atomic Safety and Licensing Suite K Board Panel San Jose, California 95125 U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555 Joel Blau, Esq. .

New York Public Service Comm. Ezra I. Bialik, Esq.

The Governor Nelson A. Rockefeller Assistant Attorney General Building Environmental Protection Bur.

Empire State Plaza New York State Dept. of Law

Albany, New York 12223 2 World Trade Center New York, New York 10047 David J. Gilmartin, Esq.

Suffolk County Attorney Atomic Safety and Licensing H. Lee Dennison Building Appeal Board Veterans Memorial Highway U.S. Nuclear Regulatory Comm.

Hauppauge, New York 11788 Washington, D.C. 20555 Atomic Safety and Licensing Matthew J. Kelly, Esq.

Board Panel Staff Counsel, New York State U.S. Nuclear Regulatory Commission Public Service Commission Washington, D.C. 20555 3 Rockefeller Plaza Albany, New York 12223 Bernard M. Bordenick, Esq.

• David A. Repka, Esq. Stuart Glass, Esq.

U.S. Nuclear Regulatory Commission Regional Counsel Washington, D.C. 20555 Federal Emergency Management Agency Stuart Diamond 26 Federal Plaza, Room 1349 Environment / Energy Writer New York, New York 10278 NEWSDAY Long Island, New York 11747 James Dougherty, Esq.*

3045 Porter Street, N.W.

Spence Perry, Esq. Washington, D.C. 20005 Associate General Counsel '

Federal Emergency Management Agency ', e. , c-Washington, D.C. 20472 3 , - i r [-

Mr. Jeff Smith Christo'pher M. Mctlurray i

^ ^

Shorehmm Nuclear Power Station '

OPHER & PHILLIPS

/

P.O. Box 618 1900 M Street, N.W., 8th Floor North Country Road Washington, D.C. 20036 Wading River, New York 11792

• By Hand DATED: June 23, 1983

• • By Federal Express

/ *.*- _- By Computer ___

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