ML20083Q924
| ML20083Q924 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/17/1984 |
| From: | Baldwin T, Keller H, Keller J, Kowieski R, Mcintire P Federal Emergency Management Agency |
| To: | |
| Shared Package | |
| ML20083Q913 | List: |
| References | |
| OL-3, NUDOCS 8404230384 | |
| Download: ML20083Q924 (140) | |
Text
FEMA, April 17, 1984 CNITED STATES OF AMERICA NOCIEAR REGUIATORY COMISSIGi Before the Atomaic Safety and Licensing Board i
In the Matter of
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1
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IDIG ISIAND LIGfTING GMPANY )
nrv*at No.50-322-OL-3
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(Beargency Planning (shorehma Nuclear Power
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Ps@)
Station, Unit 1)
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DIRECT TESTDDIY OF TEDIAS E.BAIDNIN, JOSEPH H. mJtR, IOGER B. EDHIESKI ND PHILIP H. McINTIRE ENCERNING PHASE II EMERGENCY PLAMING The Federal Emergency Managenent Agency and the Nuclear Regulatory Cmnission entered into a Menorandum of Understanding (MOU) on January 14, 1980, which defines inter-agency responsibilities with respect to emergency preparedness. Included in that MOU is an agreement whereby FEMA would make firr3ings as to whether offsite emergency response plans are adequate. Such findings are referred to as " interim" because they are provided outside the formal procedures set forth in FEMA's own regula-tions as contained in 44 C.F.R. 350, and they reflect the status of plannina at the time of evaluation. Requests for interim findings are usually made by the NRC to FEMA to assist the NRC staff in their pre-sentations during the licensing process.
l By the terms of the MOU, FEMA is also responsible for providing " expert witnesses" to testify before the Atanic Safety Licensing Board.
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1 On Septenber 15, 1983, NRC requested FEMA pursuant to the tents of the M00 'IO REVIEW Revision I of the LILCD Transition Plan whidi had been sub-mitted by the licensee applicant, the Iong Island Lighting Company, to the NRC. On September 23, 1983 FEMA's Executive Deputy Director requested the Director of FEMA's Region II to initiate a full RAC review of LIIID's Transition Plan Revision 1. Revision 2 and Revision 3 were sub-sequently subnitted to PEMA On December 30, 1983 pursuant to the terms of the MJU for review by the RAC. We RAC review of Revision 3 was discussed and consolidated at a meeting of the RAC which was held in the FEMA Region II office on January 20,19fs4. Wese review connents were finalized and forwarded to FEMA Headquarters on February 21, 1984. We RAC review of Revision 3 was transmitted to the NRC on March 15, 1984. A copy of the RAC review is appended to this testimony ard consitutes a part thereof.
The standards used in reviewing these plans are included in the joint NRC/ FEMA guidance docurnent entitled, " Criteria for Preparation arrl Evaluation of Radiological Energency Response Plans and Preparedness in Support of Nuclear Power Plants", NURIE 0654/ FEMA REP-1,Rev.l.
The purpose of this testimony is to address the contentions relating to offsite preparedness at the Shorehan Nuclear Power Station, as admitted by Board Order of February 3,1984. o
Q.1.
Please state your name and business address?
A.
Thanas E.
Baldwin - Argonne National Laboratories, 55 Hilton Avenue, Garden City, New York 11530 A.
Joseph H. Keller Westinghouse Idaho Nuclear Canpany, Inc.,
P.O. Box 4000, Idaho Falls, IO 83401 A.
Roger B. Kowieski - Federal anergency Management Agency, 26 Federal Plaza, New York, New York 10278 A.
Philip H. McIntire
. Federal Emertjency Managenent Agency, 26 Federal Plaza, New York, New York 10278 0.2.
Do ycn have statements of professional cualificiations?
A.
Yes. Our statements of professional cualifications are attached to this testinony.
03 When did Thomas Baldwin first became involved in amertjency planning?
Mr. Baldwin became involved in radiological emergency planning in A.
February,1982 under a contract for support to the Federal Bnergency Management Agency entered into by my eiployer...
- 04. When did 'Ihmas Baldwin first become involved in a review of emergency planning as it relates to the Shorehm Nuclear Power Station?
A.
Mr. Baldwin becaned involved with the review of the Shorehan Nuclear Power Station radiological emergency response plan when he received a letter frun Mr. Frank P.
Petrone, Director FEMA Region II, dated October 4, 1983.
C.5.
Please describe the nature of that involvement up to the present time.
A.
Mr. Baldwin was originally requested to review Revision 1 of the plan.
Subsequently he received Revision 2 and 3 which were also reviewed. On January 10, 1984 he attended a meeting in Hicksville, New York during which LILCD staff explained changes made to the plan in Revision 3.
He participated in the RAC meeting of January 20, 1984 to discuss and consolidate the PAC review of Revision 3.
0 6.
men did Joseph Keller first became involved in emergency planning?
A.
Mr. Keller became involved in radiological energency planning in August 1979, when a contract for support to the Federal Intervej Task Porce on Offsite Dnergency Instrmentation for Nuclear Incidents was entered into by his employer. He was assigned the responsibility of principal investi-gator on the contract. L
s 0 7.
When did Joseph Keller first became involved in a review of emergency planning as it relates to the Shoreham Nuclear Power Station?
A.
Mr. Keller becme involved with the review of the Shoreham Nuclear Power Station radiological emergency response plan when he received a letter frcm Frank P. Petrone, Director FENA Region II, dated October 4,1983.
0.8.
Please describe the nature of that involvement up to the present time.
A.
Mr. Keller was originally requested to review Revision 1 of the plan.
Subsequently he received Revision 2 and 3 which were also reviewed. He participated in the RAC meeting of January 20, 1984 to discuss and consolidate the RAC review sf Revision 3.
0.9.
When did Roger Kowieski first beco m involved in emergency planning?
A.
Mr. Kowieski first became involved in emergency planning in 1978 as l
Regional Dam Safety Coordinator.
In 1981, Mr. Kowieski was appointed by the Regional Director as the Chairman, Regional Assistance Otunnittee, responsible for the REP Program. Since that time he managed the REP program and Dam Safety activities in PEMA, Region II.
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0.10. When did Roger Kowieski first become involved in e:mergency planning as it relates to the Shoreham Nuclear Power Station?
A.
Mr. Kowieski first became involved in a discussion of the energency planning issue in 1982, at a meeting with representatives of Suffolk County, NRC, New York State and PEMA in Hicksville, New York.
Q.11. Please describe the nature of that involvement up to the present time.
A.
Sinca submission of the LIUD Transition Plan on October 4,1983, Mr.
Kowieski coordinated the review of this plan by Reginal Assistance CoTmittee, incitriing Revisions 1, 2 and 3.
He chaired the RAC meetirg of January 20, 1984 when the RAC review of Revision 3 was discussed and a concensus reached. He then finalized the s'imission of the RAC review to the National Office.
Q.12.
When did Philip McIntire first become involved in emergency plannin3?
A.
In 1966 he joined the Office of Bnergency Planning on Washington, D.C.
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'Ihis was a predecessor agency of the Federal Bnergency Management Agency.
In 1975 he first became involved in emergency radiological planning when the Federal Disaster Assistance A&ninistration became a menber of the" Cannittee that preceded the Regional Advisory Ccrmittee.
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Q.13. When did Philip McIntire first became involved in emergency planning as it relates to the Shoreh m Nuclear Power Station?
A.
Mr. McIntire first became involved in a discussion of the emergency planning issue for Shoreham in 1982, at a meeting with representatives of Suffolk County, NRC, New York State and FEMA in Hicksville, New York.
Q.14.
Please describe the nature of that involvement up to the present time.
a.
Since sutrtission of the LIILO Transition Plan on October, 4,1933, Mr.
McIntire monitored the review of this plan by Regional Assistance Ccrutittee. including Revisions 1, 2 and 3.
He monitored in the RAC meeting of January 20, 1994 when the RAC review of Revision 3 was dis-cussed ard consolidated. He coordinated the submission of the RAC revied to the FEMA National Office.
Q.15.
In the course of your review of offsite emergency planning at the Shorehm Nuclear Power Station, what documents submitted by the NRC through the NRC-FEMA MOU have you and your staffs reviewed.
A.
We have review the LII/D Transition Plan, Revision 3, whidi consists of i
the following four volumes:
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Incal Offsite Radiological Dnergency Response Plan; Voltanes I and II of the implementing procedures for the plan; and Appendix A, Evacuation Plan 0 16. ihat other doctznents have you relied on in your review of the Revision 3 of the LILCD Transition Plan for the Shorehan Nuclear Power Station?
A.
We have used NURS3-0654, FEMA-REP-1, Rev.1, Criteria for Preparation and Evacuation of Radiolacical Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, published November,1930 in preparing our review of the LILCO Transition Plan.
Q.17.
Is the panel authorized to present to the Board the current PEMA evaluation of the LIIID Transition Plan, Revision 3, for the Shorehan Nuclear Power Station as it relates to offsite emergency preparedness?
Does your testirony represent the current FEMA evaluation?
A.
Yes.
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CGf11!NTIGi 20 Q.18.
20-Does the plan contain provisions for 24 hour-a-day Buergency Broadcast System capbility for people without FM radios?
A.
According to Burrelli's New York State Media Directory, WALK broadcasts A.M. from 5:00 m to 2:00 m, and broadcasts FM 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s-a-day. The plan does not specifically address how the energency notification will be given to the population without EM radios when the M station is off the air. However, it is our understanding that WAIK M can restune broadcasting in any emergency.
It should be noted that the RAC review indicated concern about the use of the term "EBS" (see Attachnent 2 of RAC review, Section E-5).
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CCM1!NTIN 21 l
0 19. 21-Does the Public Education portion of the plan conform to current criteria and guid ece for disseminating information in languages other than English?
A Joint PEMA/NRC Issuance; Guidance Memorandtn $20, deals with foreign A.
language translation of public education brochures and safety messages.
If 5% of the citizens of voting age in a political subdivision (counties and independent cities) are members of a sirgle language minority, then translation of public education information in the pltane exposure pathway EPZ is warranted.
A determination as to the effectiveness of the public education progran for the total ppulation, including mirnrity language groups, could not be made during the plan review stage. 'Ihe effectiveness of the public education program would be evaluated at an exercise of emergency response preparedness at SNPS.
(XNNNFIN 22 0 20 22.D-Does the EPZ identified in the LIUJO Transition Plan divide any major population centers or political boundaries?
We plune exposure pathway EPZ divides the following villages:
A.
Port Jefferson - Zone Q Terryville
- Zone K Riverhead
- Zone P However, the boundary of the plune exposure EPZ follows recognizable landmarks (e.g., roads, highways, railroads, etc.) which follow as nearly as possible the 10-mile radius of the EPZ and, therefore, conform to IfJREG-0654 criteria. Wese landmarks are delineated on maps included in Appendix A of the plan. Wese larxharks should be narratively described in the text of public education materials (e.g. brochures, wall calendars with maps, telephone took inserts, etc.) to ensure that populations potentially affected by protective action recommendations understand whether they are inside the plume exposure EPZ. __
CG mpirIOi 24 Q.21.
24-Does NUREG-0654 FEMA-REP 1. Rev.1,Section II A 3, require letters of agreement from all emergency response organizations to be contained in the Radiological Emergency Response Plan?
A.
NURBG-0654,Section II A 3, requires each plan to contain written agreements referring to the concept c.f operations between Federal, State and local agencies and other support organizations having an emergency response role within the Emergency Plannirg Zones. A signature page format is wwiate in lieu of separate letters of agreement for organizations where response functions are covered by laws, regulations or executive orders.
Letters of agreement are required from support organizations assigned emergency response roles. In those cases where privately owned resources are an essential part of the response capability, agreements with the owners are required to assure that the appropriate resources will be made available in an emergency.
During the cx)urse of an exercise the ability to field the necessary resources, including equipment and personnel as outlined in the letters of agreement, would be tested.
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Q.22.
This question intentionally left blank pending Board's ruling on Stranary Disposition raotions on Contentions 24B, 33, 45, 46 and 49.
24.E-What is the status of agreements between LIIDO and s&ool personnel, Q.23.
incitriing nursery school personnel, charged with protecting dildren in school in the event of a radiclogical energency at SNPS?
No letters of agreenent with s&ools could be located in the plan.
A.
Howeler, the plan takes the followiry planning factors into consideration (see Appendix A pages II-19 and 20):
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1 officials of public and private schools located in the Plume Exposure Bnergency Planning Zone (EPZ), as well as schools located outside the EPZ but with students who live in the EPZ, have the responsibility in a radiological emergency of providing their students with the best possible protection. W ere are three general alternatives available to provide for the safety of the dildren during an emergency. We first alternative is an early disraissal, whereby all students would be returned to their hones. We second alternative is evacuation, whereby all students would be relocated to reception centers outside the 10-mile Bnergency Planning Zone (EPZ). We third alternative is sheltering students at their schools until conditions are safe for the dildren to either return hane or be relocated. W e best alternative will depend on the nature of the emergency, plant conditions, weather conditions, and time of day.
In the event of an emergency, schools will be notified of any Alert or higher emergency classification by the Emergency Broadcast System and by telephone. Each public s&ool district, parochial school, and nursery school in the EPZ will have a tone alert receiver which will autcmatically activate and transmit the EBS message. W e EBS message will advise the schools to implement specific protective actions and may contain general information about the condition of the plant, radiological corditions, etc. In addition, each school district superintendent and individual in charje of the private schcols in the EPZ will be contacted by telephone by either the Public Schools Coordinator or Private Schools Coordinator to verify that the EBS message was received and to receive requests for additional assistance.
If nursery schools are Mvised to evacuate the children to reception centers, LERO will provide the necessary tran.m -tation.
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l Q.24.
24.F-Does the LIIG Transition Plan contain letters of a:Treenent with bus companies or other vehicle providers called for in the plan to evacut.te all transit-dependent individuals, including school children? What are the implications of the current status of these letters of agreenent?
A.
Ietters of intent from bus and abulance suppliers are included in Appendix B for the following resources:
Bus companies - approximately 1560 vehicles including buses, vans, coaches, flexetts, etc.
Ambulance companies - approximately 225 vehicles including ambulances, ambuletts, etc.
f However, these letters of intent do not cmmit the bus and anbulance companies to supply equipment to LERO in the e,*ent of a radiological emergency at the Shoreham site, because contracts have tot as yet been finalized with the bus or ambulance suppliers.
The letters of intent included in Appendix B indicate that LIT 40 is attempting to arrive at mutually acceptable contracts to assure that these resources will be made available in the event of a radiological energency at the Shorehan Nuclear Power Station.
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0.25.
24.G-Do the letters of intent that presently exist provide for enough ambulances to meet the needs of Hospitals, Special Facilities, Harrlicapped, etc., as outlined in the LIIDO Transition Plan?
A.
The RAC review of the LI E Transition Plan has concentrated on assessing 4 ether various elements of the plan omeply with the Planning Standards and Evaluation Criteria set forth in NURBG-0654. An assessment of whether the number of ambulances identified in the plan (see Procedure OPIP 3.6.5, Health Care Facilities Listing) are actually available would be determined durity an exercise.
Q.26.
24.I-Does the LILCD Transition Plan contain letters of agreement providirn access arri pennission to utilize those " Transfer Points" rut presently owned by LILCO?
A.
While there are ro letters of agreement for the use of these facilities, the RAC, in its review of the LI@ Transition Plan, did not identify the lack of written agreements with the owners of non-LI @ facilities as an area of concern that wuld be.t.ufficient to find the plan in=5 equate in this regard (see NU$t[N-0654 evaluation criteria C.4).
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24.J-Does the LIIID Transition Plan contain letters of agreement with the 0 27.
special facilities (Association for the Help of Retarded Children Facilities, United Cerebral Palsy Facilities, John T. Mather Memorial Hospital, St. Charles Hospital, Central Suffolk Hospital, Maryhaven Center of Hope and BOCES Learning Center) to implesment evacuation i
procedures set forth in the Plan?
i 1
The Association for the Help of Retarded Otildren Facilities, United A.
l Cerebral Palsy Facilities, John T. Mather Memorial Hospital, St. Charles i
i Hospital, Maryhaven Center of Hope arvi BOCES Imarning Center are not identified in the plan as support organizations having an energency i
response role within the Dmergency Planning Zones. Therefore, letters of agreement from any of these faellities which do not have identified emergency response roles are not necessary.
I It chould be roted that only Central Suffolk Hospital has been identified as a support facility. A letter of agreement could not be located in the plan for this support response organization.
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l 0.28.
24.K-Does the LIIm Transition Plan contain Intttrs of agreement with drivers, ambulance corps, or other medical personnel to be used in evacuating special facilities and the hardicapped, or transporting injured persons?
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A.
We letters of intent from ambulance suppliers included in Appendix B of the plan specifies that manned vehicles will be provided in an emergency.
Q.29.
24.L-Does the LILCO Transition Plan contain letters of agreement which will provide services to dispatd> anbulances for use during a radio-logical emergency?
A.
See answar to Contention 24.F.
Q.10.
24.M-Does the LILOO Transition Plan contain letters of agreement with bus companies, unions, or other groups to provide drivers for implementation of early school dismissal or evacuation / relocation of school children?
We LERO Transportation Support Coordinator is responsible for driver support. We LIIID Transportation Plan states that the utility will provide trained, licensed LIIID enployees as a major source of bus drivers (Appendix A, III-36). We RAC has reconsnanded that the plan should specify the ntsnber of drivers that have been trained and licensei to respord to a radiological anergency at SNPS.
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s 0.31, 24.N-Does the LII/D Transition Plan contain letters c2 agreement with the
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facilities to be used as relocation centers for school children, hospital patients, handicapped individuals or residents of special facilities?
A.
An identification of which relocation centers would be utilized by each school could not be located in the plan. Suffolk Cbunty Canmunity College, BOCES in Islip, and SUNY in Stony Brook are the primary relocation centers. to back-up centers (SUNY - Farmingdale, St.
. Joseph's College - Patchogue) have been identified.
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'Ihe inventory of recuirements for protecting persons evacuated from special tacilities is shown in Procedure OPIP 3.6.5, Attachment 2.
If these persons are to be sent to relocation facilities different from the general public relocation centers, the listing of the special relocation facilities must be finalized and supported by letters of agreement.
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i Q.32.
24.0-What would be the impact on the LIE Transition Plan if Suffolk l
County Community College would not be available as a relocation center?
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A.
Another relocation center or centers with facilities to accommodate the potentially evacuated population that,would be estimated to arrive at the Suffolk County Coununity college relocation center would need to be arranged for aM these arrangements would need to be supported by letters of agreement. Any replacement relocation center that is contemplated should be at least 5 miles, and preferably 10 miles, beyond the boundaries of the pitne exposure pathway EPZ.
Q.33.
24.P-Does the LILOO Transition Plan cc,ntain letters of agreement with the American Red Cross to provide services at relocation centers?
A.
Appeniix B of the LIUD Transition Plan contains a letter from the utility confirming LILCD's discussions with the Red Cross that the agency will fulfill its usual emergency response functions, including setting up and operating relocation centers for the public.
However, a signed letter confirming these arrangements is not presently included in Appendix B of the plan.
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Q.34.
24.R-Nhat agreements exist with the State of Connecticut with regard to the recomendation and implementation of protective actions for those portions of the ingestion exposure pathway EPZ located in Connecticut?
A.
No formal agreements for the implementation of ingestion pathway protective actions in Connecticut could be located in the plan.
Section 3.6 (page 3.6-8) of the plan states that control of the ingestion exposure pathway EPZ will be directed by the LERO Health Services Coordinator. Section 3.4 E (page 3.4-4) provides for comunications from LERO to the State of Connecticut via comercial telephone and centrex.
Procedure OPIP 3.6.6 contains ingestion pathway procedures, PAFA, and agricoltural resource information, incltding food processing plants an3 dairy farms in Connecticut.
O.35.
24.S-Do letter of agreement exist in the LItro Transition Plan to provide for the initial training, annual retraining and participation in drills and exercises for emergency workers, incitding those who are responsible for accident assessment, police, security and fire fighting personnel, first aid and rescue personnel, and medical personnel?
A.
With respect to non-LIIr0 personnel including police, security, and fire fighting personnel, the participation of these personnel cannot be assured since LILCD/LERO does not have mutual aid agreements with these organizations that are supported by a letter (s) of agreement. -
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%e RAC has reomimended in its review of the LILOO Transition Plan that it should be clarified in the plan whether DCE-RAP personnel will participate in the radiological monitorirg exercises. B is clarification was requested since the letter of agreement between DOE and LII4D limits DOE radiological assistance to " advice and energency action essential for the control of innediate hazards to health and safety" (i.e., in an actual emergency) - see Appendix B, page APP-B-1.
Q.36.
24.T-Does the LILCD Transition Plan contain a letter of agreement with the U.S. Coast Guard to provide for the alert and notification of individuals on the beaches and marinas within the EPZ?
A.
We LIILO Transition Plan provides for notification of the U.S. Coast Guard (USO3), which provides public notification services for the general public on the waters within the Emergency Planning Zone. Additionally, the U.S.
Coast Guard provides private and comnercial vessel traffic control, and restricts access to affected areas in concert with LERO efforts. W e letter of agreement in Appendix B (see page APP-B-8) assures that the U.S. Coast Guard will provide these emergency support services to LIIco if they are needed in an emergency at SNPS. However, this letter is not specific with regard to the notification of individuals on beaches and in marinas. __
03 m!NTION 26 Q.37.
26.A.1-Are there adequate provisions for staffing at the LIIID Customer Service Office in Hicksville and sufficient back-up personnel from Hewlett and Brentwood to ensure that the necmaag emertjency worker
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notification functions can be perforned?
A.
An operator is on duty in the LIIID Customer Service Office in the Hicksville Operations Center 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s-a-day.
LILOO Custmer Service is the designated primary notification point of the LERO. As such, LILCO Custmer Service is responsible for receiving initial and early follow-up notifications of an emergency from SNPS and verifyirs information contained in the notification messages. When the comunication center in the Incal EOC is activated. LILOO's responsibility for receiving the notifications will shift frm Custmer Service to the Incal EOC Comunications Center. ' Ibis is expected to occur during the early stages of an Alert emergency classification. Once the Incal EDC is activated by the Director of Incal Response, primry responsibility for receiving all further notifications will rest with the Lead Comunicator in the EOC. No discussion of the availability of I
back-up personnel at either the Hedlett er Brentwood facilities could be located in the plan.
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Q.38.
26.A.2-Does the LILCD Transition Plan contain adequate provisions for receiving initial notification of an emergency and verifying the information received?
A.
We Radiological Bnergency Coununications System (RECS) is the primary notification system to be used by LILCD in notifying 1m0 should an emergency occur at SNPS. If notification were received via the RECS line, no verification call-back would be needed. Commercial telephone is identified as the backup notification system to RECS. If notification were received in this manner, call back verification would be required.
Wese procedures are detailed in Procedure OPIP 3.3.1, and are considered adequate to ensure that LERO will be able to receive arrl verify notification in the event of an emergency.
0 39.
26.C-Is the paging equipment identified in the LIL(D Transition Plan adeqate to assure that key emergency response personnel will be promptly alerted ani notified?
A.
Although there are no specific NUREG-0654 requirements for paging j
systens, the LILCD Transition Plan provides for the use of these devices.
%e operating procedures by which energency workers will call in to verify that they have been notified are described in the plan (see page 3.4-5).
However, specifics reaarding the range over which the pagers will operate, performance standards for these units, and details by which i
emergency workers will confirm that they have received the appropriate message could not be located in the plan.. - - - _
0 40.
26.D-Does the cascading notification scheme which depends upon comnercial telephone provide reasonable assurance that a sufficient ntsnber of personnel will be promptly notified and mobilized in the event of an emergency at SNPS?
A.
We provisions for alerting and activatirg essergency response personnel in each response organization as described in Section 3.3, pages 3.3-1-4; Pigures 3.3.2, 3.3.3, and 3.3.4; and Procedure OPIP 3.3.2 are adequate.
Although the plan specifies in the text that the " procedures for notification and activation of emergency response personnel are the sane as those for a site area emergency," a list of persons / groups /
organizations to be notified for mobilization at general energency is not presently included in the plan. We plan is a$ equate in satisfying the requirements of NUREG-0654 planning element F.1.e, provided that the notification list for personsforoups/ organizations to be mobilized at general swrgency is added to the plan.
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26.E-Does the LILCD Transition Plan provide for the timely notific tion of non-LILCD emergency support organizations and personnel (i.e.:
hospitals, relocation centers, bus companies, ambulance ocznpanies)?
A.
Provision for the timely notification of non-LILCD emergency support organizations and personnel representing other organizations including hospitals, relocation centers, bus conpanies, and anbulance conpanies are adequate as described in Section 3.3, pages 3.3-1-4; Figures 3.3.2, 3.3.3 and 3.3.4; and Procedure OPIP 3.3.2 of the LILCD Transition Plan.
However, as noted in the answer to contention 26.D, a list of persons / groups / organizations to be notified for mobilization at general emergency is not presently included in the plan.
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Q.42 26.E-Is there an adequate back-up rotification system to non-LIIm energency support organizations and personnel representing Brookhaven National Laboratory, the U.S. Coast Guard, and the Federal Aviation Adninistration?
A.
We primary means of notifying non-LILOO emergency workers from Brookhaven National Laboratory, the U.S. Coast Guard, and the Federal Aviation Administration is by comnerical telephone from the LILOO Emergency Operations Center in Brentwood, Iong Island, New York.
We back-up means of rotifying these organizations is as follows (see Figure 3.4.1, Stenary of Carnunication Systems):
Brookhaven National Laboratory (i.e., Brookhaven Area Office) dedicated telephone line from the LERO Emergency Opertations Center in Brentwood, New York U.S. Coast Guard - Federal Telephone Systen from the LIILO Control Room at SNPS l
Pederal Aviation Administration - Pederal Telephone Systen from the LIIG Control Roan at SNPS l
l W ese back-up means for notifying the above Federal agencies are considered adequate.
Q.43, 26.E-Does the LIIID Transition Plan limit the notification of non-LII/D emergency support organizations to the declaration of a site area or general emergency?
A.
Section 3.3, pages 3.3-1-4; Figures 3.3.2, 3.3.3, and 3.3.4; and Procedure OPIP 3.3.2 of the LILCD Transition Plan establish the provisions for alerting and activating energency response personnel in each response organization, including non-LII4D emergency support organizations at each emergency classification level. '1here are sme non-LII4D emergency workers who are notified only at the site area or general emergency classification level.
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I (DNNNTICN 27 0.44.
27.A and B-Does the LILOO Transition Plan specify estimated mobilization times required for emergency workers to arrive at their assigned duty stations after they have been notified to report?
A.
Estimated nobilization times required for emergency workers to arrive at their assiged duty stations after they have been notified to report under either normal or adverse conditions could not be located in the plan.
Hoever, with the exception of element I.8, which requires that mobilization times are available for radiological field monitoring teams, there are no specific MJREG-0654 requirenents that estimated nobilization times should be included for other emergency workers. The nobilization time for the DOE-RAD team is esti:nated to be approximately one (1) hour (see Attachment 2.2.1, page 1 of 17).
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0.45.
27.C,D and E-Does the LILCD Transition Plan specify estimated deployment times required for field workers to arrive at their field assignments (including receipt cf dosimetry, briefing information, emergency vehicles, and communications equipment) after they have arrived at their assigned staging area or dispatch location?
A.
He LIIID Transition Plan does not specify estimated deployment times required for field workers to arrive at their field assignments after they have arrived at their staging areas or dispatch locations. %e inclusion of these deployment times is not specifically required by NUREG-0654, but the effective response of emergency workers to field assigrunents is evaluated during an exercise.
0 46.
27.P-Can a determination be made at this time whether there are adequate provisions in the LILCD Transition Plan for the timely arrival of workers (e.g., traffic guides, bus orivers - those required to report at Site Area or General Dnergency Classification levels) at their field locations?
l A.
We plan contains no information upm which to base a determination as to whether the arrival of emergency workers required to report to field assignments would be timely. However, it should be noted that Procedure OPIP 3.3.3 provides for the early notification and standby of many emergency workers prior to then being dispatched to their assigned field locations.
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CGf1?NFICM 28 0.47.
28-Does the LIILO Transition Plan provide for adequate and reliable comunications with Federal emergency response organizations (FEMA, U.S.
O mst Guard, FAA)?
A.
The LIIH) Transition Plan provides for two separate connunication systems as shown in Figure 3.4.1 by which LERO can contact FIMA, the U.S. Coast Guard, ard the FAA.
a) Comerical telephone line frm the EOC, or, b) Federal Telephone System frm the plant control room.
The existence of two separate means of communication with these Federal agencies is considered adequate. -
Contantion 29 f
Q.48.
29-Wat provisions are contained in the LIIID Transition Plan for the staffing and maintenance of comunications equipment at the BOC, staging areas, transfer points, anbulance dispatch stations or other comunication posts in an emergency?
We plan specifies omenunicators for both radio and telephone. Eight A.
separate comunicators are listed (Figure 4.1.2 (2 of 2)) in the BOC.
We anbulance dispatch stations will use their nomal communication network. Each Transfer Point Coordinator will be supplied with a radio (Procedure OPIP 3.6.4, page 4 of 4) as will traffic guides, road crews, ard evacuation route spotters (Procedure OPIP 3.6.3, Attach I-2-3).
Comunications repair capabilities during an emergency could not be located in the plan.
00pm NTION 30 0 49. 30-Are provisions contained in the LIILO Transition Plan sufficient to ensure 'ffective comunication arong LIILO field emergency personnel (including security functions)? Does the plan indicate whether the radio frequencies assigned to this comunications system are available to the public? Does the plan indicate how the mobile radios are powered, dura-tion of operating time, ability to recharge and remain operative over a long period of time? Does the plan indicate the range of these radios and whether they are all on the sane frequency? Are these radios, attached to vehicles or are they hand-held?
A.
We LILCD Transition Plan establishes the LILCO Energency Radio Systen which provides four dedicated radio frequencies for comunications between the Staain; Area Ooordinators or the local EOC emergency response coordinators (in Brentwood, Iong Island, New York) and field energency response personnel. %ese radio frequencies are dedicated for the followiny groups (see page 3.4-3 of the plan):
Patclxxjue Staging Area to Patchogue dispatched Traffic Guides and Bus Transfer Points Riverhead Staging Area to Riverhead-dispatch *!d Traffic Guides and Bus Transfer Points -
Port Jefferson Staging Area to Port Jefferson dispatched Traffic Guide and Bus Transfer Points EDC to Road Crews, Evacuation Ibute Spotters, arki Ambulance Dispatch Stations We I50 frequencies are not published for public use. However, an individual with a scanner could easily " lock-on" and receive any transmission. Pron a review of the various procedures, it appears that the radios are hand-held, portable, and battery operated. We plan review did not identify operatiry time, range, or recharge requirements for the radios. Wese items are normally evaluated during an exercise.
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CCNIENTIGi 31 0 50 31-Does the LILOO Transition Plan adequately provide for back-up comunications equipnent between energency response coordinators at the BOC and field emergency response personnel?
A.
Were are no specific NURKi-0654 requirements for backup connunications capabilities between emergency coordinators at the BOC and field emergency response personnel. However, the LIIOD Transition Plan identifies four (4) radio frequencies (see page 3.4-3), each dedicated for specific groups of emergency field workers. W ese separate frequencies are accessed through the staging areas and the EOC. We have not been able to evaluate the multi-channel capabilities of LERO's radio equignent because the specifications of these units are nat included in the plan. Werefore, the back-up comunications capabilities between eTergency respanse coordinators at the EDC and emergency workers in the field cannot be evaluated at this time.
00tmlNTIG4 32 0 51. 32-Would the relay of messages from response coordinators at the DOC to field personnel through the stagirg areas delay the iglementation of emergency actions?
A.
Ib the extent that comunications between field personnel and their coordinators are shown to be effective in ommunications drills and/or exercises, the relay of messages, or lack of direct comunication, should not delay the implementation of emercency actions.,
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CDm!NTICH 34 0 53 34.A,B and C-Does the plan indicate whether the emergency radio system described in the LIICO Transition Plan is campatible with the radio comunications equipment that is presently utilized by the hospitals and ambulances that would be called upon to 2wd under provisions of the plan? Does the LII4D Transition Plan indicate whether the LIICO emergency comunication systen has direct access to the radio frequencies utilized by the hospitals ard anbulances identified in the plan? Does the use of existirs radio frequencies for cmmunications with hospitals and ambulances specified in the LII4D Transition Plan hinder the ability to implement response by fixed and mobile medical support facilities?
A.
We LIILO Transition Plan makes the followirv3 stateaent regarding radio comunications links between IERO (i.e. the local EDC in Brentwood, Iong Island, New York) aryl hospitals, fixed ambulance dispatch stations and mobile ambulances (see Section 3.4-C, page 3.4-3 of the plan):
Hospitals, fixed ambulance dispatch stations, and t.be nobile ambulances are equipped with their own radios which are used in day-to-day operations and will be coordinated through their normal channels. Lm o personnel will have direct radio or telephone comunication with applicable normal dispatch locations. Wis comunications link will enable 150 personnel to alert ambulance dispatchers to the need for ambulance service as the requirement arises. Se dispatchers in turn will contact the various ambulance units to satisfy Imo's needs.
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i It is accept:d practice to raly on existing radio links thtt have been established between hospitals, ambulance dispatch stations, and nobile ambulances. Reliance on these existing links would be expected to facilitate, rather than hinder, the ability to carry out the plan.
We LIICO Transition Plan indicates that it is not necessary for the BOC to be in direct contact with ambulance vehicles, energency medical services, and hospitals identified in the plan. his is because the plan specifies that IERO personnel will " alert ambulance dispatchers to the need for ambulance service as the requirement arises", and, that "the dispatchers in turn will contact the various ambulance units to satisfy IERO's needs" (see Section 3.4-C LILOO Bnergency Radio System).
Connanications with fixed and mobile medical support facilities are specified in the plan as follows:
Means Anbulance dispatch consnercial telephone stations and radio Ambulance drivers radio link via dispatch station Hospitals commercial telephone and radio links via anbulance dispatch stations and nobile ambulance units. l l
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With respect to radio frequencies used by field emergency response personnel, the LIIG Transition Plan states that " hospitals, fixed anbulance disptach stations, and the nobile amublances are equipped with their own radios which are used in day-to-day operations, and will be coordinated through their normal channels. (see Section 3.4-C, page 3.4-3).
'1hese ptovisions adequately meet the requirements for connunications with fixed and mobile medical support facilities required by planning standard F.2 in NUREG-0654.
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00NTENMON 55 0.58.
55-Does the LIIDO Transition Plan adequately provide for the prompt notification arv3 mobilization of key connand and control personnel to ensure that the fixed siren systen can be activated in a timely fashion?
A.
'Ihe answer to this question is covered in the responses to contentions 26C and 26D.
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Q.59.
56-Does the LIIG Transition Plan provide an adequate back-up alert an:3 rotification systen in the event of a partial or total failure of the LIIm siren system? Will this back-up systen meet the 15-minute notification requirements of NURBG-06547 Does the LILCO Transition Plan establish procedures to ensure that route alert drivers will be able to l
notify the public if their dosimeter readings exceed specified levels?
A.
'Ihe LILOO Transition Plan stipulates that " Siren activation will be verified by telephone survey (to be conducted by Marketing Evaluations, Inc.).
In the event of partial or total siren failure a route alerting system will be implemented in W1ich Lnm smergency vehicles, equipped with public address units, will drive through affected the areas in the plume exposure EPZ alerting residents to listen to the local Bnergency Broadcasting System (EBS) raiin station (see Section 3.3-E, page 3.3-4, Notification of the Public).
In the event that route alerting beones necessary, Procedure OPIP 3.3.4, page 4 of 7, establishes the following proce.ures:
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5.3 Route Alertina 5.3.1.
We Evacuation Coordinator will direct the Special Pacilities Evacuation Coordinator to initiate route alerting.
5.3.2
%e Special Pacilities Evacuation Coordinator will:
a.
Obtain the listing of all non-activated sirens from the Coordinator of Public Information.
b.
Contact the appropriate Lead Traffic Guide and direct that route alert drivers be dispatched to the areas requiring warning. Inform the Lead Traffic Guide which sirens are located in the downwind zones and direct that the Route Alert Drivers be dispatched to these zones before sending drivers to the other zones.
c.
When teams have been dispatched, rotify the Evacuation Coordinator.
An estimate of the amount of time required to implement and execute the route alerting backup alternative to the siren alerting system could not be located in the LIILO Transition Plan. Werefore, it cannot be determined whether the route alerting procedures described in the plan are sufficient to satisfy that these special arrangements will assure 100% coverage within 45 minutes of the population who may not have j
received the initial notification within the entire pitane exposure EPZ (see NUREG-0654, Appendix 3, Section B.2.C, page 3-3).
Route alertirn l
would be evaluated at an exercise or comunications drill. -
te plan specifies that emergency workers, including route alert drivers would be trained to inform their imediate supervisor if the reading on their low-range dosimeter goes beyond 200 mr. We Director of Local Response, as advised by the Radiation Health Coordinator, is responsible for authorizing exposures in excees of the EPA general public PAGs.
W erefore, route alert drivers may be requested to continue their route alert assigrinents if their dosimeter readings are within acceptable limits for emergency workers.
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i 00tm NTION 57 0.60.
57-Are there adequate provisions in the LILCD Transition Plan for notify-ing special facilities and other organizations equipped with tone-alert radios within the pline exposure EPZ to assure that these organizations would have sufficient time to i@lenent reconnended protective actions?
A.
We LILCD Transition Plan provides for an alert systen currently consist-ing of 89 fixed sirens nounted throughout the pitne exposure EPZ.
In Mdition to the fixed sirens, there is a system of tone activated alert radios for warning those organizations with a large ntsnber of people such as schools, hospitals, nursing hcrnes, harrlicapped facilities and major employers. Each special facility will be equipped with a Ibne Activated Radio receiver which, upon activation by the EBS signal from WALK rMio (97.5 FM), will automatically broadcast the emergency messages. W is system will provide these special facilities with direct notification during an Alert, Site Area Emergency and General Bnergency (See Section 3.3-E, page 3.3-4 of the plan).
However, there is no specific requirenent in TURBG-0654 for the activa-tion of tone-alert radios, prior to notification of the general public, to provide additional alerting or preparation time for the implementation of protective actions by special facilities. It should be noted that the plan provides for notification mi early disnissal of schools at the alert emergency classification level. -,-
'Ihe procedures for activating the tone-alert radios through WALK-FM radio is covered in the answer to Contention 20.
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.m 03MNTICM 58 O.61.
58-Are there adequate procedures in the LILCD Transition Plan to utilize telephones to verify that special facilities and individuals are aware of the need to evacuate and to ascertain their needs for assistance?
A.
%e LIIG Transition Plan satisfies the criteria for NrJREG-0654 plannin3 standard P, Bnergency Omsnunications, whidi requires 24 hour-per-day back-up means of connunication with energency response organizations (including special facilities). We plan stipulates that commercial telephones can be used as an alternate means of ominunication with hospitals, nursing hones, handicap facilities, and schools (see Section 3.4-E, Ccmnercial 'Iblephone and Centrex). As a canplenent to the sirens and tone-alert radios used to notify these facilities, comnercial telephone is considered an acceptable means of omsnunication for LEO to verify evacuation recarinendations, and to obtain information fron special facilities re3arding needs for assistance they may require. With respect to mobility-impaired individuals residing at home, their special needs will be assessed based on information they provide on the survey cards, which are to M returned to LILOO. A directory of mobility-impaired persons is being campiled based on the canpleted survey cards. In the event of an emergency at SNPS, the LERO Hane Coordinator is responsible for ensuring the evacuation of individuals who need assistance to evacuate their homes. We procedure by which the Home Coordinator verifies requests for assistance by telephone during an energency are detailed in Procedure OPIP 3.6.5 (see Section 5.1.2.f, page 3 of 20).
4 -_ _. _. _.
c With respect to separately domiciled hearing-imr>airei in31viduals, the plan makes the following provision:
l In the case of the deaf population at hcme, a LERO representative will be dispatched to their homes to inform then of the need to take protective action.
Pbr those deaf who are also disabled, they will be sent an appropriate vehicle to assist then in their evacuation.
(see Section 3.3, page 3.3-4 of the LILCO Transition Plan).
Based on its review of the plan, the RAC has considered these provisions for protecting mobility-impaired persons (including verification of their requests by telephone for assistance during an emergency) to be adequate proalded that the directory of non-institutionalized mobility-impaired irdividuals has been completed.
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00tMNfIGI 59 0 62.
59-Does the LIIID Transition Plan indicate whether the Coast Guard has the capability of notifying the general public on the waterways within the 10-mile EPZ within 15 minutes of the initial notification?
A.
We LIIH) Transition Plan makes the following statenent in Section 2.2, page 2.2-2:
United States Coast Guard he United States (bast Guard (USCG) provides public notification services for the general public on the waten within the "mejency pluning zone. Additionally, the U.S.
Coast Guard provides private ard comercial vessel traffic control and restricts access to affected areas in concert with LERO efforts.
However, the LIIXD Transition Plan is rot specific with reoard to the U.S. Coast Guard's capability for notifying the general public on the waterways within 15 minutes of tha initial notification. We Stardard Guide for Evaluation of Alert and ratification Systems for Nuclear Poer Plant 3 (FPMA 43/Septenber 1983) specifies that:
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'Ihe design report (describing special alerting methods) should include a description, including any assunptions made, of any analyses or calcolations necessary to verify that individuals in the areas in which the special alerting method is used can be provided an alert signal within 45 minutes when the design objective is to ensure coverage of the population who may not have received the initial notifi-cation (Section E.6.4.4.1, General Acceptance Criteria for Special Alerting Methods).
The Criteria for Acceptance established in Appendix 3 of NUREG-0654, recognize that there may be special ciretnatances under which it may not be possible to assure that both an alert signal and an informational or instructional message can be provided to the population on an area-wide basis throofnut the plane eqrnare EPZ, within 15 minutes. Under these conditions, the miniman acceptable design objectives for coverage by the system provide that:
c) 9pecial arrangements will be made to assure 100% coverage within 45 minutes of the population who may not have received the initial notification within the entire pltme expcnure EPZ.
Tae basis foc a,y special requirements exceptions (e.g., for extended water areas with transient boats or remote hiking trails) must be documented. Assurance of continued notifi-cation capability may be verified on a statistical basis.
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O W NNTIN 60 0.63.
60-Does the LIIID Transition Plan contain adequate guidelines for determining when selective sheltering will be reconnended by LERO officials and what populations would be subject to these reconnendations?
A.
Selective sheltering options are discussed on page 3.6-5 of the LII4D Transition Plan as follows:
Selective Sheltering W is protective action may be ordered at projecte3 doses belos the accepted PMs to minimize ralic>-
active exposure, particularly to pregnant women and children. Tne Selective Sheltering option will provide this flexibility.
E is protective action strategy has been adopted from the New York State Radiological Bnergency Preparedness Plan (III-50,51). It would not be recommerried without consultation with N.Y. State Comissioner of Health.
EPA's pluma exposure PMs, including recomended protective actions are listed in Table 3.6.1 of the LILOO Transition Plan.
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CONITNTION 61 0 64.
61.A,G,H and I-rbes the sheltering available for persons who may be advised to shelter during a radiological emergency at SNDS provide adequate protection?
A.
Sheltering is one of the possible protective action reo:nmendations. %e plan provides sheltering factors for various types of structures and pro-cedures, wMreby the decision-maker is to omipare projected exposures to the EPA PNis in makirg the decision with regard to protective actio 1 recomendations.
Q.65.
61.B-Does the LIIID Transition Plan irrlicate what actions individuals traveling in vehicles should take if sheltering is advised?
A.
We LILCO Transition Plan provides foc energency information bulletins to be transmitted to the p hlic using a network of Long Island radio stations similar to the Energency Broadcast System (EBS). Tne draft messages that may be used for providing instructions to the public are contained in Procedure OPIP 3.8.2.
Instructions that " people in the affected zones who are not at home should seek shelter inside buildings,"
are contained in the following draft messages:
Site Area Beergency (Sheltering)
General Bnergency (Sheltering)
General Bnergency (Sheltering and Evacuation)
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0.66.
61.C.1-Does the LIUI) Transition Plan contain adequate provisions to indicate that the necessary preplannirn for the sheltering of school children, including consideration of sheltering capacities and shielding capabilities of school buildings, is satisfactorily addressed?
A.
We plan establishes that tone-activated radio receivers will be provided to special facilities, incitxiing schools. W ese tone-alert radios will receive EBS messages which, as appropriate, would carry the following instructions:
All schools within the pityne exposure emergency plannirn zone are advised to shelter, that is, to keep diildren irdoors with outside ventilation sources closed off.
Parents should not drive to schen1 to meet their children, since the children are protected in schoal.
Convaercial telephone is used to complement the tone-alert radio systen, and to verify infornation transmitted via EBS.
The draft EBS messages contained in Procedure OPIP 3.8.2 contain the following inforration pertaining to the procedures for sh*-Itcrin3:
Sheltering is to remain irdoors with all windows and doors closed. Air corditioners/ heaters should be turned off, fires should be extinguished, and fireplace dampers closed. We people who should shelter are in planning zones....
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tese procedures will enable schools to shelter their sttdents.
I te LII4D Transition Plan indicates in AppeMix A (see page II-20) that preplannirv3 for the sheltering of school children has been considered under the following conditions:
men schools within the pitne exposure EPZ are in session, the schools will be advised to take the sane protective actions a those advised De the general public.
If some cmbinatio1 of shelteriny a-d na action is recomended for the general public, the s&ools would be advised to shelter.
If schools are in the process of opening, they will be Mvised to implement sheltering or evacuation.
The plan does not specify sheltering capacities and/or shielding capabilities for school buildings. Although there are na specific requirements for these guidelines to be included in off-site radiological emergenef preparedness plans, within the definition of sheltering given in the plan, it is projected that the schcrals would be sufficient to acconmadate the shelterinJ of thetc 46rimts in IM emt af a ra i!. el >J c.M e wJn j.
i 4
With respect to children on their way home due to early dismissal, see the answer to Contention 69C. :
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O.67.
61.D and E-Are there adequate provisions contained in the LILCD
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Transition Plan for providing sheltering to transients on beaches, on boats, in parks, or in other outdoor recreational areas?
A.
We draft EU messages that may be used for providing instructions to the public are contained in Procedure OPIP 3.8.2.
Instructions that " people in the affected zones wno are not at hczne should seek shelter inside buildings" are contained in the following draft messages:
- Site Area Emergency (sheltering)
- General energency (shelterin])
- General Emergency (shelteriry ani evacuation) ne Plan does rut syni*y t'u antl.fillit:y -)* b dlliajs, theie shelteriry capacities and/or shielding capabilities, that could be used by people who are not at home, including those on beaches, on boats, in parks or in other outdoor recreational areas. Hoever, it should be noted that there are na specific re<plenants 1.1 inW<-0654 with regard to shelteriry for transients on beaches, in parks, on boats aM/oc la athar recreational areas.
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1 CXN!ENTION 63 0 68. 63-Does the LIIID Transition Plan contain adequate guidelines for deter-mining when selective evacuation will be reenwnerded by IZO officials, and what populations (i.e. those with low tolerance for radiation) would l
be subject to these recommendations?
Selective evacuation options are discussed on page 3.6.6 of the LILCD A.
Transition Plan as follows:
Selective Evacuation Selective F:Jacuation may be implemented to evacuate from the affected area of the plane exposure EPZ members of the general public who might have a low tolerance to radiation exposure. Specifically, this would include pregnant en and children 12 years and under.
2 1s protective accioa strategy has been adopted from the M4 Vork State Mitological Emergency Preparedness Plan (III-33,54). It may be imple-mented for projected dose leiels of 1 to 5 rems whole hx1y or 5 to 25 rems to the thyroid, but ir,t witbNt consultation with the N.Y. State Conynirsioner of Health.
EPA's pitzne exposure PMS, includin] recornnended protective actions are listed in Table 3.6.1 of the LILCO Transition Plan.,
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4 GN11!NFICN 64 0.69.
64-Does the LHG Transition Plan contain adequate provisions for considering wind shifts during evacuation?
A.
Yes, the plan contains adequate provisions for considering wini shifts during an evacuation. A protective action reconnendation, in this case an evacuation, is preceeded by assessnent and dose projection.
Forecasted meterological conditions are considered in the initial step of
.ieveloping any protective action reconnendations.
T n po>:ejares include a precaution to consider meteorological conditions, and to review arri recalculate dose projections and resulting protective action reconnert!ations if changes occur. The only means of evaluatin3 En effectiveness of procedure imolementation would be an exercise.
00NIINfICN 66 0 70. 66.A-Does the LILCD Transition Plan identify an adequate ntsnber of tow trucks to deal with ytential impediments to evacuation?
A.
According to the inventory located in Procedure OPIP 3.6.3 (see page 46-A of 46), twelve (12) tow trucks are available for renoving disabled vehicles fran evacuation routes. Based on its review of the LITIO Transition Plan, the RAC has determined that provisions for the rerraval of cars by tow trucks is adequate. It should be noted that there are no spmific guidelines in 43RS3-0654 for determining whether the ntsnber of tow trucks identified in a radiological emergency preparedness plan would be adequate to remve disabled cars in the event of an emergency.
Q.71.
66.B *dat provisions are contained in the LITID Transition Plan for the timelv dispatch of tow trucks or other heavy equipnent to the site of an obstructioq?
A.
'Ihe LIllD Transition Plan makes the following provisions for dealing with potential i~ pediments to evacuation:
Disabled vehicles At the direction of the Traffic Control Coordinator, traffic control posts will be established, and potential impediments to evacuation will be renovel thrvo35 the use of tw trucks or other heavy equipnent (see Section 3.6, page 3.6-6 of the LII/D Transition Plan). l
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0.72.
66.C-Does the LIILO Transition Plan make any provision for the evacuatioq of persons whose automobiles became disabled enroute?
A.
Section 3.6 (see page 3.6-6) of the LIICO Transition Plan makes the following provision:
%ose persons without a means to evacuate will be transported by buses that will follow the pre-established routes identified in the public information brochure. We Transportation Support Cbordinator will coordinate bus operations and ensure an adequate supply of buses ard drivers, refer to Bus Route Procedure 3.6.4.
Procedure OPIP 3.6.4 (see page 6 of 42) stipulates that it is the responsibility of the Transfer Point Coordinator to monitor the progress of the evacuation, ard dispatch buses until all evacuees are picke3 up.
Q.73.
66.0.we there aiepate assurances in the LIIIL Transition Plan that snow remval vill be urdertaken by the local organizations in the event of a radiclagical err.ergency an SNPS?
A.
According to page 2.2-4 of the plan, it is anticipated that snow remval will be provided by local organizations in their normal fashion during an amergency. During severe snow or an ice storm, the plan reconnends selective or general sheltering until the hazard is mitigated. Raaad on
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its review of the plan, the RAC has suggested that pre-emergency planning for snow renoval on the evacuation routes be further developed to inclixie adninistrative procedures, SOPS, etc. These procedures have been recomended to insure that the snow renoval strategy would coincide with any evacuation scheme that might be chosen.
It should also be noted that no letters of agreenent with local snow removal organizations could be located in the LILCO Transition Plan.
Q.74.
66.F ' hat provisioits are contained in the LIIH) Transition Plan for dispensing gasoline during an evacuation, an$ how may these provisions impact an evacuation?
l A,
The Road Crew ?in:edure contained in Procedure OPIP 3.6.3 provides that vehicles requiring fuel will be provided with 1.here (3) gallons of gasoline fern fuel trucks at assigned locations.
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CDmNrION 67 0 75. 67.A 1,2 and 3-Does the LI @ Transition Plan adequately provide for transportation for the transit 4 ependent general population?
Specifically, are there a sufficient neber of buses available?
A.
As indicated in the answer to Contention 24P, the LIIID Transition Plan l
identifies approximately 1560 buses (including buses, vans, coaches, I
flexetts, etc.) for use in evacuatiry the transit-dependent general p)pulation. Ho ever, the letters of intent with the bus companies designated to supply these vehicles have not as yet been finalized.
'1herefore, it cannot be determined at this time whether the 333 forty-passenger buses that have been estimated as required in Appendix A (see page IV-745) to evacuate the transit-dependent general population a nid actually be available for use by L52tD.
Q.76 67.C-Will the use of Transfer Points, as outlined in the LILCD Transition Plan, an3/or tne possible use of m.utiple bus runs impact the timely evacuation of the transit-dependent general population frm the plme exposure EPZ?
A.
Guidelines for the preparation of Evacuation Time Estimates within the_
Pltune Exposure Pathway Bnergency Planning Zone are contained in Appendix 4 of NUREG-0654. to the extent that the evacuation time estimates -
contained in Appendix A of the plan have been assessed during the RAC review of the plan, these estimates meet the VJREG-0654 standards (see consolidatei RAC review of the LIE Transition Plan, dated February 10, 1984, appended to this testimony). Any further assessnent of the effect of " Transfer Points" and/or mutiple bus runs on the evacuatim time estimates, that are contained in the plan would require technical evaluation of the methodology and/or assumptions used to develop these estimates.
0.77 67.D-Are there adequate provisions in the LI E Transition Plan to ensure that transit-dependent evacuees at the Transfer Points will be adegaately protectei while awaiting transp)ctation to the relocation centers?
A.
We LILOO Transition Plan does not contain specific procedures detailing how transit-depeaient evacuees would be protected if they must await the arcival of transportation vahicles at the Transfer Points designated in the plan. It should be roted, 'rmever, that in its review of the pl+1, the RAC noted that there are rn specific provisions detailinJ has protective action recomendations would to developed in the absence of an actual release (see RAC review coments for element I.8 and J.10.m).
% erefore, it has been recommended that the plan should specify that protective actions sudi as sheltering, and especially evacuation could be implementei prior to significant releases hammA on a tedinical assessnent of plant conditions.
l l
1 00tmMPICN 68 0 78.
68-Does the LILCO Transition Plan specify under what ciretrnstances an early dismissal of schools is implemented? Are there Mequate provisions for the protection of school children, if different protective actions are recomended for the general population?
A.
Appendix A of the LILCD Transition Plan makes the following provision for early dismissal of schools in the event of a radiological energency at the Shoreham Nuclear Power Station:
In the event of an emergency, schools will be rotified of any Alert or higher emergency classification by the Emen3ency Broaicast System aM by telephone. Each public school district, parochial school, and nursery school in the EPZ will have a tone alert receiver which will auto-matica11y activate and transmit the EBS message. 'Itle EBS message will advise the schools to implement specific protective actions and may contain general information about the coMition of the plant, radiological conditions, etc. In addition, each school district superintendent aM individual in charge of the private schools in the EoZ will be contacted by telephone by either the Pablic Sciuols Coordipator or Private Scnools Coordinatoc to verify that the E33 messa39 m o:c 3iel, <11 to receie requests for additional assintance.
Upon an initial declaration of an Alert or a Site Area Emergency where no protective action is recommended for the general public, school officials will be advised to implement their early dismissal plans if schools are in session. Students would return hme as expeditiously as possible by their custmary mode of transportation. If one of these declarations occurs when schools are in the process of opening, school officials will be advised to have arriving buses return their students to their homes, l
and to have students who do not normally use buses to I
return hme in their usual manner. If school is not in l
session and an Alert or higher emergency classification is decla*ed, school officials will be Mvised to cancel classes for all schools in the EPZ until the emergency is terminated.,
If schools within the EPZ are stin in session when a protective action is reconnended for the general public in any area of the EPZ, the schools will be advised to take the sane protective action. That is, if some com-bination of sheltering and no action is recm mended for the general public, then the schools would be advised to shelter and put their buses on stan$by. If same can-bination of sheltering and evacuation is re".
.n-f+i for the general public, then the schools would be advised to evacuate to pr H esignated reception centers. If schools are in the process of opening, then they will be advised to inplement sheltering or evacuation, as appropriate, when their students arrive.
Those schools ouside the EPZ which have students living in the EPZ will retain those students at the school when the school day ends, if any protective actions are recomnended for the general public in any area of the EPZ (See Appendix A,Section II, pm e II-20 of the LILOO Transition Plan).
We consider that the plan exitains adeIuate provisions for protecting school children, providei that the plan is revised to ensure that the implenentation of protective actions takes into account an assessment of plant coniitions prior to actual releases.,
00lm WfION 69 0.79.
69.B-Dws the LII4D Transition Plan discuss the details of the early dismissal plans for schools or school districts within the pi me exposure EPZ?
A.
Provisions for the early dismissal of schools within the pl me exposure EPZ specified in the answer to contention 68 are 03nsidered adequate, provided that the plan is revised to ensure that the implementation of protective actions takes into account an assessment of plant conditions prior to actual releases.
O.31 69.C.1 & 2-Does the LIL T Transition Plan provide sufficient time to allow sc+ml childrea to arrive hone, so that they are urder the care of i
their parents, in the event of implenentation of an early dismissal?
A.
The LIIID Transition Plan does not specify the amount of time requiral for school children to arrive home if schools are dismissed early.
However, there are rn specific NUREG-0654 standards for returning children h ae in the event that an early dismissal of schools. As noted in the answer to contention 67D, there are no provisions detailing how protective action decisions would be developed in the al.,.ce of an actual release (see RAC review coments for element I.8 and J.10.m).
'Iherefore, the iMC has recomeMe.i that the plan should specify that the early disnissal of schools could be inplemented prior to actual releases.
-76
.. /._
.m.
0.81 69.D-Does the LILOO Transition Plan address the care of children being dismissed fran school pursuant to early dismissal, and returning to an i
empty house without adult supervision?
A.
Considerations pursuant to the care of children returning to an empty house as a result of early school dismissal could not be found in the plan, mr is this specifically required by NURBG-0654.
0 82.
69.E-Does the LIIID Transition Plan contain any procedures that aidress the situation wherein the emergency escalates after early dismissal pr>-
cedures have been initiated, but before the children have been returned to their hmes?
A.
'Ihe eswer to this question ic the sane as that given for Contentions e
69.C.1 a 2.
(
. -.a =-. -....
03m!NTIN 70 l
0 83 70-Does the LIIID Transition Plan identify relocation centers for the schools within the plume exposure EPZ, and does it o>ntain procedures for reuniting children with their families at these centers?
A.
Appendix A of the LIICO Transition Plan provides that "if some cambination of sheltering and evacuation is reconnended for the general public, then the schools would be advised to evacuate to pre-designated reception centers." A list of educational facilities that may be affected within the plume exposure EPZ is contained on pages II-10 and 10a of Appendix A of the plan.
Suffolk County Ominunity College, BOCES in Islip, and SUNY In Stony r3rr&
are the primary relocation centers. Two back-up centers (STTI -
Faenirgiale, t..Toseph's College - Patfngue) have been identified.
However, an identification of which schools are prNesignated for wtlich reception ceaters an.1 pr e iures for reuniting children with their families at these centers could not be located in the plan. Puthermore, the plan establishes promiures for the early dismissal of schools and returning school children hane to be reunited with their families at the alert emergency classification level. However, procedures for reuniting children with their families at relocation centers in the event that schools arvi the general population would be evacuated simultaneously could not be located in the plan.
_1 CONFENTION 71 0 84.
71.A.1-Du;4 the LIItD Transition Plan indicate where the buses would be located arri thei'c accessibility to LIW erployees, if necessary, during
, a rkliolojical mergency?
T.
719 plan Liignates t'w lxations of the various bus companies which have provided letters of intent to supply buses to LERO. However, the plan does not assign LERO drivers to any specific bus company. We plan.i m
.pevide, in >rocM ure OPIP 3.6.4, page 2 that the bus coordinator woald assiiyt the drivers to specific bus companies dependire upan dite'i swa,
of the pitme ergosure EPZ are to be evacuated. Based on tha p1ai esii*e cwheted by the RAC, it is not possible to determine at this ti.aw the accessibility of buses to LI@ drivers. We issue of bus accessibility atild N assesv2].lucinj an exercise based on interviews with selected bus ea1pinie.;.
2.35.
- 71. A.2 'J3es the LII4D Transition Plan contain provisions for the supervision of children at schools, in buses and at relocation centers?
' A.
The LILCD *ransition Plan makes the following Mision in Procedure OPIP
.cs: -
3.6.5, Section 5.3 - Evacuation of schools:
/
4
_73_
k q_
NDPE OFFICIAIS OF PUBLIC AND PRIVATE SCHOOLS [DCATED IN
'1HE 10-MILE INERGENCY PLANNING ZONE (EPZ) 51AVB 'IME RESPCNSIBILITY IN A RADIGIDGICAL EMERGENCY '10 PROVIDE
'1 HEIR SWDEtfrS WI'1H 'IHE BEST POSSIBLE PRDIECPION AND ARRANGE FOR 'IEEM 'IO 88 SAFELY REUNITED WI'1H
'lHEIR FAMILIES AT '1HE EARLIEST OPPOR'IUNITY. '1HE LERO DIREC10R OF IDCAL RESPONSE WILL P90VIO8 GUIDANCE AND INSTRUCTIONS 'IO ACOOMPLISH 'IERSE PURPOSES (BASED ON PREPLANNING BY SCHOOL OFFICIATS EOR 'lHEIR OWN FACILITIES).
Q.86.
71.B-1-Does the LIIID Transition Plan contain information regarding the arount of time necessary to evacuate children in nursery schools and other school populations within the plume exposure EPZ to relocation center facilities?
A.
We LII/D Transition Plan is predicated on the assumption that there will be an early dismissal of schools at the alert emergency classification level and, therefore, the evacuation time estimates far the general population shown in the plan include school children. Wis issue is addressed in Appendix A of the plan (see page V-1) which makes the following stipulation: _._
- ether or net school is in session at the onset of an accident J;.ould not significantly influence evacuation travel times. Specifically, school being in session muld serve to extend the trip generation time s>newhat.*
(footnote)
- Children are assumed to be released frm school to the hone concurrently with the comnuter trips from work to home. We departure of the family from home to initiate the evacuation trip is, in general, delayed due to school bein<J in session, only if the children return home later than the o>anater.
0 37 71.a.'l-ines the iIrm Transition Plan rely on multiple bus runs, more than one trip by each bus, in order to evacuate all school children, and is the number of these mutliple bus runs sufficient to transport all school children out of the pitzne exposure EPZ in a tLmely fashion?
A.
W e t.Itm t'ransition ?lan stipulates in Section 3.6 (see pages 3.6-6 and
- 7) that the Bus Coordinator will e nedinate bus oy cations. Procedure OPIP 3.6.'5 contains provisions whereby the Bus Coordinator, the Public School Cmrdinator, and the Private School Coordinator will coordinate the use of buses should it he necessary to evacuate school children. No specific reference to the need foe "ml.tiple has runs" to evacuate all school children could be locab+1 in the alin.
l '
8
00ImWFIGE 72 Q.88.
72.A-Does the LIrm Transition Plan indicate how long it will take to evacuate the various special facilities in the EPZ?
A.
Yes, the LIILO Transition Plan provides evacuation time estimates for special facilities within the plume exposure pathway in Table XV of Appendix A (see page V-8).
'1hese evacuation time estimates take into consideration the following circunstances:
Normal conditions Adverse cort.11tions - samtec Adverse conditions - Ninter Q.89.
72.C-Does the LILCO Transition Plan identify any relocation or reception centers for persons evacuated from special facilities other than those for United Cerebral Palsey of Greater Suffolk, Inc.?
A.
An inventory of individuals in the special facilities who may require evacuation to relocation centers and the transportation resources which are available are shown in Procedure OPIP 3.6.5, Attachment 2.
- However, the relocation centers to which these persons would be evacuated had not been arranged at the time of the RAC review of the LILCO Transition Plan.
0 90. 72.D-Does the LILOO Transition Plan irvlicate when, and under what circunstances John T. Mather Menorial, St. 01arles Hospital, and Central Suffolk Hospital would be evacuated in tlw emot of a raliol:>J cal ent-l gency at S'IPS?
A.
The plan does not intend that evacuation would be reconnended for these hospitals. As stated in Procedure OPIP 3.6.5, page 1, sheltering will be the primary protective action reonnendation for John T. Mather, St.
Charles, and Central Suf folk Hospitals. The following section is taken from the above reference.1 nje.
i i
IM Sri %fMRIN14C:4, V. Ots pit ['tw J ocgOct'/3 AcrIJi RECOMMENDATION EOR MATHER, ST. CHARLES, AND CD70RAL SUPEOLK HOSPITAL DUE TO THEIR DISTANCE FROM SNPS AND THE SilIELDING APEDRDED BY '1 HEIR SfRUCTURES.
IF AN EVACUATION IS DESIRED BY THEIR AD4INISTRATORS FOR ALL OR PART OF fiSIR pac [8,'ff' APJtATION, WMtWF1TOS '4CLL BC M408 USItKI AVAILABLE RESOURCES.
Q.91.
72.E-Does the LIIOD Transition Plan provide adequate means for protect *, -j patients in hospitals in the event that evacuation of the pitne exposure EPZ is reconnended?
A.
As stated in the answer to contention 720, the primary protective action recmmendation for the hospitals is in-place sheltering. Due to the fact that the hospitals in question are near the boundary of the EPZ, this decision was evaluated as being adequate (see PAC review at J.10.d).
Since the evacuation of hospital patients is planned as a secondary pro-tactive action recommendation, the use of resources on an as-available huis is rnultiecel aleluate.
i
l GNMITIGI 73 Q.92.
73.A.1-Is the preregistration system outli'ned in the LIIf0 Transition Plan to identify handicapped iniividuals residing at hane sufficient to identify those in31viduals needing special assistance?
A.
Se plan has procedures for a directory of ron-institutionalized mobility-impaired persons to be cmpiled based on completed survey cards of special needs of the handicapped that will be returned to LILCO.
Wese cards are contained in the public infoonation brochure. We plan is adequate in addressing this planning criteria, provided that the directory of non-institutionalized rrobility-impaired individuals is i
cmpleted.
Q.93.
73.4.2 ary3 3-Does the LIIDO Transition Plan make provisions for vecifylag the list which will be campiled from the returned postcards used in the pre-r.w3 stration system of the handicapped and for updating that 1
information on a regular basis?
A.
According to the plan, the public information brochure will be distributed annually. We are not aware of any provision for verifying the list and information needs for special elistance to be onpiled from the mail-in cards. -,
0 94.
73.B.1-Are there adequate provisions in the LIILO Transition Plan for notifying non-deaf handicapped individuals?
A.
We provisions for notification of the non-deaf non-institutionalized handicapped is considered adequate.
If special problems exist sud that the haniicapped are unable to comunicate by telephone, these cases should be identified on the preregistration cards which are to be distributed with the public information brochure. Again, the plan is considered adequate provided that the directory of non-institutionalized mobility-impaired individuals is conpleted.
Q.95.
73.B-3-Does the LIIDO Transition Plan identify sufficient personnel to assure that disabled individuals will be notified promptly to permit their timely evacuation to reception centers?
A.
We plan does not specify the number of personnel to tw assigned.
However, until the listing of the needs has been c>npiled fron the pre-registration cards, there is no way of ascertaining how many handicapped individuals will need assistance.
l l
l f
0 96. 73.B.4-Does the LIIID Transition Plan identify the estimated evacuation t
times for non-institutionalized handicapped individuals?
A.
Appendix A of the LILC3 Transition Plan states t'ut "the staly to obtain evacuation time does not explicitly consider the provision of bus service, m bulances or other specialized vehicles" (see page V-2).
i Q.97.
73.B-5-Does the LIIOD Transition Plan imilcate the ntaber of route alert drivers that would be assignol to rutify.nl avacuate the dsaf?
A.
The plan d>3s not specify the number of drivers to be assigned to rntify and evacuate the deaf. However, until a list of the handicapped and their needs has been ccmpiled from the preregistration cards, there is no way of ascertaining how many deaf inlividuals will need assistance.
Thre5 W, T1einibec oE.leivers tSat may be neeied cannot be determined i
at this time.._
Ompf!BrFIGI 74 0 98. 74-Does the location of the relocation centers identified in the LIIID Transition Plan comply with the requirernents of planning staMard J.10.h of NUREG-0654?
A.
1he RAC evalitatiori of the ;)lart f.>tal r r-ibar-i s 213 mt T.10.h to be inadequate. Of the three primary relocation centers identified, only the BOCES in Islip was found to be further than 5 miles beyond the EPZ boundary (see RAC review at J.10.h).
4 e
i.,
03r1Bff!GI 75 0 99 75-Does the LIIID Transition Plan contain information as to the number of individuals expected to utilize the relocation centers? Does the plan indicate that sufficient facilities (e.g, toilets, showers, food preparation facilities, drinking water, and sleeping acw.....adations) are available in the relocation centers?
A.
Estimates of the number of transit-dependent evacuees expected to arrive at the relocation centers are contained on the evacuation route descriptions in Appendix A of the LILCO Transition Plan (see pages IV-75 through IV-163). However, relocation center assigrinents for the popula-tion expected to evacuate the plume exposure EPZ by their own means could not be located in the plan.
According to Appendix A of the LILOO Transition Plan, it has been estimated that 9% of the seasonal population will require housing at a relocation center (see pages III 38 and 39).
Furthermore, the following criteria were used in selecting the relocation centers and linking evacuation zones to these facilities:
Adequate distance from the EPZ boundary Reasonable highway access On-site power security On-site power generation capability 4
f -
Adequate parking
)
Adequate sanitary facilities Adequate cafeteria facilities An assessnent of the ntaber of individuals estimated to use the various relocation centers and an analysis of the accomnodations and facilities at these centers was not undertaken as part of the RAC review. Criteria elements J.10.h and J.12 of NUROG-0654 consider only the distance of the relocation centers from the plume exposure EPZ and the adequacy of equipment, personnel and procedures for monitoring and registering evacuees. Based on these considerations, the relocation centers identified in the LItf0 Transition Plan are considered inadequate to meet the requirements of IUREG-0654.
OCEffENTIGi 77 Q.100. 77-Is the equipment used by LILOD, to measure thyroid contanination at relocation centers (RM 14 with HP270 probe) capable of differentiating actual readings from background readings?
A.
Yes, the equipnent used to measure thyroid contamination is adequate, if the actual reading is sufficiently above the background reading. We plan in Procedure OPIP 3.9.2 calls for maintaining background in the decontanination facility / relocation center at levels less than 50 CPM.
The 50 CPM level is for "open window" readings (beta plus gamna), while the thyroid scan procedure action level trigger-point is 150 CMP above background " closed window" (gamma only). We gauna only background would be less than the 50 CPM if the beta plus gamna' readings are 50 CPM or less. The instruments described are capable of detecting activity which would be greater than three times background. An exercise would be necessary to evaluate whether proper actions are taken if background exceeds the 50 CPM level.. -.
G3rfBfrIGE 81 0101, 81.A-Does the LIIOD Transition Plan provide adequate procedures for the disposition of containated lactating dairy animals or the treatment of uncont ainated lactating dairy animals? Do those procedures assure that the milk or meat products of these animals will be kept fran public constynption?
A.
The LILOO Transition Plan has adopted the U.S. Pood and Drug Administration PAGs which contains both preventative and emergency PAGs.
The plan in Procedure OPIP 3.6.6 contains instructions to be transmitted to the food chain establishments, if projected,or measured containation levels exceed the response levels equivalent to the preventative or emergency PAGs.
Q.102. 81.D-Does the LILOO Transition Plan contain adequate provisions for determining acceptable decay period (s) for short-lived radioisotopes and for dealing with long-lived isotopes which could pose a serious health consequence to the public through the cont aination of food? Does the plan identify the procedures that would be used to determine how tne withholding of contamin&ted milk would be achieved; how the prolorged storage and special pasteurization of milk would be achieved; how the diversion of production of fluid milk would be achieved; or how the introduction of milk supplies into ccmerce would be prevented?
A.
%e LIUD Transition Plan uses the methodology established by the U.S.
Pbod and Drug Administration for dealing with contaminated food stuffs.
% e decay period for short-lived radioisotopes is handled by standard methods which involve the half life of the nuclide, the initial containation level, and the response level for a particular protective action. Food stuffs contaminated by long-lived radioisotopes are dealt with solely by considering the response level for a particular protective action. We methods which allow for decay of short-lived radionuclides consists of prolonaed storage after pasteurization of milk or diversion of fluid milk to other products which will not reach the public until after an appropriate decay period. % ese methods cannot be implemented if storage or product diversion capability do not currently exist. We Radiological tiealth Coordinator is responsible for contacting the food chain establishment and informiry) the of the protective action recam-mendations. %e public is to be informed by the Coordinator of Public Information of protective action recommendations.
In addition, the U.S.
Food and Drug Administration has the authority to conden containated food stuffs haviry) the potential for or intended for interstate comerce.
Q.In3. 81.C-Does the LIUD Transition Plan contain procedures for disposinq of the wash water or milling residue rmoved fra contarninated foods and does the plan contain procedures for identifying the source (s) of farm produce, including those informally sold at local farm stands?
A.
Procedures for disposing of wash water or milling residues removed from containated foods could not be located in the plan. However, if sufficient contamination were to be released so that these protective actions would be warranted, there would be a large area of contamination - -
i i
and any problen with these residues would be minor. Procedure CPIP 3.6.6 i
contains a listing of agricultural fams and processing plants within the EPZ. However, it cannot be ascertained if all local farm stands are i
included.
i i
Q.104 81.0-Does the LIIG Transition Plan contain maps showing key land use
)
data, watersheds, water snpply intakes, and water treatment plants? Does f
l the plan indicate how potentially contaminated water supply wells would j
be identified and isolated? Does the plan indicate f::ta where alter-native water supplies would be acquired?
i A.
As stated above in the answer to contention 81C, the plan contains lists of farrs and food processing plants within the ingestion pathway EPZ.
There are, however, no maps referenced for recording survey and monitoring data, key land use data, daries, food processing plants, watersheds, etc.
If LIIm has access to State maps, this should be l
l referenced in the plan. % ere are also no lists of food processing facilities located outside the 50-mile EPZ which process food originating i
within the 50-mile EPZ. W e plan states that potable water should not be I
l constsned before the source has been checked and approved for use.
According to the plan, water from closed tanks and covered wells, which
{
is not contaninated, could be constsned. We Health Services Coordinator j
would make arrangements for alternate emergency water supplies.
I
-es-
0.105. 81.E-Does the LIIG Transition Plan irrlicate how the diet of residents and transients is to be restricted, how cont a ination of food products would be implemented, and how exports of agricultural products and ducks frcn Suffolk County would be controlled from being distributed to other parts of the county?
A.
According to 2e LIIED Transition Plan in Procedure OPIP 3.6.6, Section 5.C, once the decision would be made to curtail the mnsumption of food or water, the Director of Incal Response would approve procurement of We IoJ stics Support Coordinator will obtain these i
necessary supplies.
supplies through Material PurchasirrJ and the Support Services Coordinator would arrame for local distribution. We plan states on page 1 of Procedure OPIP 3.6.6., that LIIED will compen:: ate for food which is not salvmeable. W e plan also states (see Procedure OPIP 3.6.6, Sect.
5.1.3.6) that the Director of Incal Responso will contact the States of New York and Connecticut with the IEPO ingestion pathway protective action recomendations. If the States are willing to impleent their own plans for the ingestion pathway, ro further IIRO actions are necessary.
However, if the States are unwilling to implement their plans, IIRO has procedures to contact the affected facilities (OPIP 3.6.6 Sect. 5.4).,
Q.106. 81.F-Does the LIIDO Transition Plan indicate the resources (i.e.,
nersonnel, facilities and equipnent, including corununications equipnent) that would be mEde available to implement protective actions within the ingestion pathway EPZ?
j A.
We implementation of ingestion pathway protective actions is to be primarily carried out by food chain establishments. Werefore, specific resources for the implementation of these protective actions are not shown in the plan. We procedures to notify these establishments of what protective actions to take are given in Section 5.4 of Procedure OPIP 3.6.6 4
1 I
l l l l
l OmrferFIGI 85 0107. 85-Does the LILCO Transition Plan contain acceptable plans for recovery and reentry?
A.
The RAC review of the plan found NUREG-0654 element M.3 to be adequate, but elements M.1 and M.4 to be inadequate. Criteria element M.1 was found inadequate because the procedure referenced (Procedure OPIP 3.10.1) is based upon incmplete considerations. For ex mple, a partial or total evacuation of the plume exposure EPZ would have to be implemented prior to convening the Recovery Action Comittee. W is provision is considered inadequate since recovery actions may be required if only sheltering had been reccanended. With regard to critieria element M.4, the plan does not contain a method for periodically estimating total population exposure. We plan does provide, however, that an organization will be established for this purpose (see page 3.10.2 of the plan)..
CCWIBrf!GI 88 Q.108. 88-Does the LIIID Transition Plan contain a method for converting accept-able surface contamination levels from units of disintegrations per minute to radiation doses (e.g., persons-rens) so that re-entry decisions can be made, and does the plan indicate how the cost benefit analysis for temporary reentry ($1 000/ person-rem) will be applied?
A.
The conversions for disintegrations per minute to radiat. ion doses are not needed. We plan uses the criteria in Regulatory Guide 1.86, which the 1
NRC uses to return licensed facilities to unrestricted use. We Health Services Coordinator will consider requests for temporary reentry based on the known exposure rates from surveys and the cost-benefit analysis (see Procedure OPIP 3.10.1, Section 5.5.1).
l
G3rfBrfIGI 92 Q.109. 92-Does the New York State Radiological Dnergency Preparedness Plan discuss the SNPS site in sufficient detail to assure coordination between the LERO and LII4D emergency response and a potential response by the State of New York or Suffolk County?
A.
The lack of assurance of coordination between LERO and a potential response by New York State or Suffolk County has been identified as an area of concern by the RAC in its review of the LITIO Transition Plan.
The plan does, hcwever, contain provisions (see page 3.1-1) for the LERO Director of Iocal Response to work with Suffolk County representatives if they should choose to participate. 'the States of New York and Connecticut are also included in the plan (OPIP 3.6.6) in connection with implementation of protective action reconnendations in the ingestion pathway EPZ.. _.
CCMWFIGE 93 Q.110. 93.A-Does the LII4D Transition Plan indicate whether the EOC has a back-up power supply or alternative facility that would enable the EOC functions to be continued if offsite power is lost?
A.
A gas generator is included in the list of major equipnent at the local BOC in Brentwood, Iong Island, New York (see page 4.1-4 of the plan).
0 111. 93.B-Does the LILOO Transition Plan indicate whether back-up power is available at staging areas, bus transfer points, receiving hospitals, or relocation centers? Does the Plan indicate whether these facilities would be able to function if there was a loss of offsite power?
A.
The availability of back-up power at staging areas, bus transfer points, hospitals, or relocation centers could not be located in the plan.
However, the plan states that on-site power generation capability was one 1
of the criteria used in the selection of relocation centers (see answer to contention 75).
l 9
l '
03ffWrf1GI 94 0112. 94.A-Does the plan indicate whether back-up power is available at tr'e LILCO Cust mer Service Office to assure the notification of LERO in the l
event of an offsite power failure?
A.
The availability of back-up power at the LIIf0 Custoner Service Office (in Ficksville, Long Island, New York) could not be located in the LIILO Transition Plan. According to provisions in the plan, the RECS line in 4
the LILOO Customer Service Office is monitored 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s-per-day. The LERO officer at the Customer Service Office is responsible for activating the paging system which notifies key emergency response personnel that an actual incident has occurred. Page 3.4-5 of the plan states that the paging systens can be accessed by any telephone, including telephones at the following locations:
l LILCO Customer Service Office, Hicksville Incal EOC, Brentwood 0113. 94.B-Does the LIILO Transition Plan indicate whether the EDC has back-up power to assure that LEIO would be able to notify energency personnel in the field if offsite power is lost?
A.
As stated in the answer to contention 93A, the EOC has a back-up generator and would be able to continue notification of personnel in the field in the event of an offsite power failure. _-
OGr1Mri'IQt 95 Q.114. 95.A-Does the LIIID Transition Plan indicate whether the siren system has a source of back-up power that would enable them to be operated in the event of an offsite power failure?
A.
LILOO has contracted with Marketing Evaluations, Inc. to verify that each siren has activated. Information regarding whether the siren system has back-up power could not be located in the plan. We plan makes adequate provision for route alerting, in the event of partial or total siren failure (see page 3.3-4 of the plan).
Q.115. 95D-Does the LILCD Transition Plan indicate whether the tone-alert radios will have back-up power (including batteries) that would enable them to operate in the event of an offite power failure?
A.
We plan provides for weekly testing of the tone-alert radio system.
his testing program should be sufficient to insure reliable operation of each radio assuming that these units are not solely dependent upon electrical power. Specific reference as to whether the tone-alert ratios will be battery operated or have backup electrical power could not be located in the plan.
_96-
Q.116. 95E-Does the LIILO Transition Plan indicate whether the Bnergency News Center has a back-up power supply or alternate facility that would enable it to continue functioning, if there is a loss of offsite power?
A.
The availability of back-up power or an alternate facility for the Dnergency News Center could not be located in the plan. It should be noted that NUREG-0654 does not specifically require a back-up power supply for the Dnergency News Center.
CGerarffGI 96 0117. 96.A-Does the LIIXD Transition Plan indicate whether the private ambulance services and bus empanies listed in the Plan have the capability for supplying their services to LEBO in the event of a loss of offsite power?
A.
The capability for atulance services and bus conpanies to supply their services if there is a loss of offsite power could not be located in the plan. However, since atulances and buses are Itabile, the primary concern is for the capability of LERO to be able to cmmunicate the need for vehicles. According to the plan, this cornunication is handled by two-way radio which should have the capability of operating without offsite power. Furthermore, this capability would be evaluated during an exercise.
Q.118. 96.B-Does the LIUDO Transition Plan indicate whether the hospitals, nursing homes and facilities for the handicapped located within the EPZ have the capability of implementiry protective actions that may be recommended if there is a loss of offsite power?
A.
No specific discussion as to the implementability of protective action reconnendations at special facilities in the event of loss of a offsite power could be found in the plan.
Q.119. Teiat impact would a power failure have during an evacuation of the pitne exposure pathway as it relates to residential lighting, street lights, traffic signals and service stations?
A.
'Ite plan does not address back-up power for any offsite facility except the local EOC (see answer to Contention 93.B). A power failure during an evacuation would have significant initial effects brought about by traffic-signals and gas pumps not functioning.
7 i
1 i !
Y GMmpf1GI 97 Q.120. 97.B-Does the LILCD Transition Plan take into account a range of possible weather conditions (including unfavorable weather) in order to adequately consider the mobilization, deployment and emergency response of LERO personnel?
A.
W e plan considers weather conditions in connection with the evacuation time estimates. W e question of mobilization and deployment of response personnel during adverse weather conditions could not be located in the plan.
-100-
r
, q' Thoeae E. Baldvis Senior Demographer / Economist Professional Skills:
Demographic /Econorsic spec ialist experienced in economic Dr. Baldwin is a and soc ioeconomic analyses for industrial and energy development projects.
experience with strong technical capabilities in He has over ten years demographic and economic forecasting, cost-benefit and financial feasibility analyses, and market studies.
Professional Experience 1983 - present Environmental Systems Engineer Energy and Environmental Systems Division Argonne National Laboratory Carden City, New York Dr. Baldwin is Regional Coordinator for support services provided by Argonne National Laboratory under contract to the Federal Emergency Management Agenc y.
He is responsible for the scheduling and management of services furnished to the FEMA, Region II of fice in New York City.
Dr.
Baldwin is experienced in reviewing state and local radiological emergency plans and evaluating their capabilities to protect populations response living in the emergency planning zones surrounding commercial nuclear power plants.
He frequently serves as a federal observer and team leader at off-site radiological emergency preparedness exercises and is responsible for the preparation of post e xe rc ise assessment reports detailing the results of these exercises.
1782 - 1983 Senior Demographer / Economist Energy and Environmental Analysts, Inc.
Environmental Consultants Carden City, New York Responsible f or analyzing the demographic, economic and social aspects of energy and industrial projects.
Served as a consultant to the Port Authority of New York and New Jersey, New York Public Development Corporati.on and Merrill Lynch Pierce Fenner and Smith, Inc., in assessing the economic feasibility of a satellite telecoussunications facility for New York.
As a c o n s ultant to Argonne National Laboratory, reviewed state and local of f-site radiological emergency response plans for commercial nuclear powe r plants in New England, New York and New Jersey.
Also responsible for expanding Energy and Environmental Analysts' base of clients who require assessments o f ec onoetic return and the socioeconomic impacts associated with metropolitan development projects.
i
/
Professional Experience Continued:_
1981 - 1982 Manager of Economics Dravo Van Houten, Inc.
Consulting Engineers New York, New York Energy Economics - Managed marketing and project evaluation analyses of and gas industry leading to corporate investment decisions.
These the oil prepared both for internal use by Dravo Corporation and for studies were clients of Dravo Van Houten.
Industrial Development Economics - Reviewed and evaluated the cargo and projections of regional economic growth used to obtain World forecasts financing for container and bulk handling facilities proposed for the Bank Port of Montevideo, Uruguay.
Analyzed forecasts of projected fish production and fishing fleet development which were used to estimate the f rom agro-industrial facilities proposed for the Port of economic return Conakry, Guinea.
Developed proposals for the fina n c ia l / e c o n omic feasibility of marine engineering projects that ranged in size from limited, privately financed projects to large foreign regional development programs.
1979 - 1980 Senior Economist PRC Harris, Inc.
Consulting Engineers Lake Success, New York Energy and Environme ntal Studies - Projected the demand for low pressure reserves in a rural upstate New York county based on demographic trends gas and economic forecasts of future residential, commercial and industrial growth. Conducted the cost-benefit analysis of erosion protection measures for the U.S. Corps of Engineers project to protect c ommercial and residential developments along the Indian River Inlet in Delaware.
Evaluated existing socioeconomic impact models for use by the Corps of Engineers Passaic River Basin Study Group.
Analyzed the economic benefits of improving the channel to ac commodate larger fishing vessels in the Woodelef t Canal at Freeport, Long Island.
I nd us trial Development Economics - Project Manager for Terminal Construction Corporation's site / financial f ea sibility study for the development of a wholesale food dis tribution center in the Hackensack Meadowlands, New Jersey.
Direc ted regional planning and socioeconomic analysis of growth related to the proposed development of a large-agro-industrial port planned for Damietta, Egypt.
Technical responsibilities'to these studies included the determination of optimal phasing and evaluating the economic return on investment from the proposed projects.
L
{
Professional Experience Continued:
1972 - 1979 Social Economist Energy and Environmental Systems Division Argonne National Laboratory Chicago, Illinois Socioeconomic Impact Assessments _ - Responsible for demographic, economic and s oc iological analyses undertaken as part of a variety of research pro-jects spons o r ed by the U.S. Department of Energy.
These studies examined the socioeconomic impacts of changes in employment, population size and a s sociated with the construction and demographic composition that are operation of large-scale energy projects.
Responsibilities to this research required in-depth experience with regional economic and demographic project techniques, including cxport-base, input-output, and cohort survival me thod s.
The cons t ruc tion of social surveys, use of population sampling methods, multivariate regression techniques and statiseica1 analysis of population composition were also an integral part of this work.
LDC Energy Assessments - Responsible for de f ining the socioeconomic c o mp o nent of Argonne National Laboratory's role in the International Energy Development Program sponsored by the U.S. Department of Energy.
- Detailed, country-specific energy assessments were prepared for a number of countries.
Specific responsibilities to this prog ram included the identification of socioeconomic issues and problems, policy analysis, the development of research methodologies and inte rac tion with foreign representatives.
Familiarity with planned and subsidized economies and experience with the application of econometric models to these situations was gained in the course of this project.
Knowledge of s p e c i fic econometric methods for estimating f uel-spe c ific energy demand as a function of price elasticities was also used in this research.
Environmental Pollution Damages - Participated in a j oint Argonne National Laboratory / University of Chicago, Department of Economics project sponsored by the National Science Foundation (NSF) to analyze relationships between environmental pollution and the regional economy.
Several studies were completed.
These included:
a survey of Chicago coal users to determine the costs of conversion to other fuels, an inventory of building materials to estimate the cos t s of soiling due to air pollu.: ion, and a multivariate regression residuals analysis that displays the geographic dis t ribu tion of relationships between socioeconomic characteristics of the population and air quality in the Chicago SMSA.
Experience developed in the cou-se of these studies included survey construction and sampling, economic cost-benefit analysis, and the use of air quality display models.
Education:
B.S.,
Sociology and Biology, Missouri Valley College, 1967.
M.A.,
Sociology and_ Human Ecology, University of Cincinnati, 1969.
Ph. D., 9uman Ecology and Demography, University of Cincinnati, 1973.
j l
I a-
s k
Publications
- Baldwin, T.E., Outlook for Engineering Services in the Oil and Gas Market; Dravo Van Houten, Consulting Engineers (June 1981).
- Baldwin, T.E., A Qualitative Assessment of Economic Change in Queens County, New York; Citibank, N. A.
(March 1981).
- Baldwin, T.E., and R. Poetsch, An Approach to Assessing Local Sociocultural Impacts Using Projections of Population Growth and Composition, Argonne National Laboratory Report ANL/EES-IM-24 (August 1977).
- Baldwin, T.E., et al., Economic and Demographic Issues Related to Deployment of the Satellite Power System:
A White Paper published by the U.S. Department of Energy.
Baldwin, T.E., et al., A Framework for Detailed Site-Specific Studies of Local Socioeconomic Impacts from Energy Development (December 1976).
- Baldwin, T.E., et al., A Soc ioeconomic Assessment of Energy Development in a Small Rural County:
Coal Gasification in Mercer County, North Dakota, Volumes I and II (August 1976).
Baldwin, T. E., J. C. Bosch, J r., and R.R. Cirillo, Projecting Regional Air Pollution Using Traditional Planning Variables, Proceedings of the APCA Specialty Conference; "Long-Term Maintenance of Clean Air Standards."
(February 3, 1975 ).
Objectives and Decisions:
How Do We Draw the Lines ? Paper presented at the Regional Seminar on Land Use Issues sponsored by the Bi-State Metropolitan Commission, Geneseo, Illinois (January 15, 1975).
- Baldwin, T.E., R.R. Cirillo, S.J. LaBelle, and A. S. Kennedy, Guidelines for Air Quality Maintenance Planning and Analysis; Vol. 13, Allocating Projected Emissions to Subcounty Areas (November 1974).
Community Structure and the Adaptation of Municipal Finance, paper presented at VIII World Congress of the International Sociological Association, Toronto, Ontario (August 26, 1974).
Baldwin, T.E., and A.S. Kennedy, The Feasibility of Predicting Point Source Emissions Using Industrial Land Use Variables:
A Path Analysis, paper presented at annual meetings of APCA, Denver, Colorado (June 10, 1974).
t Kennedy, A. A., et al., Air Pollution / Land Use Planning Project Phase II Final Report:
Vol.1-11, prepared for the Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency.
s f
- Kennedy, A.S., and T.E. Baldwin, Clean Air Through Urban a'nd Regional Planning, proceedings of the Third International Clean Air Congress, Dusseldorff, Germany (October 1973).
Norco, J. E., R. R. Cirillo, T. E. Baldwin, and J.W. Gudenas, An Air Pollution Impact Methodology for Airports and Attendant Land Use, a report prepared for the Office of Air and Water Programs, U.S.
Environmental Protection Agency (January 1973).
C roke.
K.C., A.S. Kennedy, and T.E. Baldwin, Research Problems and Issues in the Application of Land Use Controls to Environmental Protection, proceedings of the Interagency Conference on the Environment, Live r mo re,
California (October 1972).
i O
e JOSEPH H. KELLER PROFESSIONAL QUALIFICATIONS Education:
Bachelor of Science in Chemistry, Washington College, Chestertown, MD, 1956.
Master of Science in Inorganic Chemistry, Pennsylvania State University, University Park, PA, 1958.
Graduate Assistant in Chemistry, Pennsylvania State University, University Park, PA, 1958-61.
Professional Positions:
1961-1966 Assistant Professor of Chemistry at Idaho State University, Pocatello,10. Responsibilities included teaching courses in freshman chemistry, quantative analysis, instrumental analysis, advanced inorganic chemistry and laboratory radiochemistry.
8/66 - 10/73 Employed at the Idaho National Engineering Laboratory in Idaho Falls, ID (then called the National Reactor Testing Station).
The site is government owned and administered by the Department of Energy Research and Development Agency).
I was employed by one of the operating contractors, initially Idaho Nuclear Corp.
followed by Allied Chemical Corp. My position was a technical one in the research and development area of fission product behavior and properties.
I 10/73 - 6/74 Employed as research scientist by Nuclear Environmental Services division of SAI, Inc., Idhao Falls, ID. Responsibilities included contract support on performance gaseous rad waste processing equip-ment in a BWR and analysis of sources of inplant radiation exposure to workers.
6/74 - 12/78 Employed as scientific and engineering supervisor by Allied Chemical Corporation at the Idaho National Engineering Laboratory.
Responsi-bilities included supervision of a research laboratory involved with analysis of fission product levels in irradiated nuclear fuel speci-mens and analysis of the fission product content of samples of the worlds 1st known natural fission reactor and the supervision of an analysis laboratory for environmental samples. Conducted contract research in support'of MRC.
-.m,
-7
.,--,.e y.--v-y
3
. L 12/78 - present Employed as scientist by Allied Chemical Corp., Exxon Nuclear Idaho Co., Inc., (After 7/3/79), and Westinghouse Idaho Nuclear Company, Inc. (af ter 3/1/84), at the Idaho National Engineering Laboratory. Responsibilities include research and development contract support to NRC and FEMA.
Attended FEMA orientation training course on Radiological Emergency Preparedness Planning for DOE Contract Personnel.
Experience:
Proved existence of previously unrecognized airborne radioiodine species to be hypoiodous acid.
I Developed sampling device to differentiate various chemical forms of airborne radioiodine.
Developed inorganic adsorbent to retain airborne radiotodine.
Measured fission product behavior in simulated loss of coolant accident.
Made highly accurate and precise measurement of natural abundance of krypton in the atmosphere.
Measured gaseous fission products in efflu(ats and process streams in 5 BWR's stations.
Performed effluent and environmental measurements to assess iodine-grass-cow-milk dose pathway at BWR's.
Made effluent and environmental measurements of radioiodine at a pharmaceutical plant to assess environmental impact.
Analyzed fuel specimens to determine accurately the fission yields in the fast flux region of the neutron spectrum.
Analyzed fuel specimens to establish breeding or conversion ratio in Th-U fuels from the light water breeder program.
14 3
Developed a sampling device of airborne C and H in nuclear plant effluents and process streams.
Participated in environmental program for iodine milk dose pathway using radioxenon to measure dispersion empirically at 8WR site.
Directed gaseous portion of a program to measure movement of radio-nuclides through process equipment in PWR's so that the predictive models can be evaluated.
t
.. ~ _ _ _ - _.
f Responsible for technical evaluation of commercial BWR off-gas systems.
Evaluated applicability of off-site, real-time instrumentation to determine the magnitude of unmonitored releases in accident i
situations.
Evaluated soil to vegetation transfer of stable cesium and strontium.
Reviewed current state of knowledge or scavenging of the environment airborne radiciodine by rain or snow.
Testified as FEMA witness at Indian Point ASLB hearing.
Adjunct facility member at FEMA Emergency Management Institute.
Publications:
J. H. Keller, F. A. Duce, and F. O. Cartan, " Retention of Iodine on Selected Particulate Filters and a Porous Silver Membrane Being Considered for the LOFT Maypack," IN-078, May 1967 W. J. Maeck, D. T. Pence, and J. H. Keller, "A Highly Efficient Inorganic Adsorber for Airborne Iodine Species (Silver Zeolite Development Studies," IN-1224, October 1968 R. L. Nebeker, J. H. Keller, L. T. Lakey, D. E. Black, W. P. Palica, and R. E. Schindler, " Containment Behavior of Xenon and Iodine Under Simulated Loss-of-Coolant Accident Conditions in the Contamination.
Decontamination Experiment," IN-1394, June 1971 B. Weiss, P. G. Voilleque, J. H. Keller, B. Kahn, H. L. Kgger, A. Martin, and C. R. Phillips, " Detailed Measurements of I in Air, Vegetation, and Milk Around Three Operating Reactor Sites,"
NUREG-75/021, March 1975 W. J. Maeck, W. A. Emel, L. Dickerson, J. E. Delraare, J. H. Keller,
$39. Duce, and R. L. Tromp, " Discrepancies g Comments Regarding A
Pu Thermal Fission Yields and the Use of Nd as a Burnup Monitor," ICP-1092, December 1975
~
N. D. Dyer, E. B. Neischmidt, J. H. Keller, and B. G. Motes,
" Procedures Source Term Measurement Program," TREE-1178, October 1977 N. D. Dyer, J. H. Keller, R. L. Bunting, B. C. Motes, S. T. Croney, i
D. W. Akers, C. V. McIsaac, T. E. Cox, R. L. Kynaston, S. W. Duce, D. R. Underwood, J. W. Tkachyk, "In-Plant Source Tenn Measurements at Ft. Calhoun Station-Unit 1," NUREG/CR-1040, July 1978 J. L. Thompson, S. W. Duce, and J. H. Keller, "An Atmospheric Tritium and Carbon-14 Monitoring System," NUREG/CR-386, September 1978 l
w' 4
N. C. Oper. J. H. Keller. R. L. Suntint. S. C. Metes. 5. T. Croney.
D. W. Akers. C. V. Melsaac. T. E. Cox R. L. Kynaston
- 5. W. Duce, l
D. R. Underused. J. W. Tkachyk. "In-Plant Source Ters Measurements at Zien Station." NURE6/CR-0715. February 1979 J. H. Keller. L. W. McClure. M. Hota. A. L. Ayers. Jr., R. Lo, and L. W. Barrett. "Solling Water Reactor off-gas Systems Evaluation."
NURES/Cr-0727. June 1979 R. W. Benedict.
A. 8. Christensen J. A. Del Deb 610. J. H. Keller, and D. A. Knecht. " Technical and Economic Feasibility of Zeolite Encapsulation for Krypton-86 Storage." ENICO-1011.- September 1979 J. H. Keller. S. G. Metes. D. W. Akers. T. E. Cox. 5. W. Duce, and J. W. Tkachyk " Measurement of Xe-131. C-14 and Tritime in Air and i
l I-131 Vegetation and Milk Around the Quad Cities Nuclear Power i
Stations." NURES/CR-1125. ENICO-1023. Merch 1980 J. W. Mandler. S. T. Croney N. C. Dyer. C. V. Mc!saac. A. C.
Stalker
- 8. C. Notes. J. H. Keller. T. E. Cox. O. W. Akers.
l J. W. Tkachyk. and S. W. Duce "In-Plant Source Tern Measurements at Turkey Point Station - Units 3 and 4." NURES/CR-1629. September 1980 P. G. Voilleque. 8. Kahn H. L. Kreiger. D. M. Montagenery.
g3gnd 8. H. Mss. %aluation of W A1WtationM J. H. Keller I at the Quad Cities Nuclear Power Station."
Pathway for NUREG/Cr-2644. ENIC0-1110. April 1982 L. G. Hoffman and J. H. Keller, " Characterization of Soil to Plant Transfer Coefficients for Stable Cesium and Strontium." NUREG/CR-2495.
ENICO-1105. June 1982 P. G. Vo111eque. L. G. Hoffman, and J. H. Keller, " Wet Deposition Processes for Radio 10 dines." NUREG/CR-2438. ENIC0-1111. August 1982
- 8. J. Salmonson. L. G. Hoffhan. R. J. Honkus. J. H. Keller " Guidance on Offsite Emergency Radiation Measurement Systems - Phase 2 - Milk Pathway." WINC0-1009. April 1984 Papers:
F. O. Cartan, H. R. 8eard. F. A. Duce, and J. H. Keller, " Evidence for the Existence of Hypoidous Acid as a Volatilo Indine Species Produced in Water Air Mixtures at Tenth AEC Air Cleaning Conference, New York. NY. August 1968 J. H. Keller. F. A. Duce. O. T. Ponce, and W. J. Meeck. "Hypoideus Acid: An Airborne Inorganic Iodine Species in Staae-Air Mixtures at Eleventh AEC Air Cleanine Conference. Richland WA. September 1970 J. H. Keller. F. A. Duce, and W. J. Neck. *A Selective Adserbent Sampling for Differentiating Airborne Iodine Species at Eleventh AEC Air Cleanine Conference. Richland. WA. September 1970 J.H. Keller, T.R. Thomas, D.T. Pence, W.J. Maeck, " Iodine Chemistry in Steam Air Atmospheres at-Fifth Annual Health Sg/_eiga Society / Midy/ ear Symptoms, Idah'o Falls, ID, Noveinber
, i J. H. Keller, T. R. Thomas, D. T. Pence, W. J. Maeck, " Iodine Chemistry in Steam Air Atmospheres at Fifth Annual Health Physics Society Midyear Symposium, Idaho Falls, ID, November 1976 J. H. Keller, T. R. Thomas, D. T. Pence, and W. J. Maeck, "An Evaluation of Materials and Techniques Used for Monitoring Air-Borne Radioiodine Species at Twelf th AEC Air Cleaning Conference Oak Ridge, TN, August 1972 J. H. Keller, L. L. Dickerson, F. W. Spratkes, and W. J. Maeck, Deter-mination of the Natural Abundance of. Krypton in the Atmosphere at Am. Chem. Soc. Nuclear Chemistry and Technology Division Meeting, Newport Beach, CA, February 1973 J. H. Keller, " Iodine Species Measurements," invited paper at Nuclear Safety Analysis Center Workshop on Iodine Releases in Reactor Accidents Palo Alto, CA, November 1980 131 P. G. Voilleque and J. H. Keller, " Air-to-Vegetation Transport of g
as Hypoiodous Acid," Health Physics 40, p 91-94.1981 l
(
~
rW Roger B. Fawiseki PRTESSIGEL GRLIFICATICNS l
Mr. Fowieski is Ibger B. 'Nowinski is empicyed at Fl!Nh, Region II, New York.
currently serving as the Chairman of the Regicmal Assistance Camittee, Natural and Technol@=1 Hazards Division, Region II, Federal Dnargency Management A9enCY-Mr. Kowieski holds an MS in Envism. ital Engineering fr m. Wroclaw Polytechnic Institute, Poland and a Professional Engineer License frm the State of New Jersey.
'Ihe witness began to acquire skills in management, planning, and design while l
Fra 1971 to 1973, Mr. Fowieski worked for Iouis working for the private sector.
Berger Associates where he was involved in design of interstate higtssays and water t
l resources projects. In 1973, Mr. Fowieski joined URS Corporation as a Project In this capacity he was responsible for planning, design, and managenent Manager.
of various projects in water resources and envisu ital fields including flood hazard identificaticm shviiae, flood cmtrol, sewege treatment plants for hazardous waste, instrinentation, and Envirorunantal Inpact Statements.
Ihe witness began his Federal services in 1977 with the Federal Insurance Adninis-tration (FIA) in the U.S. Department of Housing and Urban D=-M &t. As an As-i sistant Director for Engineering with FIA (1977-1980), the witness was pr4Miy responsible for the management, administration and inglenantation of all Flood Insurance Studies, dam safety pr%=> activities and other floodplain related ac-tivities in the Region. In this capacity, the witness monitored, supervised, and coordinated the work of approximately 25-30 private engineering consultants and federal agencies ccoducting work in New Jersey, New York, Puerto Rico, and the He also provided technical assistance to State and Tev-al officials Virgin Islands.
on various flood damage mitigation techniques and flood warning metixxis designed to increase the public awareness and to reduce future flood losses.
Appointed by the FIA Administrator to the Task Force caprised of national shpasts in hazard mitigaticn, he assisted the Administrator in analysis evaluation and re-direction of external and internal operaticms of FIA Prcp.
6.
(1978).
In 1978, Mr. Kowieski was also named as Regional Dam Safety Coordinator responsible for the management and swmaful inplementation of the Dam Safety Pshp.-i within the Region. In this position, he was involved in. u. pay acticn planning for dama and reservoirs. This involved the evaluation of emargency planning in the event of dam failure, delineating the inundation areas, and pr=Mng notification and evacuatism plans.
In 1981, Mr. Kowieski also served as Acting DiH&r of the Insurance and Mitigatics Division responsible for the management and planning of all activities related to the NFIP and hazard mitigation.
I With the realignment of the Regional office in November 1981, Mr. Kowieski was naned Acting Chief, Technol@eal Hazards and EnsiMng Stgport Gmp and the Chairman of Regional Assistance (weittee. In this e==e4ty, the witness was l
responsible for managing and adninistrating all of engineering activities pertain-ing to the NFIP, Radiolevyie=1 Bnergency Preparedness Progrens, Daun Safety Progran, and hazardous materials program.
4 L
Boger B. Kawieski (Continuation)
As 1%4==n of the Regional Assistance Cmmittee, the witness dealt with those representatives of the Governce respcmsible fcr the ' REP s@me, the Departnant In this vity, of Health, the la=4=1sture, and emergency services agencies.
he provided a high level of technical amaiatance to State and local gova.m.-its Under his direc-in preparation of plans required to meet federal regulations.
tion and sqm: vision as RAC Chairman, Region II stwN11y empleted a large amount of work with very limited staff, including reviews and exercises for Nine In C+:~2+r 1982, Mile Point, Ginna, Indian Point, Oyster Creek, and Salem.
Mr. Kawieski was prmoted to Project Officer, Natural and Technological Hazards In this capacity the witnass assists the chief of the division in Division.
managing the activities of the division, including Radiological h:ucg cy Plan-He ning Programs, National Flood Insurance Program, and the Dam Safety Prcyram.
also served as the agency's expert witness for the Indian Point Attmic Safety and Licensing Board.
h E
3 l
l Philip McIntire In August of 1982, Philip McIntire was named Chief of the Natural and Technological Hazards Division of the Federal Emergency Management Agency.
In this capacity, he directs the agency's program of evaluating emergency preparedness around nuclear power plants and administers the National Flood Insurance Program in New Jersey, New York, Puerto Rico and the Virgin Islanus. He also manages the agency's earthquake preparedness, hurricane loss reduction and dam safety programs.
Since his appointment, Mr. McIntire has directed FEMA's evaluation of the status of off-site safety around Indian Point and other commercial nuclear reactors in New York and New Jersey.
In this regard, he has been the agency's lead expert witness before the Indian Point Atomic Licensing and Safety Board and has directed the preparation of several reports to the Nuclear Regulatory Commission regarding off-site safety in the Region.
His Federal service began in 1966 as a Management Intern for the Office of Emergency Planning, Washington, D. C.
Assignments in the nation's capital included serving as Staff Assistant to the Director of the Office of Emergency Preparedness for the NATO Committee on the Challenges of Modern Society in the planning and holding of meetings of international disaster experts in Brussels, Rome, Venice and San Francisco. He transferred to the New York Regional Office of the Federal Disaster Assistance Admini-stration in 1972.
Mr. McIntire has an MBA degree, with a major in Management, from the City University of New York. He also received a BA degree from Bowdoin College, Brunswick, Maine, with a Government major.
He also completed the Civil Service Commission's "Meninar for Advancing Managers", and was a principal author of " Disaster Preparedness Report to Congress". Throughout his Federal career, Mr. McIntire has received numerous awards and citations.
4
w LILCO Transition Plan for Shorcham - Revision 3 j
Key to Consolidated RAC Review Dated February 10, 1984 The Regional Assistance Committee (RAC) review of the LILCO Transition Plan for Shoreham (Attachment I) is based upon planning criteria specified in NUREG-0654, FEMA-REP-1, Rev. 1; Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of, Nuclear Power Plants, November, 1980.
The plan has been evaluated against i
each planning element specified in NUREG-0654 applicable to State and/or i
Local jurisdictions.
These evaluations are keyed to the following rating system:
ADEQUATE RATING A (Adequate)
A* (Adequate - concerns pertaining to LER0's legal authority identi-fied during this review)
The element is adequately ad-The element is adequately addressed dressed in the plan. Recommen-in the plan provided concerns per-dations for improvement shown in taining to LERO's legal authority bold type are not mandatory, but are resolved. The issues of legal their consideration would further authority affecting these elements improve the LERO plan. These are more fully described in Attach-recommendations include revisions ment 2.
to the NUREG-0654 cross-referen-ce, and other minor improvements.
Recommendations for improvement (not) related to legal concerns) shown in In some cases, however, particu-bold type are not mandatory, but lar elements have been rated their consideration would further cdequate provided the necessary improve the LERO plan. These recom-revisions are made to maintain mendations include revisions to the the adequate rating. These NUREG-0654 cross-reference, and recommended modifications are other minor improvements.
a explained for each such element in the RAC review.
In some cases, however, particular elements have been rated adequate provided the necessary revisions (not related to legal concerns) are made to maintain the adequate rating.
l INADEQUATE RATING l
l 1 (Inadequate)
I* (Inadequate - Concerns pertaining to LER0's legal authority identified during this review) l.
The element is inadequately The element is inadequately addressed in addressed in the plan for the the plan for the reason (s) (not related reason (s) stated in bold type.
to legal concerns) stated in bold type.
The plan and/or procedures The plan and/or procedures must be must be revised before the revised before the element can be consi-element can be considered dered adequate.
adequate.
In addition, concerns pertaining to LERO's legal authority were identified by the RAC, and are more fully described in Attachment 2.
s L-.
LILCO Transition Plon for Shorchem - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 1
of 60 NUREG-0654 Element Review Comment (s)
Rating A.
Assignment of Responsibility (Organization Control)
A.l.a The lead role for response activities I*
belongs to the utility, LILCO.
The plan establishes the Local Emergency Respo,nse Organization (LERO) developed by the utility and comprised of federal, utility and private organizations.
Suffolk County is not participating in offsite emergency planning for Shoreham (see Chapter 1, Section 1.1, page 1.1-1 of the plan which references Resolution 1196-83, adopted February 17, 1983 by Suffolk County Legislature),
and New York State has not implemented actions (see Chapter 1, Section 1.4, page 1.4-1. of the plan) relative to their authority.
The New York State Response, should it decide to respond, is not discussed in the 1981 plan as stated (see page 1.4-2, lines 28-29).
Therefore, the plan does not address what support New York State will provide in a radiological emergency in Suffolk County when LILCO's resources are exhausted.
If New York State is likely to respond, provision for interface with the LERO decision process should be included.
- See footnote at the end of comments for element A.l.a which are continued on page 2.
l l
l
LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 2
of 60 NU REG- 06 5 4 Element Review Comment (s )
Rating A.l.a The plan should also address federal Cont.
agencies (other than DOE, FAA and USCG) in terms of their role in response.
The U.S. Department of Agriculture, FDA, EPA and NRC may be involved in an accident.
The NRC will assign a liaison to the local EOC as well, and will require at least two commercial telephone lines and at least two telephone instruments.
- This element is inadequately addressed in the plan.
In addition, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2,
Legal Concerns for details).
A.1.b.
The operational role of LERO is defined I
in sections 1.4, 2.1 and 3.0.
Bowever, the concept of operations and relationship of each organization to the total emergency response effort is vague.
Specifically, the relationship of all organ-izations/ positions (e.g.,
hospitals, ambulance personnel, facilities to be used as relocation centers, outside consultants and federal agencies such as FAA, EPA and USDA) to LERO and the implied lines of responsibilities should be described in the concept of operations (sections 2 and/or 3).
Local Law Enforcement and Fire Departments are listed ao Support Organizations with primary responsibility, yet on page 2.2-4 there is no clear statement that these organizations will participate.
The role of Suffolk County, should it elect to respond, should be specifically detailed as in Procedure OPIP 3.6.3 (Traffic Control) page 8.
I
3 s
e LILCO Transition P10.n for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 3
of 60 NUREG-0654 Element Review Comment (s)
Rating A.l.c The organizational components of LERO are I
illustrated in Figure 2.2.1.
The block diagram assumes that New_ York State and Suffolk County will communicate with LERO.
Figure 2.1.2 shows the LERO Radiation Health Coordinator as having primary responsibility for accident assessment, while Figure 2.1.1, page 2 shows this position as being filled by "other personnel."
The discussion on page 2.1-3 line 36 implies that this position is a LERO function..2.1, page 2, lines 24-25 states that DOE will perform accident assessment.
From the language on page-2.1-1, it appears that the Radiation Health Coordinator is provided by DOE /BHO, but this is not confirmed by the LERO chart (Figure 2.1.2) under Bealth Services Coordinator.
Clarification should be provided in the plan as to the role of the "outside consultant (s)" in performing the accident assessment function.
Figure 2.2.1 should be revised to depict missing agencies (e.
in a clearer mar.ner.
g.,
- EPA, USDA)
. e s.
LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 4
of 60 NUREG-0654 Element Review Comment (s)
Ratinq A.l.d Specific individuals who shall be in A*
charge of the emergency response are identified by title under Chapter 2, organization (pages 2.1 2.1-8).
Again, LILCO personnel are the majority of LERO staff, along with DOE-RAP per-sonnel from the Brookhaven Area Office (BHO).
The plan is adequate in addressing this element provided that the specific individual (s) who will perform the responsibilities of the Radiation Health Coordinator is identified by title and affiliation.
- This element is adequately addressed in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details).
A.l.e The lead Communicator (see A
page 2.1-7) has responsibility for i
ensuring that all communicator positions in the local EOC are manned on a continuous basis once facility is activated.
Also, Chapter 3, Section 3.4, pages 3.4 3.4-5 stipulates that the Radiological Emergency Communications ( RECS ) line between the Plant and LERO, and LILCO Notifica-tion Radio System are monitored 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
e s
LILCO Transition Plnn for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 5
of 60 NUREG-0654 Element Review Comment (s )
Rating A.2.a The functions and responsibilities for I*
major elements and key individuals by title, of emergency response, 4
are specified in the plan for the following:
Command and Control, Alerting and Notification, Communications, Public Information, Accident Assessment, Public Health and Sanitation, Social Services,
Fire and Rescue, Traffic Control, Emergency Medical Services, Law Enforcement and Transportation.
However, the responsibility for
" Protective Response," required by NUREG-0654, has not been defined in the text, nor is it listed in Figure 2.1.2.
The NUREG cross-reference should be revised to include as a citation for element A.2.a, Figure 3.5.2 which specifies
" protective response" responsibilities.
Section 2.1 does not distinguish between primary and support responsibilities for the response organizations.
The dis-tinction between primary and support responsibilities should be clearly stated in the text that describes the responsibilities for each of the various response organizations.
In addition, some clarification should be made to Figure 2.1.2 to show a single primary responsibility for each function.
Primary responsibilities are identified for more than one agency for the following functions in Figure 2.1.2:
Public Information and Notification l
e e
Accident Assessment Medical and Public Bealth e
e Traffic Control
- See footnote at the end of comments for element A.2.a which are continued on page 6.
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 6
of 60 NU REG- 065 4 Element Review Comment (s)
Rating A.2.a Lead agency responsibilities should be Cont.
specified for functions where more than one agency has primary responsibility.
Lead, primary and support responsibilities for each agency should be specified in the
" position definitions" in Procedure OPIP 2.1.1. This cross-reference to Figure 2.1.2 could assist the emergency response coordinators in using the plan and procedures.
Figure 3.3.7 assigns primary responsibility for alerting the general public to the LERO-Director of Response.
The LERO-Coordinator of Public Information is responsible for providing public information.
These same LERO support functions (i.e.,
Alert General Public and Inform Public with EBS Broadcasts) refer to FEMA.
This must be clarified, since FEMA has no responsibility for notifying the public during a radio-logical emergency.
- This element is inadequately addressed in the plan.
In addition, concerns per-taining to LERO's legal authority to implement the plan werd identified by the RAC during this review (see Attachment 2, Legal Concerns for details ).
I
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 7
of 60 NUREG-0654 Element Review Comment (s)
Rating A.2.b.4.1 refers to legal authority under I*
10 CFR 50.47 (c)(1) which provides as follows:
Failure to meet the standards set i
forth in paragraph (b) of this sub-section** may result in the Commission declining to issue an Operating License; however, the applicant will have an opportunity to demonstrate i
to the satisfaction of the Commission that deficiencies in the plans are not significant for the plant in question, that adequate interim compensating actions have been or wil] be taken promptly, or that there are other compelling reasons to permit plant operation.
I The cited authorities (Section 1.4 of the I
LILCO Transition Plan relate to the l
authorities of the NRC to license a plant under various degrees of emergency preparedness and compensation, rather than the police-type actions.
i I
The utility has developed LERO, comprised of utility, Federal, and private individuals.
If New York State and Suffolk County im-i plement an emergency plan, LERO would, follow their lead (see Section 1.4, pages 1.4 l 1.4-2; also, Attachments 1.4.1 and 1.4.2).
I
- This element is inadequately addressed in the plan.
In addition, concerns per-taining to LERO's legal-authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details).
- Standards A-P specified in criteria defined in NUREG-0654; FEMA-REP-1 Rev. 1.
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear j
Power Plants - For Interim Use and Comment" January 1980.
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LILCO Transition Plan for Shornhem - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 8
of 60 NU REG- 065 4 Element Review Comment (s)
Rating A.3 Appendix B contains letters of agreement for the I*
following support oi Janizations identified in section 2.2 of the plan.
Signed Dated e DOE /Brookhaven National Lab Yes Yes e WBLI radio Yes Yes e WCTO radio Yes Yes e WGSM radio Yes Yes e U.S.
Coast Guard Yes Yes e New York Telephone Yes Yes e Marketing Evaluations, Inc.
Yes Yes e WALK radio No Yes e American Red Cross No No The plan states that:
"It is anticipated that all local law enforcement agencies and fire departments within the ten mile EPZ will continue to carry out their normal response functions during an emergency.
Should the incident escalate to the point of requiring these agencies to evacuate from the local area, it is further anticipated that these agencies will take their own compensating measures, based upon the situation at hand, and continue to render the necessary services in response to the situation."
The plan also states that:
"It is Enticipated that snow removal operations within the ten mile EPZ will be provided by local organizations in their normal fashion during an emergency."
However, no letters with Suffolk County or local agencies responsible for law enforcement, fire response or snow removal could be located in the plan.
No reference to public laws requiring local agencies and services to respond could be found using the NUREG cross-reference.
The " Local Public Service Agencies" and
" Local Emergency Medical Services Agencies" listed in Figure 2.1.2 should be specified.
- See footnote at the end of comments for element A.3 which are continued through page 10.
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 9
of 60 NU REG- 0654 Element Review Comment (s)
Rating A.3 Letters of intent from bus and ambulance Cont.
suppliers are included in Appendix B for the following resources:
e Bus companies - (1559/? vehicles #)
e Ambulance companies - (224/? vehicles it)
Bowever, these letters of intent do not commit the bus and ambulance companies to supply equipment to LERO in the event of a radiological emergency at the Shoreham site, because contracts have not as yet been finalized with the bus or ambulance suppliers.
The contract revisions requested by several of the ambulance companies could limit the number of ambulances and ambuletts that will be available.
The LERO Transportation Support Coordinator is responsible for driver support.
The LILCO plan states that the utility will provide trained licensed LILCO employees as a major 4'
source of bus drivers (Appendix A, III-36).
The plan should specify the number of drivers that have been trained and licensed to respond to a radiological emergency at SNPS.
The letter of agreement from DOE on page APP-B-1 does not specify the degree of response to be provided.
Shoreham's requirement is closer to that of a
" compensating measure" rather than radio-logical assistance, as is stated in the letter.
DOE's role, in this case, is that of the offsite response agency, providing independent dose assessment capabilities.
This is not clearly stated in the generic letter from DOE which limits DOE's role to
"... advice and emergency action essential for the control of the immediate hazards to health and safety."
1 I
- Includes buses, vans, coaches, flexetts, etc.
if Includes ambulances, ambuletts, etc.
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LILCO Transition Plan for Shornhnm - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 10 of 60 NUREG-0654 Element Review Comment (s)
Rating A.3 Letters of agreement could not be located for Cont.
the following support organizations / persons or Representative Outside Agencies (see Procedure OPIP 2.1.1, page 12) identified in the plan.
e Stony Brook Hospital e Central Suffolk Bospital e SUNY Stony Brook e BOCES Central Islip e SCCC Selden e Local law enforcement agencies e Local fire departments e Local snow removal organizations e Federal Aviation Administration e Laboratories which provide environmental sample analysis e Radiological Health Coordinator (outside consultant) e Relocation center coordinator e Nursing support e Counselling coordinator Letters of agreement with support organ-izations which provide laboratory and en-vironmental sample analysis could not be located in the plan.
The resources LERO expects to use to support the federal responses which are identified in Attachment 3.11.1 should be supported by letters of agreement from those organizations.fff
- This element is inadequately addressed in the plan.
In addition, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2,
Legal Concerns for details ).
fifLetter of intent with Coram Bus Service is included in Appendix B, pages APP-B-30 and 30A.
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 11 of 60 i
i NUREG-0654 Element Review Comment (s)
Rating A.4 The LERO Director of Local Response is A
responsible for ensuring the continuity of emergency resources for 24-hour operations over a protracted period.
The establishment and maintenance of LERO over a protracted period is described in Section 2.1, page 2.1-1, line 26-29; page 2.1.2, lines 36-39 and Procedure OPIP 2.1.1.
,Tbn NUREG-0654 cross-reference should be re-vised to include Procedure OPIP 2.1.1 as a citation for element A.4.
C.
Emergency Response Support and Resources C.l.a According to the plan, the LERO Director A*
of Local Response requests the Governor to ask the President to declare an emergency or disaster.
Section 3.11, page 3.11-1 of the plan provides that if this request is granted, federal assistance would be administered by the Federal Radiological Preparedness Coordination Committee (FRPCC).
The above statement in Section 3.11, page 3.11-1 of the plan
- referring to the Federal Radiological Preparedness Coordination Committee is incorrect, and should be deleted.
The plan should state that the federal response to a radiological emergency would be coordinated by the Federal Emergency Management Agency in accordance with the Federal Radiological Emergency Response Plan.
The NUREG-0654 cross-reference should be revised to include Attachment 2.2.1 (page 2 of 17, line 27) which states that "BBO is notified by LILCO customer services."
i
- This element is adequately addressed in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan'were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details ).
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 12 of 60 NUREG-0654 Element Review Comment (s)
Rating C.l.b The DOE-RAP is specified to provide A
radiological monitoring assistance and expected times for arrival are provided.
The plan is adequate in addressing this element provided that specific resources and expected times of arrival are identified for the U.S. Coast Guard (see section 2.2, page 2.2-2).
Any additional federal resources, including expected times of arrival to be furnished through the FRERP (see Section 3.11, page 3.11-1) or other arrangements, should also be specified (e.g.,
EPA, NRC, USDA).
C.l.c The LILCO transition plan identifies I
resources that are available to support the federal response.
LERO has not specified what resources have been identified by federal agencies to support their effort (e.g.,
air fields, command posts, telephone lines, radio frequencies and telecommunications centers).
For example, the EPA response teams will also require:
airfield for landing military e
aircraft (C-130) four independent stationary electrical e
outlets (110/120 volts 0 30 amperes AC) source of liquid nitrogen e
e office, lab and storage space.
LILCO Transition Plc.n for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 13 of 60 NU REG -065 4 Element Review Comment (s)
Rating C.2.a LERO representatives are already at the A
SNPS site and may be dispatched to the near-site Emergency Operations Facility (EOF).
C.3 Page 3.5-2 of the plan identifies two ORS A
teams from DOE-RAP for monitoring services and several other organizations for analyses.
C.4 Written letters of agreement are incomplete.
I*
Letters of Agreement were not found in Appendix B for all organizations listed in Sections 2.2, 3.5 and Attachment 3.11.1 of the plan (also see analysis comments for element A.3).
- This element is inadequately addressed in the plan.
In addition, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details ),
i
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LILCO_ Transition Plan for Shorehem - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 14 of 60 NUREG-0654
' Element Review Comment (s)
Rating D.
Emergency Classification System D.3 The Emergency Classification System, A
desc'ribed in Chapter 3, Section 3.2, page 3.2-1 conforms with the system set forth in Appendix 1 of NUREG-0654; FEMA-REP-1, Rev. 1.
D.'4 The emergency action procedures to be A
taken are adequately described in Chapter 3,
Concept of Operations and the Implementing Procedures.OPIP 1.1.1 through 5.4.1.
E.-
Notification Methods and Procedures E.1 The' notification and mobilization of A
emergency response organizations including the verification of messages is outlined in Section.3.3, page 3.3-1 and Procedures OPIP 3.2.2, 3.3.3 and 3.3.4.
The LILCO Customer Services Office in the Hicksville Operations Center is the primary LERO notification point.
Figures 3.3.2 through 3.3.4 do not include a list of persons / groups / organizations to be notified forfmobilization at general emergency.
These notification procedures are the same as for Site Area Emergency.
The plan is adequate in addressing this element provided that the notification list of persons / groups / organizations to be notified at general amergency is added to the plan.
s
4 LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 15 of 60 NUREG-0654 Element Review Comment (s)
Rating E.2 The necessary procedures for alerting, A
notifying, and mobilizing emergency response personnel are found in pro-cedure OPIP 3.3.2.
Section 3.4, page 3.4-5 which describes the LILCO paging system, and Figure 3.4.1 should be added to the NUREG-0654 cross-reference.
E.5 The plan establishes a system for A*
disseminating appropriate information contained in initial and follow-up messages received from the licensee, including the appropriate notification to the broadcast media.
The notification system described through-out the plan is termed the Emergency Broadcast System (EBS).
Bowever, this system, which is a network of Long Island radio stations, with WALK as the entry station, is not the official Emergency Broadcast System (EBS) for Long Island.
The official Emergency Broadcast System, is authorized by the Federal Communications Commission, for use by government officials to previde information to the general public.
For clarity, the system developed by LERO should use different nomenclature to distinguish it from the FCC sanctioned EBS system.
The plan is adequate in addra msing this element provided that this issue is clarified in the plan.
l
- Thii hiement is adequately addressed l
in the plan.
However, concerns per-l taining to LERO's legal authority to l
implement the plan were identified by the RAC'during this review (see Attach-ment 2, Legal Concerns for details ).
LILCO Transition Plan for Shorchem - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 16 of 60 NUREG-0654 Element Review Comment (s)
Rating E.6 The prompt notification system consists A*
of 89 fixed sirens, tone activated radios provided to special facilities, (i.e.,
schools, hospitals, medical support hospitals, handicapped facilities ambulance companies, nursing homes, and major employers, etc.), EBS, and a mobile public address system.
Marketing Evaluations Incorporated will verify that each siren has activated (see page APP-B-53).
The plan adequately covers the need to demonstrate, under NUREG criteria, that there are means to notify the public.
- This element is adequately addressed in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details).
E.7 The draft messages intended for the public A
found in Procedure OPIP 3.8.2 satisfy NUREG-0654 requirements.
Procedure OPIP 3.8.2 includes the following draft messages:
e EBS Activation Advisory e Alert (release of radiation)
De-escalation of Emergency e
e Termination of Emergency Test Message for EBS e
e Spurious Activation Message of Prompt Notification Sirens e Description of Emergency Planning Zones for Suffolk County (to be included in EBS messages).
LILCO Transition Plan for Shorchem - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 17 of 60 NUREG-0634 Element Review Comment (s)
Rating i
E.7 The plan details how press conferences Cont.
will be conducted.
Based on FEMA's exercise experience, it is helpful to have emergency information bulletins available for use by decision-makers, the press, rumor control, and other PIOS.
Radio emergency information bulletins contained in the plan include dosage information.
Such information should be presented in less technical language in order to maximize the general publics' understanding of this information.
In addition, sample messages should include, as appropriate, information for farmers, food distributers, food processing facilities, etc.
F.
Emergency Communications F.1.a Provision for 24-hour activation of the LERO A
emergency response network is accomplished via the RECS line in the LILCO Customer Service Office in the Hicksville Operations Center (see Section 2.1, page 2.1-7 and Section 3.4, pages 3.4-1 to 3.4-5).
This RECS line is monitored on a 24-hour basis and the LERO officer at the Customer Service Office is responsible for activating the paging system which notifies key emergency response personnel that an actual incident has occurred.
l The LILCO Notification Radio System
}
serves as the backup communication system I
to the RECS for communications between the Shoreham Control Room and the LILCO Customer' Service Office.
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LILCO Transition Plan for Shorehnm - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 18 of 60 NUREG-0654 Element Review Comment (s)
Rating F.1.b Section 3.4 E (page 3.4-4) provides for A
communications from LERO to Suffolk County, i
Nassau County, New York State, and Connecticut via commercial telephone and centrex.
The plan should provide for communication with the State of Rhode Island which is affected by the 50-mile EPZ.
The plan is adequate in addressing this element provided that arrangements are established for communications with Rhode Island.
The NUREG cross-reference should be revised to include section 3.4 page 3.4-4 as a citation for element F.1.b.
F.1.c The plan provides for notification of the I
following federal emergency response organiza-tions:
e FEMA e
DOE response team o
U.S. Coast Guard (USCG) e Federal Aviation Administration (FAA)
However, the plan does not provide for direct notification by LERO of o..ser federal e.mergency response organizations in the event that direct support is to be requested from those organizations.
In addition to DOE, USCG, and FAA, communications with other Federal support agencies should be arranged, i.e.,
NRC, FDA, EPA, etc.
F.1.d Communication between the local EOC in A
Brentwood, New York and the licensees EOF (or TSC) is maintained via the following means (see Figure 3.4.1):
e RECS line commercial telephone e
e radio
LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 19 of 60 NUREG-0654 Element Review Comment (s)
Rating F.1.d The RECS line will allow 24-hour per day Cont.
notification l
between the plant and LERO.
Communication with the radiological field monitoring teams is maintained via radio link.
F.1.e The provisions for alerting and activating A
emergency response personnel in each response organization as described in Section 3.3, pages 3.3-1-4; Figures 3.3.2, 3.3.3 and 3.3.4 and Procedure OPIP 3.3.2 are adequate.
A list of persons / groups / organizations to be notified for mobilization at general emergency should also be included in the plan (see also comment for element E.1).
The plan is adequate in addressing this element provided that the notification list for persons / groups /
organizations to be mobilized at general emergency is added to the plan.
F.2 Communications with fixed and mobile medical support facilities are specified A
in the plan as follows:
Means e Ambulance dispatch stations commercial telephone and radio e Ambulance drivers radio link via dispatch station 3
e Hcspitals commercial telephone and i
radio links via ambulance dispatch sta-tions and mobile ambulance units.
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l LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 f
Page 20 of 60 NUREG-0654 Element Review Comment (s)
Rating i
F.3 Communication drills will be conducted A*
by LILCO (see Section 5.2, Part A, page
),
5.2-2a).
Communications will be tested i
monthly; while communications between the plant, the local EOC, and field monitoring teams will be tested annually.
Also, see page 3.4-7.
1 According to the cross-reference submitted with the plan, the frequency of siren tests as suggested in Appendix 3 i
of NUREG-0654; FEMA-REP-1, Rev. 1 is specified in the LILCO Nuclear Operations Support Department Procedures.
Those procedures should be submitted to FEMA for review in order to assure that the required siren tests will be performed in accordance with NUREG-0654, Appendix 3, i
page 3-12, Section h (2), Siren Testing Guidance, Oversight.
This element is adequate provided that the LILCO Nuclear Operations Support Department Procedures contain the required frequency of siren tests.
- This element is adequately addressed in the plan.
However, concerns per-i i
taining to LERO's legal authority to j
implement the plan were-identified by
)'
the RAC during this review (see Attach-ment 2, Legal Concerns for details).
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I LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review l
Dated February 10, 1984 l
Page 21 of 60 NUREG-0654 Element Review Comment (s)
Rating G.
Public Education and Information l
G.l.a-d Section 3.8, pages 3.8-1-3 of the plan A
provides for the dissemination of brochures to the public which include the information required by NUREG-0654.
The information to be provided will include:
e educational information on radiation e
contact for additional information 1
e protective measures e
survey card on special needs of the j
handicapped.
Educational brochures will be mailed to 1'
all households and commercial establish-ments.
LILCO plans to use their billing lists for the mailing.
In addition, inserts will be developed for the Suffolk telephone directory which will include the following:
Map of 10 mile EPZ/ emergency e
planning zone.
e List of EBS stations.
Siren system description / purpose.
e s
Protective actions the public may be e
advised to take (sheltering, evacuation).
o Relocation center locations, e
Items to take along for an evacuation.
Local telephone directories'will also i
contain the above items.
In addition, these local directories will contain maps showing evacuation routes.
Brochures will be updated on an annual basis, and an annual orientation of news media will be reinforced during annual exercises.
The public education brochure refers to 1
the Emergency Broadcast System (EBS).
This nomenclature should be changed to differentiate the LERO system from the FCC sanctioned EBS system (see comment for element E.5).
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LILCO Transition PIRn for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 l
Page 22 of 60 i
NUREG-0654 Element Review Comment (s)
Rating l
G.2 The public information program and pro-
.A visions for its dissemination as described in Section 3.8 of the plan are adequate.
1 G.3.a The emergency news center (ENC) is to be A*
established in the Quality Inn, Old Mill in Ronkonkoma, New York.
This facility will be set up as the central clearing house for the release of information received from the utility and LERO representatives (see Section I
3.8, page 3.8-4).
The plan provides that
" private and public agency /or organization representatives (i.e.,
American Red Cross, j
Suffolk County, FEMA, NRC, State of ficials, etc.) will be invited to participate as a panel in all news conferences."
1 The NUREG-0654 cross-reference should be revised to include page 3.8-1 as a citation for element j
G.3.a.
i
- This element is adequately addressed I
in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan were identified by i
the RAC during this review (see Attach-I ment 2, Legal Concerns for details).
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G.4.a The LERO Coordinator of Public Information A
(CPI) and LILCO's Emergency News Manager at the ENC is the designated spokesperson(s) for LERO.
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1 LILCO Transition Plan for Shorehrm - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 23 of 60 NUREG-0654 Element Review Comment (s)
Ratinq G.4.b LERO Public Information Personnel at the ENC A
are charged with the responsibility "to provide accurate information (to the media) on a timely basis. "
G.4.c The ENC is designated as the central location A
for rumor control.
The rumor control point is for the use of utility personnel at the LILCO Customer Relations District Offices and the l
LILCO Customer Call Boards, in answering i
questions asked by the public.
The rumor control point will be staffed by representa-tives from LERO and the u.tility.
The plan does not provide information about rumor.ontrol staffing, the number of rumor control telephone lines that will be available and staffed, and how current information will be provided to the rumor control staff.
It is recommended that the rumor control staff 4
i be provided with press releases and radio emergency information bulletins to assure i
that they are apprised of the current emergency i
- status, i
i G.5 LERO will coordinate an annual orientation A
program for the news media.
This program will familiarize the media with the following:
Utility emergency plans, e
e Radiation information, Points of contact for release of public i
e information in the event of an emergency, and o
The location and operation of the ENC.
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 24 of 60 4
NU REG- 065 4 Element Review Comment (s)
Rating H.
Emergency Facilities and Equipment H.3 The local EOC to be operated and staffed by A
l LERO personnel is located at the LILCO 2
Operations Facility in Brentwood, Long Island, New York.
H.4 The activation and staffing of the local EOC A*
by LERO personnel is specified in Section 3.3, 1
page 3.3-1; Section 4.1 page 4.1-1 and Procedure OPIP 4.1.1 of the plan.
i The plan is adequate in addressing j
this element, provided that the modifications and clarifications outlined i
below are incorporated in the plan.
The Radiation Health Coordinator should be included on the emergency call checklists in Procedure OPIP 3.3.2.
l Per analysis comment E.1 and F.1.e, Figure i
3.3.4 does not include a list of persons /
groups / organizations to be notified for mobilization at general emergency.
1 The plan and Procedure OPIP 4.1.1 appear to be contradictory.
It is not necessary 3
to delay notifications to the EOF and'New
+
York State until full activation of the local EOC is' completed (as stated in Section 4.1.A of the plan).
Procedure i
OPIP 4.1.1, Section 5.2 indicates that the Director of Local Response will make i
these notifications upon arrival at the local EOC, Section 4.1.A of the plan should be changed to agree with the implementing procedure, j
The NUREG-0654 cross-reference should be revised i
to include Procedure OPIP 4.1.1 as a citation for element H.4.
i
- This element is adequately addressed in the plan.
However, concerns per-taining to LERO's legal ~ authority to implement the plan were identified by the RAC during this review (see Attach-l ment 2, Legal Concerns for details).
.- ~..
i LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 25 of 60 NUREG-0654 Element Review Comment (s)
Rating H.7 The two (2) Offsite Radiological Survey (ORS )
A teams, each consisting of two (2) individuals per team from DOE-RAP are provided in the plan. These teams will obtain their ORS kits at Brookhaven National Laboratory (BNL).
Equipment is shown for the two ORS teams on 4.4-1, while the plan states on page 3.5-2, page line 22 that additional teams from LILCO will be available, if needed.
It is unclear whether the LILCO ORS support teams will be using radiological survey kits from DOE, or whether this equipment is LILCO's property.
If these kits belong to LILCO, the plan is adequate.
If, however, these kits are not LILCO property (i.e., BNL/ DOE property), the plan should specify:
(1) where the ORS kits for the LILCO support teams are to be maintained, (2) how LILCO personnel are to be deployed, and (3) how LILCO instrumentation compares to DOE's.
The plan is adequate in addressing this element provided that clarification of ownership and responsibility for maintenance of the ORS kits are specified.
The equipment lists on page 4.4-1 and Attachment 2.2.1 are different.
The plan should specify who is responsible for supplying the equipment on page 4.4-1.
The NOREG-0654 cross-reference should be revised to include Procedure OPIP 3.5.1 (see Section 5.2.1) as a citation for element H.7.
LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 26 of 60 NUREG-0654 Element Review Comment (s)
Rating H.10 Section 5.3 of the plan provides that A
LILCO will inspect, inventory and operationally check emergency response equipment at least once each calendar quarter. Calibration of instruments will be done at intervals recommended by manu facturers.
The plan also makes provision for reserve equipment.
Survey meters compatible with the GM1 probes should be included on the equipment list.
The availability of backup equipment for the additional field monitoring teams from LILCO should also be specified in the plan.
H.ll A detailed list of equipment to be used in A
the emergency response by LERO is located in the portions of the plan listed in the NUREG cross-reference.
The plan is adequate provided that the modifications outlined below are incorporated in the plan.
The equipment list on page 4.4-1 includes only one air sampler.
The plan should state whether back-up samplers are available at the staging area.
It should be taken into consideration that radiciodine sampling capability is lost in the event of pump failure.
How does the list on page 4.4-1 relate to the list in Procedure OPIP 5.3.1, which includes multiple air samplers?
- Also, are there radiation meters to go with the GM detectors listed in Procedure OPIP a
5.3.1 as available at the local EOC?
Communications equipment on page 4.1-4 should include radio links between the field teams and EOC.
i
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LILCO Tronaition Plen for Sharchem - Rnvision 3 Consolidated RAC Review Dated February 10, 1984 Page 27 of 60 NU REG- 065 4 Element Review Comment (s)
Rating H.ll The NUREG-0654 cross-reference should be
- Cont, revised to include Procedure OPIP 3.5.1 as a citation for element B.ll.
H.12 Page 3.5-2 of the plan states that field A
data will be radioed back to the Environ-mental Survey Function and all samples will be returned to the local EOC, or as directed, for laboratory analysis by DOE-RAP or SNPS labs.
I.
Accident Assessment I.7 The capability and resources for field A
monitoring within the plume exposure EPZ are to be provided through the DOE-RAP resources at the Brookhaven Area Office.
The capabilities, mobilization, response time, and equipment for these resources are provided in the FRMAP plan for the support of local emergency response plans.
Procedure OPIP 3.5.1 and the equipment list in Attachment 2.2.1 of the plan do not coincide.
The plan is adequate in addressing this element provided that these two lists are reconciled.
Procedure OPIP 3.5.1, page 7 should describe what provisions are available to return sample media for laboratory verification on an expedited basis, particularly, samples which yield l
positive results in the field.
l
LILCO Trnnaition Plnn for Shornham - Ravinien 3 Consolidated RAC Review Dated February 10, 1984 Page 28 of 60 NUREG-0654 Element Review Comment (s)
Rating I.8 The capabilities, equipment and expertise for I
accident and dose capabilities are found in Procedure OPIP 3.5.2.
Field team composi-tion, communication, monitoring equipment and estimated deployment times are found in Section 3.5 and Procedure OPIP 3.5.1.
Page 3.5-2 of the plan gives field team composition.
Pages 3.1-2 and 4.1-2 of the plan specify that the LERO Director of Local Response, with the Radiation Health Coordinator, is responsible for formulating the protective action decisions.
The plan does not specify whether LERO has accident assessment personnel who can weigh the plant's status from an operational view in developing protective action recommendations.
The choice of protective actions is apparently keyed almost entirely to radiation dose or projected dose.
Consideration should be given to the plant's status including; prognosis for stabilizing, improving or worsening situations, or timing of releases so that preventive evacuation prior-to a release is not overlooked when such releases may be imminent.
The plan does not specify how protective action decisions would be made in the absence of an actual release.
The plan should specify that protective actions such as sheltering, and especially evacuation, could be implemented prior to initiation of significant releases, if possible.
The NUREG-0654 cross-reference should be revised to include the following citations for element I.8:
Section 2.1, Figure 2.1.1, page 2 of 4 e
e Section 2.2, Attachment 2.2.1 Section 4.4, page 4.4-3 (means of e
transportation for field teams).
_ _ _ _ _ _ _ _ _ _ = _ _ _. _
i LILCO Trnnaition Plnn for Shorchem - Ravision 3 Consolidated RAC Review i
Dated February 10, 1984 Page 29 of 60,
i NUREG-0654 Element Review Comment (s)
Rating I.9 Section 2.2, Attachment 2.2.1 states I
that the DOE Brookhaven Area Office can provide support to LILCO for airborne radioiodine sampling and analysis to concentrations as low as 5X10E-08.
While the equipment listed is potentially capable of making the required measurements, j
the methodology shown in Procedure OPIP 3.5.1 (see Section 5.3.7b) would not give accurate results for most accident con-ditions.
Even without core damage, 3
j radiolodine may be collected on the l
particulate filter if the iodine is j
in elemental form.
Therefore, one cannot rule out activity on the particulate filter l
as not being iodine.
Also, the nomogram which relat s iodine to total fission products j
for the calculation of thyroid dose (OPIP 3.5.2, Att. 11) may not be realistic in this aspect.
Furthermore, the amount of 4
fission products collected from a core damage I
accident are highly dependent on a number i
of parameters, such as moisture in containment, filtration of release, distance from the site, etc., and are not easily amenable to the l
nomogram assumptions.
i The heading of attachments 5 and 6 Procedure OPIP 3.5.2 should be changed
]
to read " Multiply results by 10E-6."
l r
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1 1
LILCO Trenaition Plan for Shorchem - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 30 of 60 NUREG-0654 Element Review Comment (s)
Rating I.10 The procedures for estimating integrated I
dose from the projected and actual dose rates (plume exposure) were found in Procedure OPIP 3.5.2.
Ingestion pathway dose estimations were found in Procedure OPIP 3.5.3.
Procedure OPIP 3.6.1 contains protective action recommendations.
Procedure OPIP 3.5.2 is lacking several nomograms which are required for the calculations.
The plan should include provisions for the consideration of plant parameters regarding types of releases.
Reliance on the stated 0.05 m/sec. deposition velocity is applicable under a limited set of atmospheric conditions, and should not be relied upon as LERO's only means of ingestion pathway zone protective action decisions.
Field surveys with HP210 detectors can quickly determine j
ground deposition.
The NUREG-0654 cross-reference should be revised to also include Procedure OPIP 3.6.1 as a citation for element I.10.
I.11 Capabilities to locate and track the plume A
1 (field monitoring) are to be provided through the DOE-RAP resources at the Brookhaven Area Office.
The capabilities, mobilization, response time, and equipment for these resources are provided in the FRMAP plan for the support of local emergency response plans (see Attachment 2.2.1 of the plan).
Procedure OPIP 3.5.1 Section 5.3 should be included in the NUREG-0654 cross-reference submitted with the plan since it discusses the plume tracking method to be used by the ORS teams.
I
LILCO Trnnnition Plnn for Shormhnm - Ravinien 3 Consolidated RAC Review Dated February 10, 1984 Page 31 of 60 NUREG-0654 Element Review Comment (s)
Ratinq J.
Protective Response J.2 The provisions for evacuation of SNPS non-I essential site personnel in Section 3.6 (page 3.6-8) describe only the route to be taken if a public evacuation is in progress (i.e.,
high traffic density).
There is no discussion of alternative routes that are to be used for inclement weather and specific radiological conditions.
The plan should include a discussion of transportation to be used by SNPS site personnel.
J.9.
EPA's plume exposure and FDA's ingestion I
pathway PAG's are listed in Section 3.6.
There is no discussion of how protective actions would be implemented based on plant conditions prior to actual releases (see comment for element I.8).
- Also, Tables 3.6.2 and 3 6.3 are taken from the FDA draft report, and are not the final values.
The NUREG-0654 cross-reference should be revised to include Table 3.6.1 as a cita-tion for element J.9.
J.10.a The Evacuation Plan (Appendix A Section I -
A*
Preface pages I-l to I-2 ) is made up of two plans -- a study performed by Suffolk County as part of an agreement with LILCO (9/21/81), and a study performed I
by KLD Associates under an agreement with LILCO to develop an evacuation plan (12/30/81),
LILCO has integrated the two studies into Appendix A.
- See footnote at the end of comments for element J.10.a which are continued on i
page 32.
LILCO Trnnsition Plnn fer Shornham - Ravisinn 3 Consolidated RAC Review Dated February 10, 1984 Page 32 of 60 NUREG- 065 4 Element Review Comment (s)
Rating J.10.a The maps showing evacuation routes, evacuation Cont.
areas, preselected offsite radiological monitoring locations (including Table 3. 5.1 and Procedure OPIP 3.5.1 listing designators for these locations) and shelter areas are included in the plan.
Although the relocation centers are indicated on Figure 9, Zone A, they are not specifically identified as relocation centers.
The legend should be revised to include symbols designating relocation centers on this map, since it is indexed on the NUREG cross-reference.
The NUREG-0654 cross-reference should be revised to include Attachment 11 of Procedure OPIP 3.5.1 as a citation for element J.10.a.
- This element is adequately addressed in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details).
J.10.b The map in Figure 3 of Appendix A does not I
show subarea boundaries for evacuation areas F (F1-F5) or K (Kl-KS). 'If it is planned that evacuation can be effected by subarea, then these subarcas should be delineated in accord with the seasonal population data for 1980 and 1985 in Table III of Appendix A.
Table III, Page III-2 of Appendix A, reflects population distribution by ERPA.
Population numbers should be stated for each ERPA.
A map (s) showing population distribution has not been included in the plan.
l LILCO Trnnaition Plon for Shorahrm - Ravision 3 Consolidated RAC Review Dated February 10, 1984 Page 33 of 60 i
NUREG-0654 Element Review Comment (s )
Rating i
i J.10.c The means for notifying the transient and A*
resident population consists of fixed sirens (89 units) and EBS.
The NUREG-0654 cross-reference should be revised to include Procedure OPIP 3.3.4, Section 5.4 (notification of the deaf) as a citation for element J.10.c.
- Thic element is adequately addressed in the plan.
However, concerns per-taining to LERO's legal authority to t
implement the plan were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details).
J.10.d The procedure and inventory of requirements A
for protecting institutionalized mobility-impaired persons has been completed.
However, the procedures and resources to deal with non-institutionalized mobility impaired persons still require completion (i.e.,
the directory of non-institutionalized mobility-impaired persons needs to be completed).
The directory to be compiled for noninstitu-tional mobility impaired individuals should include the number of such persons at a given address and a designator indicating each person's impairment (e.g.,
ambulatory, non-ambulatory, sight impaired, hearing impaired, wheel chair, etc.).
This information is needed to insure that the means of notification is appropriate and to facilitate the coordination of equipment to be used in relocating these persons, if necessary.
It is understood that this directory is being updated based i
on completed survey cards on special needs of the handicapped that are being returned to LILCO.
The plan is adequate in addressing this element provided that the directory of noninstitutionalized mobility impaired individuals has been completed.
t
LILCO Transition Plan for Sherahem - Ravinion 3 Consolidated RAC Review Dated February 10, 1984 q
Page 34 of 60 NUREG-0654 Element Review Comment (s)
Rating J.10.e The provisions for use of KI for emergency I
workers are discussed.
However, there is concern with the method by which KI will be distributed.
Procedure OPIP 3.6.2 states i
that distribution will be accomplished by directing emergency workers to a distribution location.
This may require recalling emergency workers from the field and a time delay in administering KI to them.
The offsite field monitoring teams have KI 4
i in their kits.
Another concern relates to expiration dates on the KI.
Procedure OPIP 3.6.2 states that no KI should be issued if it is beyond its indicated shelf life.
'j At the present time, there is no KI available which is not beyond the labeled expiration date, however, FDA has granted extensions for its use.
The procedures should reflect FDA extensions, i
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LILCO Trnnnition P1nn for Shornhem - Rnvisien 3 Consolidated RAC Review Dated February 10, 1984 Page 35 of 60 NUREG- 065 4 Element Review Comment (s)
Rating J.10.f Page 3.6-3, lines 22-24 of the plan state A*
that the PAG for use of KI as a thyroid blocking agent is a projected dose of 10 rem to an emergency worker's thyroid.
No provision is made for the general i
population which is consistent with New York State policy (see letter from J.L.
Smith to Harold R.
Denton, N.R.C.
S.N.R.C-539 Attachment 1, page 4-J-10c clarification).
The 10 rem PAG is considerably lower than the FDA Final Recommendation of 25 rem or greater projected thyroid dose.
It would appear that LILCO has taken the more conservative lower limit of NCRP Report No. 55 (10-30 rem) or the original FDA draft recommendation (10-20 rem).
The EPA PAG for emergency workers is 25 rem thyroid (see Chapter 3, Section 3. 6, C.,
page 3.6-5, lines 6-7).
The plan states that only those
]
emergency workers who have been pre-i viously screened for its use will be l
given KI (see page 3.6-5, lines 5-8).
A discussion of how this screening will be accomplished could not be located in the plan.
The plan is adequate in addressing this element provided that the procedures for screening emergency workers who would be given KI are included in the plan.
- This element is adequately addressed in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details ).
LILCO Trnnnitien Pirn for Sh7rnhem - R7visien 3 Consolidated RAC Review Dated February 10, 1984 Page 36 of 60 NUREG-0654 Element Review Comment (s)
Rating J.10.g The plan does reflect resources for school A
or general evacuation including the number of buses to be used.
The letters of intent arranging for bus resources have been included in the plan.
However, these letters of intent indicate that contracts establishing the terms under which bus companies will pro-vide their equipment in the event of a radiological emergency at SNPS have not been finalized.
Therefore, the actual commitment of these resources is uncertain.
The notification call up list for transportation personnel has not been completed (Procedure OPIP 3.3.2 - 163 pages).
The plan is adequate in addressing this element provided that contracts are successfully negotiated with the bus companies providing their vehicles, and the notification call up list for transportation personnel has been completed.
The NUREG-0654 cross-reference should also be revised to include Procedures OPIP 3.6.4 and 3.6.5 as citations for element J.10.g.
LILCO Trnnaition Plan for Shorahrm - Rnvision 3 Consolidated RAC Review Dated February 10, 1984 Page 37 of 60 NU REG- 065 4 Element Review Comment (s)
Rating J.10.h Suffolk County Community College, BOCES I
in Islip, and SUNY in Stony Brook are the primary relocation centers.
Two back-up centers (SUNY - Farmingdale, St. Joseph's College - Patchogue) have been identified.
All of these centers would be set up and run by the American Red Cross.
There is no legend on Figure 9, Zone A (page IV-76, Appendix A) defining the designators for SUNY, SCCC and BOCES as relocation centers.
- Bowever, it has been estimated that only the BOCES relocation center is at least five miles beyond the 10-mile EPZ.
The following table of estimated distances of relocation centers beyond the boundaries of the plume exposure EPZ has been derived from the map and scale on Figure 9 of Appendix A.
1 5 mi beyond 1 10 mi beyond 10 mile EPZ 10 mile EPZ e SUNY in Stony Brook Not able to be No determined e Suffolk Community No No College e BOCES yes Not able to be determined The NUREG-0654 cross-reference should be revised to include Procedure OPIP 3.7.1 as a citation for element J.10.h.
J.10.1 The projected traffic capacities of evacua-A tion routes under emergency conditions are shown in Appendix A,Section III, Table IV, pages III-17-33.
The necessary studies have been completed, and adequately satisfy NUREG-0654 requirements.
}
LILCO Transition Plan for Shorehnm - Rsvision 3 Consolidated RAC Review Dated February 10, 1984 Page 38 of 60 i
NUREG-0654 Element Review Comment (s)
Rating 1
J.10.j The plan and procedures call for contact-A*
ing the Coast Guard and FAA and requesting i
cooperation of these agencies for assistance I
(i.e., clearance of boats from Long Island Sound, j
clearance of aircraft, etc.).
The LERO Traf-
)
fic Control Coordinator is responsible for i
coordinating the road logistic aspects for an evacuation and coordinating the maintenance of traffic control points for an i
evacuation.
The locations of approximately
{
147 traffic control posts are specified in Appendix A,Section IV, Figure 8, pages IV-52-81.
i Provisions for access control, to limit access to evacuated areas, is contained in Appendix A,Section IV, Evacuation i
Procedures.
i
- This element is adequately addressed I
in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details ).
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LILCO Tranaition Plan for Shorchem - Ravinien 3 Consolidated RAC Review Dated February 10, 1984 Page 39 of 60 NOREG-0654 Element Review Comment (s)
Rating J.ld.k The means for dealing with potential impedi-I*
ments to evacuation are addressed in Section 3.6, page 3.6-6 of the plan and Appendix A, page IV-5.
Provisions for the removal of cars by tow trucks is adequate.
According to page 2.2-4 of the plan, it is anticipated that snow removal will be pro-vided by local organizations in their normal fashion during an emergency.
During severe snow or an ice storm, the plan recommends selective or general sheltering until the hazard is mitigated.
It is suggested that pre-emergency planning for snow removal on the evacuation routes be further developed to include administrative procedures, SOPS, etc.
These procedures are recommended to insure that the snow removal strategy would coincide with any evacuation scheme that might be chosen.
The NUREG cross-reference should list Procedure OPIP 3.6.3 as a citation for element J.10.k.
- This element is inadequately addressed in the plan.
In addition, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details).
1
)
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LILCO Tranaition Plcn for Shorchem - Rovinion 3 Consolidated RAC Review Dated February 10,.334 Page 40 of 60 NU REG -06 5 4 Element Review Comment (s )
Rating J.10.1 The presentation of time estimates for A
evacuation of various sectors in Appendix A, Table XV, page V-8 conforms with the preferred format for presenting the data and results for the following types of evacuation:
Conditions Normal Adverse Permanent population x
x Transient population x
x General population x
x Special population x
x T'.e table as presented is adequate.
As recommended in Appendix 4 of NUREG-0654, the time for confirmation of evacuation should be estimated and included in Table XV of Appendix A.
J.10.m According to page 3.1-2 and page 4.1-2, the -
I LERO Director of Local Response, in conjunction with the Radiation Health Coordinator, formulate the protective action decisions.
The plan does not specify whether LERO has accident assessment personnel who can weigh the plant's status from an operational view in developing protective action recom-mendations (see comment I.8).
Nor are the off-site conditions (non-radiological) specifically addressed, in that the Evacuation Coordinator, who should have information re-garding any off-site constraints to protective actions, is not involved in the decisions.
The NUREG-0654 cross-reference should be i
revised to include Procedure OPIP 3.6.1 as a citation for element J.10.m.
l 1
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 41 of 60 NUREG-0654 Element Review Comment (s)
Rating J.ll Section 3.6, page 3.6-8 of the plan states I
that control of the ingestion exposure path-way EPZ will be directed by the LERO Health Services Coordinator.
Procedure OPIP 3.6.6 contains ingestion pathway procedures, PAGs, and agricultural resource information such as listings of dairy farms, processing plants, duck growers, hog farms, vegetable and fruit growers, potato processing plants in New York and processing plants, dairy farms in Connecticut.
The I
inclusion of Rhode Island within the 50-mile EPZ should be reevaluated, since Rhode Island was included in a previous revision (see comment for criteria element F.1.b).
The plan is not specific for imposing pro-tective procedures such as impoundment de-contamination, processing, decay, product diversion, and preservation.
There are no maps referenced for recording survey and monitoring data, key land use data, dairies, food proce'ssing plants, water sheds, etc.
If LILCO has access to the State maps, this should be referenced in the plan.
There are also no lists of food processing facilities located outside the 50 mile EPZ, which process food originating within i
the 50 mile EPZ.
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LILCO Transition Plan for Shoreham - Revision 3 Consolida ced RAC Review Dated February 10, 1984 Page 42 of 60 NOREG-0654 Element Review Commentie),
Rating J.12 Using the cross-referenced sections I
for this element, the number of decontamination kits available, and their place of storage at each location could not be located in the plan.
Based on a review of the equipment inventory listed in the plan, it is questionable whether the number of potential relocatees could be monitored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Neither Section 5.5 of Procedure OPIP 4.2.1, page 3 of 14, nor Section 5.0 of i
Proceduro OPIP 3.9.2 describe the means for evacuee registration prior to monitoring.
The procedures should describe i
clearly understood measures which, to the greatest extent practicable, minimize the likelihood for potentially contaminated persons to gain access to a relocation center where evacuees are to be housed, fed and cared for.
f Although Procedure OPIP 3.9.2 adequately covers the monitoring and decontamination of evacuees, more information is needed on the Red Cross responsibilities and procedures at the centers.
d There are no registration forms (other than exposure) supplied with the plan.
There should be procedures for completing registration forms for non-contaminated individuals.
The procedures should also specify where evacuee monitoring records i
will ultimately be maintained.
Also, the available equipment shown for monitoring evacuees may not be sufficient to meet the 12-hour time limit within which all evacuees arriving at relocation centers must~be nonitored.
0 I
1
LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 43 of 60 NUREG-0654 Element Review Comment (s)
Rating J.12 The NUREG-0654 cross-reference should be revised Cont.
to include Procedure 4.2.1 as a citation for element J.12.
K.
Radiological Exposure Control K.3.a Page 3.9-2 of the plan states that all I
emergency response personnel will be issued self-reading pocket dosimeters and TLD's.
The LERO Dosimetry Coordinator is responsible for maintaining exposure control records on a 24-hour per day basis.
The plan states (page 3.9-2, line 8) that all emergency response personnel will be issued dosimeter chargers, yet the inventory lists in OPIP 5.3.1 show that insufficient numbers of chargers are available.
- Also, page 4.4-1, line 39, states that dosimeter chargers will be kept at each emergency worker staging area and wherever emergency workers receive dosimetry equipment.
This is inconsistent with the statement that all emergency response personnel will be issued dosimeter chargers.
The plan should, clarify whether dosimeter chargers will be issued to each ' emergency worker, or whether dosimeters will be zeroed and distributed at the emergency worker staging areas.
It is recommended that emergency workers should not be issued dosimeter chargers because it is possible that they could recharge their dosimeters in the field, thereby obviating the purpose of these instruments in recording cumulative exposure.
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LILCO Trnneition Plan for Shorchem - Revinion 3 Consolidated RAC Review Dated February 10, 1984 Page 44 of 60 NUREG-0654 Element Review Comment (s)
Rating K.3.b Page 3.9-2 of the plan states that A
emergency workers inside affected areas are instructed to take dosimeter readings at 15 minute intervals.
Emergency Worker Daily Dose and Permanent Dose Record forms are contained in Section 3.9 and also in Procedure OPIP 3.9.1.
Section 3.9.A, page 3.9-3 of the plan states that emergency worker dose records will be maintained at the local EOC.
K.4 The LILCO Transition Plan (Rev. 3) provides A
for emergency workers to be trained to in-form their immediate supervisor if the reading on their low range dosimeter goes beyond the 200 mR that it will register.
Dages 3.9-2 and 3 of the plan state that cne Director of Local Response, as advised by the Radiation Health Coordinator, is responsible for authorizing exposures in excess of the EPA General Public PAGs.
Page 3.9-3 lines 18-19 give an exposure guideline for hands and forearms of 200 R for lifesaving activities.
This should be omitted, since such exposures apply to on-site rather than offsite environmental exposures.
N g
LILCO Trancition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 45 of 60 NUREG-0654 Element Review Comment (s)
Rating K.5.a Tables 3.9.1 and 3.9.2 specify action I
levels for determining the need for decontamination.
While Table 3.9.1 gives maximum acceptable contamination Icuels, there are several concerns with this table.
" Probe shield open" readings in mr/hr have no value due to differences in beta energy and the efficiency of the probe.
For all open window readings, CPM should be used, rather than mr/hr.
The listings in Table 3.9.1 for skin, hair, clothing and vehicles are reasonable.
However, the data in Procedure OPIP 3.9.2 do not correspond to these values.
The threshold for decontamination in Table 3.9.1, and the values for release shown in Table 3.9.2 do not agree. Table 3.9.2 gives the NRC surface contamination levels for decommissioning nuclear power plants, which are too low for practical application under emergency conditions.
t
LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 46 of 60 NUREG-0654 Element Review Comment (s)
Rating K.5.b Page 3.9-4, line 45 and page 4.3-2, line 5 I
of the plan and Procedure OPIP 3.9.2 (Section 5.8.1-C) state that any emergency worker with thyroid contamination resulting in readings in excess of.13 mR or 150 CPM, will be sent to a designated hospital for further medical treatment.
Page 4.3-2 uses.13 mR/hr. as the lower limit.
Procedure OPIP 3.9.2 has been changed to 120 CPM in Revision 3.
The correct number should be identified and used consistently.
The BP 270 probe identified in Procedure OPIP 3.9.2, Section 5.5.la is unable to detect alpha activity.
The decontamination techniques described in Procedure OPIP 3.9.2 are adequate.
- However, radiological decontamination equipment, supplies, and storage and disposal capability for contaminated waste associated with the de-contamination process could not be located in.the plan or procedures.
Monitoring equipment including lists of supplies used for decontamination at the decontamination centers should be itemized, as well as quantities available.
No indication of first aid administration or available kits could be found in the plan or procedures.
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LILCO Transition Plan for Shorchnm - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 47 of 60 NUREG-0654 1
Element Review Comment (s)
Rating L.
Medical and Public Health Support L.1 The plan (pages 2. 2-2 and 3. 7-2 ) identifies I
University Hospital in Stony Brook, New York and Central Suffolk Hospital in West Islip, New York as having the capability for handling injured, contaminated patients.
The capability / expertise of medical facilities and personnel at Stony Brook Bospital and Central Suffolk Bospital that will be used to evaluate radiation uptakes and exposures should be described.
No indication that personnel from these hospitals are pre-pared to handle contaminated individuals could be found in the plan.
L.3 Procedure OPIP 4.2.2 contains a list of I
hospitals capable of treating contaminated injured individuals; however, the listing does not include their capacity and any special radiological capabilities.
Procedure OPIP 4.2.2, although referenced in the NUREG cross-reference, is not referenced in section 3.7, Medical and Public Health Support of the plan.
Pro-cedure OPIP 4.2.2 should be referred to in Section 3.7, to ensure that the LERO Bealth Services coordinator and staff are aware of these additional resources in the event they are needed.
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 48 of 60 NUREG-0654 Element Review Comment (s)
Rating L.4 Page 3. 7-1 of the plan states that A
the LERO Ambulance Coordinator will coordinate the services of trained emergency medical technicians, ambulances and rescue vehicles.
The plan is adequate in addressing this element provided that the list of ambulance companies with which LERO has letters of intent supported by finalized contracts will be contained in Procedure OPIP 4.2.2 The NUREG-0654 cross-reference should be revised to include Procedure OPIP 4.2.2 as a citation for element L.4.
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 49 of 60 l NU REG- 065 4 Element Review Comment (s)
Rating M.
Recovery and Reentry Planning and Postaccident Operations M.1 Section 3.10, pages 3.10-1 and 2 I
and Section 3.11, pages 3.11-1 and 2 of the plan and Procedure OPIP 3.10.1 discuss Re-entry and Recovery.
Procedure OPIP 3.10.1 provides for participation of the following agencies / organizations on the Recovery Action Committee if they are available:
FEMA representative e
DOE representative e
e S ta te representative County representative e
l.10.1 and Section 3.10 (Recovery /Re-entry) give no consideration to plant conditions, such as the probability of additional significant releases, con-tinuing or intermittent low level releases, etc..10.1 refers to acceptable levels for unrestricted release of property during a decommissioning of a facility (per Reg-Guide 1.86) and are not related to recovery from an emergency.
Procedure OPIP 3.10.1 notes that the plant must be stable, no significant releases occurring, etc. as precautions for entering Recovery.
However, there is no indication of who de-termines whether these conditions have been satisfied.
Consequently, Recovery /Re-entry Procedures 3.10.1 are based upon incomplete considerations.
An evacuation is not necessarily a prerequisite for recovery.
Due to time constraints, sheltering may have to be implemented rather than evacuation.
It should be indicated in Section 3.11 that post-emergency phase activities are a responsibility of EPA as per the FRMAP.
LILCO Transition Plan for Shorehnm - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 50 of 60 NUREG-0654 Element Review Comment (s)
Rating M.3 The LERO Director of Local Response is re-A sponsible for instri. ting all Recovery Action Committee coordinators to notify members of the response organization when recovery operations have been initiated (see Procedure OPIP 3.10.1, Sections 5.3.4 and 5.3.6).
M.4 The referenced section of the plan I
provides for the completion of radiation field surveys to determine whether contamination levels in an evacuated area are within accept-able limits for reentry of the public into formerly contaminated areas.
No " method" for estimating total population
. exposure could be found on page 3.10-2 of the plan which is cross-referenced for this element.
The plan should establish a method for estimating total population exposure, not merely state that an organization will be established for this purpose.
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 L
Page 51 of 60 NUREG-0654 Element Review Comment (s)
Rating N.
Exercises and Drills 1
N.l.a The referenced section of the plan A*
describes the purpose, scope, frequency and procedures for. exercises.
The plan states that an exercise shall simulate an emergency that results in offsite radiological releases which would require the overall emergency response capabilities of SNPS, FEMA and LERO.
The following revisions should also be made to portions of the plan dealing with exercises:
Accident Assessment and Evaluation, e
and Emergency Response Facilities, should be added to the list on page 5.2-3, B,
lines 22-36, of capabilities to be tested in exercises.
e FEMA should be deleted from line 15 on page 5.2-3 since FEMA does not test its response capability in every exercise.
- This element is adequately addressed in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details ).
N.l.b The plan contains no provision for the A*
mobilization of State and local personnel and resources in order to verify responses during exercises.
However, 'he plan does establish the means for mobilizing LERO personnel and resources that would be adequate to verify the capability to respond to an accident scenario requiring response.
- This element is adequately addressed in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details ).
LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Deted February 10, 1984 Page 52 of 60 NURIG-0654 Element Review Comment (s)
Rating N.2.a The plan adequately addresses the A
testing of communications systems with the following:
Federal emergency response e
organizations and states within the ingestion pathway -
quarterly, The nuclear facility (SNPS) -
o
- annually, o
The State and local (LERO) EOCs
- annually e
Local (LERO) radiological monitoring team - annually The plan provides for drills of communication with the state and local EOCs.
The NUREG-0654 cross-reference should be revised to include Procedure OPIP 3.4.1 as a citation for element N.2.a.
N.2.c Page 5.2-2a of the plan and Procedure A
5.1.1, Section 5.2.2.1.c adequately provide for a Medical Drill to be conducted annually in conjunction with the annual exercise.
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 53 of 60 NUREG- 0654 Element Review Comment (s)
Rating N.2.d The referenced section of the plan A
provides for radiological monitoring drills.
i The plan is adequate in addressing this element provided that it is clarified in the plan whether DOE-RAP personnel will participate in the radiological monitoring exercises.
This clarification is requested since the letter of agreement between DOE and LILCO limits DOE radiological assistance to " advice and emergency action essential for the control of immediate hazards to health and safety" (i.e.,
in an actual emergency) - see Appendix B, page APP-B-1.
N.2.e.(1) Page 5.2-2 of the plan and Procedure OPIP A
5.1.1, Section 5.2.2.1.d. adequately provide for health physics drills to j
be conducted semi-annually.
N.3.a-f The referenced section of the plan A
adequately provides for exercise scenarios to include the following:
The basic objectives; e
e The date(s), time period, place (s) and participating organizations; The simulated events; e
e A time schedule for real and simulated initiating events; A narrative summary describing the e
conduct of exercises or drills; Arrangements for scenario material to be e
provided to official observers..
Provisions for, and the use of, protective clothing should be added to Section 5.2 page 5.2-1, line 12.
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LILCO Transition Plan for Shornhnm - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 54 of 60 NUREG-0654 Element Review Comment (s)
Rating N.4 Section 5.2, pages 5.2-1 and 5.2-4, A
lines 4-6, 14 and 15 of the plan establishes that the LILCO Emergency Planning Coordinator (EPC) is responsible for conducting exercises that will be critiqued by observers from Federal, State and local governments.
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N.5 Procedure OPIP 5.l.1, Sections 5.2.6 and A
5.2.7 adequately provide for LERO to evaluate observer and participant comments and implement corrective actions.
The LILCO Emergency Planning Coordinator is responsible for incorporating plan changes indicated as a result of the drills and annual exercise critiques.
Procedure OPIP 5.1.1, Section 5.2.6.5 makes the following provision:
"The EPC (Emergency Planning Coordinator) shall collect and evaluate all exercise / drill records including checklists, logs, LERO Observation Sheets, survey reports, etc. from LERO, federal, state, and local obscrvers and keep them on file."
(Emphasis added)
This provision is beyond the scope of FEMA's policy on the Availability of Records under the Freedom of Information Act Relating to State and Local Radiological Emergency Plans and Preparedness Program per the June 30, 1983 memorandum for Regional Directors from James L.
- Holton, Director, Office of Public Affairs, and George Jett, General Counsel which states:
l LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 55 of 60 NUREG-0654 Element Review Comment (s)
Rating N.5 The critiques of individual members of Cont.
the Regional Assistance Committee (RAC) evaluating the effectiveness of a Radiological Emergency Preparedness exercise qualify for withholding under the Freedom of Information Act pursuant to 5 U.S.C.
552(b)(5).
According to policy guidance from the Department of Justice, the purpose of the (b)(5) exemption is to assure:
presidents, agency heads, and other decisionmakers that they can safely i
welcome a full spectrum of candid expressions from their staffs and/or peers, because they will be free to accept or reject all such input on its apparent intrinsic. merit, not on whether a particular staff memorandum may make the official's action look better or worse, especially if the action is controversial or later proves unsuccessful....
Federal Observers should be deleted from Section 5.2.6.5 of Procedure OPIP 5.1.1.
However, the statement should be added to Procedure OPIP 5.1.1 to read that Federal comments for the exercise are provided by FEMA in the post-exercise assessment which summarizes the evaluation of the Federal Observers.
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v LILCO Transition Plan for Shorehrm - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 56 of 60 NUREG-0654 Element Review Comment (s)
Rating O.
Radiological Emergency Response Training 0.1 Section 5.1, pages 5.1-3 through 5.1-5 A
of the plan and the LERO Training Matrix (Figure 5.1.1) provide emergency response training for LERO personnel through a training program consisting of 21 modules.
Radiological emergency response training is included.
Also, tapping the Federal sector, LILCO would avail itself of approximately 12 courses, some given by FEMA, some by NRC, and some by EPA.
The Red Cross would also be utilized, providing six training courses.
Procedure OPIP 5.1.1, Section 5.1.5 provides that the records maintained by L1LCO will show the names and emergency position of individuals trained, the instructor's name, and the dates on which they received training.
O.l.b Procedure OPIP 5.1.1, Section 5.1.3 I
states that Emergency Response Training will be offered to all members of LERO support organizations, such as the U.S. Coast Guard and ambulance personnel.
Since there are no mutual aid agreements with local police and fire-organizations, the procedure does not offer training for these personnel.
This training should be offered to "all local law enforcement agencies and fire departments within the 10-mile EPZ," which are anticipated to carry out their normal emergency response functions during a radiological emergency at SNPS.
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LILCO Transition Plan for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 57 of 60 NUREG-0654 Element Review Comment (s)
Rating 0.4 The referenced section of the plan establishes a training program for emergency response personnel which is keyed to specific emergency response training topics.
The following subelements of this planning criteria have been reviewed as follows:
0.4.a Directors or coordinators who A
are LILCO employees.
- However, clarification is needed between the plan and LERO Training Matrix on identification and content of Module 15.
0.4.b No provision has been included I
for training of Radiological Health Managers, nor for anyone in LERO, to evaluate the implication of plant conditions in protective action recommendations.
0.4.c Radiological monitoring teams and A
radiological analysis personnel 0.4.d Police, security and fire fighting I
personnel are to be filled by personnel with whom LILCO/LERO does not have a mutual aid agreement supported by a letter of agreement.
0.4.f First aid and rescue personnel A
0.4 9 Local support services personnel A
0.4.h Medical support personnel A
0.4.j Personnel responsible for transmission A
of emergency information and instructions.
0.5 Except as noted above for specific functions, A
Chapter 5, Section 5.1 of the plan, Training, states that LILCO will provide for periodic retraining on at least an annual basis for personnel with emergency response responsibilities.
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LILCO Traneition Plan for Shorchem - Revizion 3 Consolidated RAC Review Dated February 10, 1984 Page 58 of 60 NUREG-0654 Element Review Comment (s)
Rating P.
Responsibility for the Planning Effort P' 1 The referenced section of the plan and A*
1 implementing procedures provide for the training of LERO personnel who are responsible for the planning effort.
P.2 The LILCO Emergency Planning Coordinator (EPC)
A*
is responsible for the administration of the LILCO Transition Plan (all revisions).
P.3 The LILCO EPC is responsible for conducting an A*
annual review and update of the LILCO Transition Plan including procedures and letters of agree-ment.
P.4 The LILCO EPC is responsible for incorporating A*
plan and procedure changes resulting from exercises and assigning the responsibility for implementing corrective actions.
As noted above, various agreements necessary to implement the LILCO Transition Plan are not included at this time.
The plan is adequate in addressing this element provided that the agreements necessary to implement the LILCO Transition Plan are included in the plan and updated annually.
- These elements are adequately addressed in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details),
t I
LILCO Transition Plnn for Shoreham - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 59 of 60 NUREG-0654 Element Review Comment (s)
Rating P.5 The LILCO EPC is responsible for distributing A*
the LILCO Transition Plan and approved changes to the organizations and appropriate individuals responsible for their implementation.
Pages for revisions 1, 2 and 3 do not carry revision dates.
Effective revision dates should be added to all pages as they are changed.
P.6 Section 1.4, pages 1.4-1 and 1.4-2, A
and attachment 1.4.2, contain the required list of supporting documents.
P.7 Appendix C to the plan lists by title, A
the procedures required to implement the plan.
References to the following procedures could not be located in the narrative sections of the plan.
e 1.1.1 Offsite Preparedness Implementing Procedure Development e
3.6.4 Bus Routes e
3.6.5 Special Evacuations e
3.7.1 Public Bealth Support e
4.1.2 EOC Documentation and Record Keeping e
4.2.1 Relocation Center Operations
- This element is adequately addressed in the plan.
However, concerns per-taining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attach-ment 2, Legal Concerns for details).
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LILCO Transition Plan for Shorehrm - Revision 3 Consolidated RAC Review Dated February 10, 1984 Page 60 of 60 NUREG-0654 Element Review Comment (s)
Rating P.8 The plan contains a specific Table of I
Contents, and is cross-referenced to NUREG-0654 criteria.
However, the cross-reference should be revised to include the citations that are not indexed as noted in the above comments.
Also, the applicability of the following references to the NUREG-0654 criteria elements listed below should be clarified, or these references should be deleted from the NUREG-0654 cross-reference submitted with the plan.
NUREG-0G54 Element Reference Cited in Plan C.2.a section 3.11 - attachment 3.11.1 J.10.h Appendix A - Fig. 9 Zone A J.10.j Procedure OPIP 3.3.2 P.10.
Section 5.4, page 5.4-2 of the plan A
states that the telephone number lists will be updated on a quarterly basis, and more frequently, if necessary.
- Also, Procedure OPIP 5. 4-1, Section 5.4.4 calls for telephone numbers in emergency procedures to be updated quarterly.
ATTACHMENT 2 CONCERNS PERTAINING TO LERO'S IBGAL AUIHORITY IDIETIFIED DURING RAC REVIfM OF LIICO TRANSITIN PIAN POR SHOREHAM - REVISIm 3 4
February 10, 1984 Belos, are the legal concerns identified during the RAC review of the LILOO Transition Plan for Shoreham - Revision 3.
For easy reference, each NUREG-0654 element affected by the legal concern (s) is restated, followed by the RAC comments.
A.1.a. Each plan shall identify the States, local, Federal and private sector organizations (including utilties), that are intended to be part of the overall response organization for Emergency Planning Zones. (See Appendix 5).
With neither State nor local support or participation in the emergency planning process, the following legal authority concerns have been identified:
command and control responsibilities coordination with local and State authorities including law enforcement agencies and fire departments coordination with contiguous State and local governments LERO's ability to seek a declaration of a State of emergency and to request State and Federal assistance arrangements for agreements with emergency response organizations and/or individuals responsibility for alerting and notification of the public A.1.d. Each organization shall identify a specific individual by title who shall be in charge of the emergency response.
The plan assigns responsibility for " protecting the health and safety of residents and transients within the Emergency Planning Zones (EPZs) defined in this plan" (page 2.1-1, lines 37-41), to the LERO Director of Tocal Response.
At this time, LERO Director of Incal Response has the responsibility for " decision making and strategic controls",
and responsibility to " decide upn the major responses to be made" (see page 3.1-1, lines 15-17). The concern is whether or not LERO has the authority to implement decisions that are made.
A.2.a. Each organization shall specify the functions and responsibilities for major elements and key individuals by title, of emergency response, including the following: Commarx! and Control, Alerting and Notification, Comunications, Public Information, Accident Assessment, Public Health and Sanitation, Social Services, Fire and Rescue, Traffic Control, Emergency Medical Services, Law Enforcement, Transportation, Protective Response (including authority to request Federal assistance and to initiate other protective actions), and Radiological Exposure Control.
The description of these functions shall include a clear and concise sumary such as a table of primary and support responsibilities using the agency as one axis, and the function as the other.
(See Section B for licensee).
For Coments, See A.1.a.
- g A.2.b. Each plan shall contain (by reference to specific acts, codes or statutes) the legal basis for such authorities.
J.4.1 in the Plan refers to legal authority under 10 CFR 50.47 (c)(1).
The utility has develoned LFRO, comprised of utility, Federal and private individuals. If New York State and Suffolk County implement an emergency plan, LERO would follow their lead (see Section 1.4, pages 1.4-1, 1.4.2; also, Attachments 1.4.1 and 1.4.2).
We authority of LERO to implement this plan under NRC codes and regulations and New York State Executive Law, as well as the issue of LERO's police power authority, has not been resolved.
A.3.
Each plan shall include written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role within the Emergency Planning Zones. We agreements shall identify the emergency nuasures to be provided and the mutually acceptable criteria for their implementation, and specify the arrangements for exchange of information.
W ese agreements may be provided in an appendix to the plan or the plan itself may contain descriptions of these matters and a signature page in the plan may serve to verify the agreements. We signature page format is appropriate for organizations where response functions are covered by laws, regulations or executive orders where separate written agreements are not necessary.
During the RAC review, the following legal concerns were identified:
LERO's authority to enter into agreements and/or contracts with emergency response organizations identified in the plan No signature page format nor reference (s) to laws, regulations or executive orders requesting response by local agencies specified in the plan could be found C.I.
We Federal government maintains in-<lepth capability to assist licensees, States and local governments through the Federal Radiological Monitoring and Assessment Plan (formerly Radiological Assistance Plan (RAP) and Interagency Radiological Assistance Plan (IRAP). Each State and licensee shall make provisions for incorporating the Federal response capability into its operation plan, including the following:
a.
specific persons by title authorized to request Federal assistance, see A.1.d., A.2.a.
The plan provides for the LERO Director of local response to " Request the Governor to ask the President i
to declare an Emernency or Disaster". W e legal basis for this procedure has not been identified in the plan.
C.4.
Each organization shall identify nuclear and other facilities, organizations or individuals which can be relied upon in an emergency to provide assistance. Such assistance shall be identified aM supported by appropriate letters of a3reement. Por Coments - See A.3.
E.5 State and local government organizations shall establish a system for disse,tinating to the public aporopriate information contained in j
initial and followup messages received from the licensee includirn the aporopriate notification to appropriate broadcast media, e.g.,
the Emergency Broadcast System (EBS).
LERO has established a network of Iong Island radio stations for disseminating emergency information to the public. LERO's authority to disseminate emergency information to the public without the involvement of State and/or local government officials remains a concern.
E.6.
Each organization shall establish administrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone.
(See Appendix 3.)
It shall be the licensee's responsibility to demonstrate that such means exist, regardless of who implements this requirement.
It shall be the responsibility of the State and local governments to activate such a system.
The official EBS system authorized by the Federal Comunication Comission (FCC) is used by government i
offi.cials to disseminate emeroency information to the l
public. LERO's legal authority to activate the alert and notification system without State and/or local government par-icipation remains a concern.
F.3.
Each organization shall conduct periodic testing of the entire emergency comunications system (see evaluation criteria H.10, N.2.a and Appendix 3).
No statement that State and local governments will partici-pate in comunication drills with LERO could be located in the plan.
G.3.a. Each principal organization shall designate the points of contact and physical locations for use by news media during an emergency.
We plan does not soecify the level of involvement by State and local officials in the development and/or review of EBS and news releases (see coment E.5).
H.4.
Each organization shall provide for timely activation and staffing of the facilities and centers described in the plan.
Without a State Site Specific Plan for the SNPS, there are no procedures specified for the activation and staffing of the State EOC in the event of a radiological emergency at the Shoreham site.
W erefore, provision for the notification and mobilization of personnel to coordinate the State's interface with the LERO response remains a concern.
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1 J.10.a. Maps showing evacuation routes, evacuation areas, preselected l
radiological sampling and monitoring points, relocation centers in host areas, and shelter areas; (identification of radiological sampling an3 nonitoring points shall include the designators in Table J-1 or an i
equivalent uniform system described in the plan);
The Evacuation Plan (Appendix A Section I - Preface pages I-1 to I-2) is made up of two plans - a study performed by Suffolk County as part of an agreement with LILCO (9/21/81), and a study performed by KLD Associates under an agreement with LILCO to develop an evacuation plan (12/30/81). LILOD has integrated the two studies into Appendix A.
I Since Suffolk County is not participating in the offsite emergency planning process, are the data developed by Suffolk County under contractural agreement on emergency response planning executed in 1981, still applicable.
J.10.c.Means for notifying all segments of the transient and resident population; As noted in analysis coments E.5 and E.6, LERO's legal authority to activate the alert and notification system and to disseminate emergency information to the public without the involvement of the State and/or local government remains a concern.
i J.10.f. State and local organizations' plans should include the method by which decisions by the State Health Department for administering radioprotective drugs to the general population are made during an emergency and the predetermined conditions under which such drugs may be used by offsite emergency workers; The authority of the Health Services Coordinator to i
authorize the use of KI for other LERO emergency workers who are not LILCO employees is of concern, since the
" State Health Department" would not be involved in the decision-making regarding use of KI by emergency workers.
J.10.j.The organization's plans to implement protective measures for the l
plume exposure pathway shall include:
Control of access to evacuated areas and organization responsibilities for such control; l
1 Since the staff assigned to Traffic Control are LILOO stployees, the ability to accomplish this effort under the authority of 10 CFR 50.47 reasins a concern.
).
Assigning access control duties to LILCO employees including:
4 setting-uo and controlling roadblocks dealing with evacuation etc., remains a concern J.10.k. Identification of and means for dealing with potential impediments (e.g., seasonal impassability of roads) to use of evacuation routes, and contingency measures; According to page 2.2-4 of the plan, it is anticipated that snow removal will be provided by local organizations in their normal fashion during an emeraency.
LERO's coordination with local agencies responsible for snow removal needs to be addressed to ensure that snow removal is in accordance with the evacuation scheme in case of a radiological emergency. In addition, LEBO's authority to remove impediments to evacuation remains a concern.
N.1.a. An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preoaredness plans and organizations. 'Ihe emergency preparedness exercise shall simulate an emergency that results in offsite radiological releases which would require response by offsite authorities. Exercises shall be conducted as set forth in NRC and FEVA rules.
Since New York State and Suffolk County are not partici-pating in the planning process, the testing of integrated capability of the offsite authority (s) remains a concern.
N.1.b. An exercise shall include nobilization of State and local personnel and resources ade pate to verify the capability to respond to an accident scenario recuiring response. The organization shall provide a critique of the annual exercise by Federal and State observers / evaluators. The scenario should be varied from year to year such that all major elements of the plans and preparedness orcanizations are tested within a five-year period. Each organization should make provisions to start an exercise between 6:00 p.n. and midnight, and another between midnight and 6:00 a.m.
once every six years. Exercises should be conducted under various weather conditions. Some exercises should be unannounced.
Since New York State and Suffolk County are not partici-pating in the planning process, mobilization of their personnel and resources during an exercise remains a concern.
P.I.
Each oroanization shall provide for the training of individuals responsible for the planning effort.
P.2.
Each organization shall identify by title the individual with the overall authority and responsibility for radiological emergency resconse planning.
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P.3.
Each organization shall designate an Emergency Planning Coordinator with resconsibility for the development and updating of emergency plans and coordination of these plans with other response organizations.
P.4.
Each organization shall update its plan and agreements as needed, review and certify it to be current on an annual basis. W e update shall take into account changes identified by drills and exercises.
P.S.
We emergency response plans and approved changes to the plans shall be forwarded to all organizations and appropriate individuals with responsibility for implementation of the plans. Revised pages shall be dated and marked to show where changes have been made.
NUREG-0654 mandates an integrated approach to the development of offsite radiological emergency plans by States, localities, and licensees.
Since New York State and Suffolk County are not partici-pating in the development, updating of and training for a radiological emergency plan for Shoreham, the lack of an integrated approach to offisite radiological emergency preparedness remains a cancern.
l
e UNITED STATES OF AMERICA NUCLEAR RIGIAIORY CQtilSSION BEFORE THE ATG11C SAFEIY AND LICENSING BOARD In the Matter of
)
)
Docket No. 50-322-OL-3 IDMG ISIAND LIGHTING C01PMW
)
(Ehergency Planning)
)
(Shoreham Nuclear Power Station, Unit 1 )
CERTIFICATE OF SERVICE I hereby certify that copies of the Federal Buergency Management Agency's testianony relating to Group II Contentions on offsite preparedness at Shorehan Nuclear Power Station have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk, by express mail, this 18th day of April 1984:
Janes A. Laurenson, Esq.*
Howard L. Blau, Esq.
Administrative Judge, Chairman 217 Newbridge Road At(xnic Safety and Licensing Board Hicksville, NY 11801 U.S. Nuclear Regulatory Comnission East-West Tower, Rn. 402A 4350 East-West Hwy.
Bethesda, MD 20814 W. Taylor Reveley III, Esq.*
i Hunton & Williams Dr. Jerry R. Kline*
707 East Main Street Administrative Judge Richnond, VA 23212 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Connission East-West Tower, Rn. 427 Cherif Sedkey, Esq.
4350 East-West Hwy.
Kirkpatrick, Inckhart, Johnson Bethesda, MD 20814
& Hutchison 1500 Oliver Building Mr. Frederick J. Shon*
Pittsburgh, PA 15222 Administrative Judge Atonic Safety and Licensing Board Stephen B. Lathan, Esq.
U.S. Nuclear Regulatory Connission John F. Shea, III, Esq.
East-West Tower, Rn. 430 TWxney, Iatham & Shea 4350 East-West Hwy.
Attorneys at Law Bethesda, MD 20814 P.O. Box 398 33 West Second Street Jonathan D. Feinberg, Esq.
Riverhead, NY 11901 Staff Counsel New York State Department of Atomic Safety and Licensing Public Service Board Panel 3 Bnpire State Plaza U.S. Nuclear Regulatory Connission Albany, New York 12223 Washington, D.C.
20555 Ralph Shapiro, Esq.
Canner and Shapiro 9 East 40th Street New York, NY 10016 1
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Atomic Safety and Licensing James B. Dougherty, Esq.
Appeal Board Panel 3045 Pbrter Street, N.W.
U.S. Nuclear Regulatory Comnission Washington, D.C.
20008 Washington, D.C.
20555 Stewart M. Glass, Esq.
Docketing and Service Section Regional Counsel Office of the Secretary Federal Bnergency Managenet Agency
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U.S. Nuclear Regulatory Comnission 26 Federal Plaza, Rm. 1349 Washington, D.C. 20555 New York, New York 10278 Spence Perry, Esq.
Secretary of the Conniesion Associate General Counsel U.S. Ibclear Regulatory Federal Energency tianagenent Agency Connission Room 840 Washington, D.C.
20555 500 C. Street, S.W.
Washington, D.C.
20472 Bernard M. Bordenick, Esq.*
Herbert H. Brown, Esq.*
David A. Reoka, Esq.
Lawrence Coe Lanpher, Esq.
Edwin J. Reis, Esq.
Karla J. Imtsche, Esq.
U.S. Nuclear Regulatory i
Kirkpatrick, lockhart, Hill Commission Gristopher & Phillips 7735 Old Georgetown Road 1900 M Street, N.W.
(to inailroom) 8th Floor Bethesda, MD 20814 Washington, D.C.
20036 Fabian G. Palomino, Esq.*
Eleanor L. Frtx:ci, Esq.*
Richard J. Zahnleute, Esq.
Attorney Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber Panel State Capitol U.S. Nuclear Regulatory Comnission Albany, New York 12224-Bethesda, MD 20814 Gerald C. Crotty, Esq.
Ben Wiles, Esq.
Counsel to the Governor Assistant Counsel to the Governor Executive Chamber Executive Chamber State Capitol State Capitol Albany, New York 12224 Albany, New York 12224 m
Stewart M. Glass Regional Counsel for~
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Federal Dnergency 11anagenent Agency l
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COURIESY COPY LIST Edward M. Barrett, Esq.
Mr. Brain R. McCaffrey General Counsel Iong Island Lighting Company long Island Lighting Company Shorehan Nuclear Power Station 250 Old County Road P.O. Box 618 Mineola, NY 11501 North Country Road Wading River, NY 11792 Marc W. Goldsmith Ehergy Research Group, Inc.
191B Tecimical Associates 400-1 Totten Pond Road 1723 Hamilton Avenue Walthan, MA 02154 Suite K San Jose, CA 95125 Martin Bradley Ashare, Esq.
Suffolk County Attorney Hon. Peter Cohalan H. Ike Dennision Bldg.
Suffolk County Executive 4
Veteran's Menorial Hinhway County Executive /Imgislative Bldg.
Hauppauge, IN 11788 Veteran's Menorial Highway Hauppatge, NY 11788 Ken Robinson, Esq.
N.Y. State Dept. of Law Mr. Jay Dunkleberger 2 World Trade Center New York State Energy Office Room 4615 Agency Building 2 New York, NY 10047 Empire State Plaza Albany, NY 12223 Ms. Nora Bredes Shoreham Opponents Coalition 195 East Main Street Snithtown, IW 11787 Iman Friednan, Esq.
j Costigan, Hyman & Hyman 1301 Franklin Avenue Garden City, New York 11530 f
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