ML20084P058
| ML20084P058 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/15/1984 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Kline J, Laurenson J, Shon F Atomic Safety and Licensing Board Panel |
| References | |
| OL-3, NUDOCS 8405170389 | |
| Download: ML20084P058 (17) | |
Text
Al-) \ RELM L'o coja:gsp0hDaGS DOCKETED HUNTON Oc WILLIAMS 707 EAST MAIN STREET P.O. Box 1535 aooo c svu.uim avenue. u.w.
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FIRST TE.sNEsSEE BANn suiLoiNG ei.srvi .......'o**" May 15, 1984
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8357 James A. Laurenson, Chairman Dr. Jerry R. Kline Mr. Frederick J. Shon Atomic Safety and Licensing Board D O CKE7 "9.-
U.S. Nuclear Regulatory PROD.ah,I w d
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Commission East-West Tower 4350 East-West Highway Bethesda, MD 20814 Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1)
(NRC Docket No. 50-322-EP)
FEMA RAC Meeting on Shoreham Emergency Plan Gentlemen:
At the request of Mr. Glass, counsel for FEMA, I forward to the Board and parties copies of three documents respecting the May 11, 1984 meeting between LILCO representatives and the RAC for FEMA Region II:
- 1. Meeting Notice, dated May 8, 1904
- 2. Summary of Draft Preliminary Responses to Consolidated RAC Review of LILCO Transition Plan for Shoreham, dated 5/10/84
- 3. Attendance list, May 11, 1984 Very truly yours, Donald P. Irwin 8405170389 840515 One'of Counsel for PDR ADOCK 05000322 Long Island Lighting Company G PDR .
91/730 Enclosures cc w/
Enclosures:
- Attached Service List g
i Enclosure 1 1
Federal Emergency Management Agency
@ Region H 26 Federal Plaza New York, New York 10278 May 8, 1984 MEETING NOTICE l
SUBJECT:
MAY 11,1984 MEETING OF FEMA, REGION II REGIONAL ASSISTANCE COMMITTEE (RAC)
WITH LONG ISLAND LIGHTING COMPANY (LILCO)
LOCATION: 26 Federal Plaza New York, N.Y. 10278 Room 305 B (Third Floor)
DATE: May 11, 1984 TIME: 10:00 AM PURPOSE: The purpose of this meeting is to provide LILCO the opportunity to receive clarification on the RAC plan review of the LILCO Transition Plan, Revision III for Shoreham. Any questions from LILCO will be limited to the RAC comments as they relate to the Planning Standards contained in NUREG-0654. This meeting will not result in any approvals, conditional or otherwise, of any new material presented. The formal review of any new materials must follow the normal procedure of submittal by NRC to FEMA pursuant to the terms of the NRC/ FEMA Memorandum of Understanding.
The RAC will not entertain any questions.from other parties than LILCO. If time will allow, other parties may present their points of view from 3:00 PM to 4:00 PM.
The meeting will adjourn at 4:00 PM.
l
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l l
SID64ARY OF DRAFT PRELIMINARY RESPONSES TO CONSOLIDA1TD RAC REVIEW Enclosure 2 OF Lil40 TRANSITION FRAN FOR SHOREHAM leese Creded inadequate 5/10/s4 Page 1 of 12 leem No. RAC Casment . Resolution Panes of Plan / Proc. Affected A.1.2.(1) h plan dres not addresa det support flew York State will A description of the types of support New York State provide la e radiolosteal emergency in Suffolk Canty when Plan p. 1.4-2 may provide to LERO, should they elect to do so, has LitI0's resources are exhausted. been incorporated in the plan.
(2) If flow York State to likely to respond, provialen for interface New York State has continuous access to emergency information Plan p. 1.4-2 with the LERO docteten procese should be included. at Shoreham via the Radiological Emergency Communica-tiene System (RECS) which connects all nuclear factittles in the state with state off tetale. Wie the RECS line and commercial telephone lines, they would interface with the Brentwood EOC.
(3) h plan should also addrese federet agencies (other than DOE, A description of the support which imletal agencies such Plan pg. 2.2-4 to PAA, and USCC) in terms of their role in resposse. as NRC, FEMA, EPA, llSDA and DOT may provide has been 2.2-4f incorporated.
i (1) h IRC will assign a Itateen to the local ECC es well, and The NRC has been allocated space in the local EOC as well se util require et least two commercial telephone lines and at Plan Figuress 4.1.1 to two telephone lines and equipment. 4.1.3 least two telephone inettissente.
OPIP 4.1.1 Att. 1 A.1.b.(1) The concept of operettene and relettonehty of each organiza- The relationehtp of all the organizatione le detatted Plan p. atti tion to the total amargency response effort to vague. Spec- in Chapter 2, 3 and Appendix A of the plan. Ita NUREG titeetly, the relattanehty of all orgententions/poettione cross reference has been expanded to identify all (e.g., hospitale, astulance pereommel, factittles to be used applicable sections.
as relocation centers, outside censultante and federal agencies such as PAA, IPA and USDA) to IJR0 and the implied lines of responsiblittles should be described la the concept of operations.
(2) Local 1.sw Enforcement and Fire Departmente are listed as CPIP 3.6.3 has been revised to incorporate Suf folk County police Plan p. 3.6-6 Support Orgentrattone with primary responelbtitty, yet on department in the traffic control function, shmld they decide to page 2.2-4 there to no clear statement that these organizations OPIP 3.6.3 asetet IIRO in an evacuation. The plan has been stetterly Section 5.1.3 will participate. h role of Suffolk County, should it elect resteed in Section 3.6. Due to the difficulty of incorporating to respond, should be spectitcally detailed as in Procedure 5.3.9 fire and rescue departmente into the emergency response on an 5.4.13 OPIP 3.6.3 (Tretite Control) page 8.
ad-hoc baste, the plan does not anticipate their involvement. Attachment 14
Page 2 of 12 Item No. RAC C<mmmet Resolution Peses of Plan / Proc. Affected A.1.e.(1) In Ptgure 2.2.1, the bloch diagram ase mos that New York State Both New York State and Suffolk County have Radiologicaf No modification and Suffolk County will casemmicate with 1.ERO.
Emergency Communicatione System (RECS) Itnee et their disposal -
These dedicated lines ring when 1.ERO picks them up and it is assumed that New York State and Suffolk County will pick them up if they ring.
(2) Clartiteetten eheuld be provided la the plan me to the role .
of the "outelde consultant (s)" to performing the accident The role of en "outelde consultant" as the Radiation Neelth Plan p.2.1-3 Coordinator has been clarified, assessment funetIan.
(3) Figure 2.2.1 should be revloed to deplet missing agencies (e.g., gPA, USDA) in a clearer mammer, Figure 2.2.1 hos been modified to depict all supporting Figure 2.2.1 federal agencies.
A.2.c.(1) S e respemelbility for 'Trotective Reepanoe", required by he Director of local Seeponse assumes responsiblitty for Plan p.2.1-1 ISBC-0654, hos not been defined in the test, nor to it listed in Figure 2.1.2. De 8MBC crose-reference should be revised initiating protective response actions. Figure 2.1.2 has Figure 2.1.2 been resteed to degitt such. The NUREC cross-reference Plan p. mitt to include as a citation for element A.2.a Figure 3.5.2 dich was modified, specIfles "protecttwo respomoe" reopeneIbtIities.
(2) Section 2.1 does not diettagotah betweer primary and support reopenettilittee for the response orgenfrettone. Sec tieta 2A has been resteed to distingulah that primary Plan p. 2.1-1 agencies are directly responsible and support agencies assist or perform one aspect of the function.
(3) Clertiteattan should be onde to Figure 2.1.2 to show a single primary responeittitty for each function. Figure 2.1.2 has been resteed to esalgn only one agency the Figure 2.1.2 primary responsibility for each function.
(%) lead, primary and support reopensibilities for each esency should be specified ta the "positten definitione" In Procedure 0FIF 2.1.1 hee been revised to assign lead, primary and OrlP 2.1.1 Att. 2 OPIP 2.1.1. support responsiblitties to each position described.
(5) PEMA has no responsibility for motifytag the public during a radiological emergency. Figure 3.3.7 has been revised removing FEMA ao e reopenalble Figure 3.3.7 agency for alerting and nottitcation.
A.2.b.(1) The cited authorittee (Secties 1.4 of the Lil40 Tranettien Plan) 2his is a legal authority tesue to be addressed eleeuhere. No modificetton relate to the authorittee of the NRC to license a plant under wortous degrees of emergency preparedness and compensation, rather than the police-type actione.
Page 3 of 12 lean No. RAC r-e Reeclutton Panes of Plan / Proc. Affected A.3. (1) No letters with Suffolk County or local agencies responsible for law enforcement, fire reopense or onow removal could be LITE 0 has to indication from local agencies responetble for law Plan p. 1.6-2b located in the plan. No reference to public lave requiring enforcement, fire response or snow removal that they will actively '
local agencies and services to reopend could be found ustas participate in thte emergency plan. It ta, however, espectes that the NURBC cross-reference, they will perform their normal functions without direct coordination with Lil@ and etnce this is all that is ettpulated in the plan, Lit m does not require a letter of agreement. The laws from the Suffolk County Charter detalling county responsiblitty for snow removal, fire safety and police actions have been added to the plan.
(2) The '1.ecal Public Service Agencies" and 'tocal Emergency Medical Figure 2.1.2 has been revised to change the titles of Local Pubite Ptsure 2.1.2 Services Ageactee* listed in Figure 2.1.2 should be specified. Service Agencies to Local Law Enforcement Agencies and Fire OPIP 3.6.5 Departments and local Emergency Medical Services Agencies to Att. 5 and 6 Private Ambalance Compantes. OPIP 3.6.5 has been amended to add two new attachments, #5 - Private Ambulance Companies and
- 6 - Local Law Enforcement Agencies and Fire Departmente.
(3) Contracts have mot as yet been finalised with the bus or ambulance suppliere. Contracts have been finalized with all bus and ambulance companies Plan Appendia B and will be inserted in Appendix B of the plan.
(0) the plea should specify the number of drivers that have been Pisure 2.1.1 identtites the number of bus drivers that are necessary No modification tratned and licensed to respond to a radiological emergency to implement the evacuation plan. Litto camunits that at least this at SNPS.
number will be trained, licensed and available. Idhile bus drivers are presently staffed at approximately 150%, thte number varies and it is inappropriate to identify in the plan.
(5) The letter of agreement from DOE on page APP-B-1 does not specify the degree of response to be provided, the DDE letter attached as APP-B-1 to a standard letter of agreement No modification used by tre DOE throughout the country. LilIO has not requested that the D0E* RAP team perform any function that is outside of their normal emergency response. it is only because of their prontatty to Shoreham (6 miles) that allows Lil40 to expect a rapid response, with full access to all local DOE-RAP resources. This high level local response would have been made available to Suffolk County if they had participated in the emergency response.
Page 4 of 12 Itse No. RAC Cassent Resolut ion
_ Paaes of Plen/ Proc. Affected (6) letters of agreement could not be located for the folloutng Letters of Agreements support orgentsettons/ persons or Representative Outelde Agencies o Stony Brook Hospital - These letters are (see Procedure OPIP 2.1.1, page 12) No modifiestion o Central Suffolk Hospital being pursued.
g Stony Brook Roepita' o Central Suffolk Neapital o SUNY Stony Brook e SINsY Stony Brook - letters with relocation No andtftcation o BOCES Central leltp centers are obtained o BOCES Central felty . o SCCC Selden and maintained by ARC.
o SCCC Selden o local law enforcement agencies o Local law enforcement o lacel fire departmeste - These esencies perform only their No modification o local fire departmente normal function and are not retted o local snow removal organteations o Local snow removal upon to support the emergency response, o Federal Aviattom Adstatstretton o laboratories etch provide enviroseental o PAA esmple analyste - A letter of understanding with the Plan Appendia B e Radiological Roalth Coordinator FAA has been obtained and included in Appendix 8 (outside comoultant) e Belocation center coordinator o Nuretag support o Commeelling coordinator o Support organisatione dich provide laboratory o Laboratories e tch - This support to provided either by DOE No modification and envirossental campte analyste provide sample analyste et Brookhaven Laboratory, with e tch a LOA estata, or through SNPS etch malna taine laboratof fee under contract.
o Radletion Health - See Impell Contract Plan Appendia B Coordinator o Relocation Center - these are ARC personnel. No modtiteation Coordinator LIISO has a LOA with o Nuretng Support ARC not their personnel.
o Counselling Coordinator (7) The resources 12R0 expects to use to support the federal It to not necessary for LILCD to obtain Letters of Agreement No modtittation responsee uhtch are identified in Attachment 3.11.1 should be supported by letters of agreement from those organisatione, with thte multitude businesses such as restaurante and hotele to ensure the availability of their services to support .n emergency response.
C.I.e. LERO has not specified dat resources have been identified by Federal agencies will receive resources primertly through the Plan p. 2.2-4 federal agencies to support their ef fort.
' DOE at Brookhaven. Any subsequent support will be provided by LERO and LILCO's extensive array of resources.
Page 5 of 12 Item No. BAC Cement Resolution Pates of Plan / Proc. Affected C.4 Written letters of agreement are locomplete. See A.3 No modification P.1.2. N plan does not provide for direct notification by LERO of OPIP 3.3.2 has been revloed to provide for 1.ERO's notification Plan p.2.1-4 other federal emergency response orgentastions in the event of other federet agencies such as NRC, PDA, etc. Pisure 3.3.4 that direct support i < to be requested from those organisations.
OPIP 3.3.2
= Seettone 5.3.3(e)
Attachment 4A In addition to DOE, USt%, and PAA, communications with other Federal support egencies should be arranged, i.e., NRC, PDA.
EPA, etc.
I.g. (1) The plan does not specify whether 1230 has acetdent assesament CPIP 3.6.1 has been revised to mesign a Nuclear Engineer the CPIP 3.6.1 pereennel who can esteh the plant's statue from an operational view te developing protective action recommendations, responsibility of ew;luating if protective actione are necessary Section 2.2 based on potential degradation of plant conditaans. OPIP 2.1.1 page 12b Attachment 3 (2) The plan does not specify how protective action doctoions would This information is now provided in OPIP 3.6.1 tAttch OPIP 3.6.1 be made to the e h ence of am actual release. The plan should has been revloed to incorporate pre-determined protective Section 5.0 specify that protective actione such as sheltering, and especially actions bened on plant conditions.
evacustten, could be implement <d prior to initiation of significant Attachment 5 and 6 rolesses, if possible.
(3) The NURBC-0654 cross-reference should be rewteed to include the following ettettone for element I.g The NUREC-0654 cross reference has been widttted Plan p. x, as necessary.
o Sectica 2.1, Figure 2.1.1, page 2 of 4 o Section 2.2, Attachment 2.2.1
! o Section 4.4, page 4.4-3 (mesmo of transportation for field tease).
I.9 (1) The methodology shoun in Procedure CPIP 3.5.1 (see Section 5.3.7b)
Section 5.3.7b has been revloed to read, "the centater le not OPIP 3.5.1 would not give occurate tenette for moet accident conditione.
acceptable for use if the noteture check dot le pink." Section 5.3.7b (2) Even without core desage, radiotodine may be collected on the particulate The note in OP!P 3.5.2 Section 5.6.7, stating that the filter OllP 3.5.2 filter if the ladtne to la elemental form. Therefore, one cannot rule out need not be measured unless there has been fuel or core damage. Section 5.6.7 octivity on the particulate filter se not being todine. has been removed. Thus, activity on the particulate filter util Att. 9 be measured in all cases.
Page 6 of 12 Item No. RAC e - t Resolutton Paaes of Plan / Proc. Affected (3) The namegram which relates tedies to total fleston products for An explanation of OPIP 3.5.2 and the anstaptione used for the Plan p. 3.5-2 the calculation of thyreld dose (OPIP 3.5.2 Att.11) may not be ets and decay of radiosotopes released has been inserted tato -
reeltette in this sopoet. The amount of flecton products collected thte section.
from a core d- accident are ht$ly dependent on a number of pers-metere such es moteture in contal - t, filtration of release, distance from the ette, etc., and are est easily ameadable to the namogree someptione.
(0) The hendtag of attactuente 5 and 6 Precedure CPIP 3.5.2 should be the referenced attachmente have been removed and incorporated OPIP 3.5.2 changed to read '9tsittply results by 10E-6." into the computerized procedure.
1.10 (1) Procedure OPIP 3.5.2 to lachtag several memograme editch are h referenced nomograme have been incorporated into the OPIP 3.5.2 required for the calculattoms ,
computerized procedure.
Section 5.2 (2) The plan should teclude provielene for the consideretton of N plan has been retteed to explain that OPIP 3.5.3 plant pornosters regarding typse of releases. Reliance on the Plan p. 3.5-3 uses a conservative (high) depositten velocity to ensure OPIP 3.5.1 stated 0.05 m/sec. depeeltten velocity is applicable under a that areas of concern are identitled so that field tease any limited set of a lc esaditions, and should not be retted Section 5.3.6 (d) be sent for further investigation or protective actione may upon as 12RO's only onens of ingeotten pathuey sone protective be implemented. In addition OrlP 3.5.1 has been modified action doctelame. Plead surveye with IW219 detectore can quickly to include a ground deposition survey with an H.P. 210.
determine grossed depeettlan.
(3) 1he NtmBC-06% crese-referomee should be revloed to also include the NUREG-06% erose-reference has been modified. Plan p. zu Precedure CPIP 3.6.1 se a citetten for element 1.10 J.2 (1) There to me discuesten of alternettve routes that are to be used h evacuation route for ette evacueen to the one regardless of Plan p. 3.6-8b for inclement usather and specific radiological conditions. whether the public le evacuating or if there to inclament usather.
The destination, however, may vary. Site personnel may be instructed to go home of to the Wildwood substation. If these are untahabitable, Riverhead or Pt. Jefferson district offices may be used.
(2) h plan should include a discuesten of transportation to be Site evacuees util use their personal vehicles. Plan p. 3.6-86 used by SNPS atte peroommel.
J.9 (1) There is no discuesten of how protective actions would be See 1.8(1) OrlP 3.6.1 Implammated bened en plant condittene prior to actual releases (see coment for element 1.8). Section 2.1, 5.0 Att. 5 and 6 (2) Tables 3.6.2 and 3.6.3 are taken from the PDA draft report, and h referenced tables have been removed from the plan. The Plan p.1.6-3 are not the final values. updated tables are in OPIP 3.6.6 Tables 3.6.2, 3.6.3
Page 7 of 12 Item No. RAC Comment Resolution Paare of Plan / Proc. Af fected (3) h NWRAG-06% crose-reference should be regteed to include h Nt*EG-06% cross-reference has been modified. Plan p. xvt Table 3.6.1 es a citetton for element J.9 -
i J.10.b(1) h map to Figure 3 of Appendia A does not show subarea boundertes h subareas (F1-FS) and (Kl-K5) wov1d never be evacuated No modification for evacostion areae F (F1-FS) or E (Kl-ES). Independently and thus do not require demarcation on Figure 3.
(2) Populattaa members should be stated for each ERPA. A nep(e) showing A map has been added to the plan telch shows the population Appendts A, Sec. 111 psyulettom distribution has not been included to the plan. for each ERPA. Figure 7.1 J.10.1(1) Precedure OPir 3.6.2 states that distributtom will be accomplished h plan has been resteed to provide El to emergency workere Plan p. 3.6-5 by directing emergency morLere to e distributton locattom. This at their staging areas before going into the field.
may regatre rece!!!ag emergency morters from the field and a time Orl? 3.6.2 delay in admtaletertog El to them. Section 5.1.c (2) At the peesent time, there to me El avellable uhtch to not beyond The El tablete purchased by LiliD have a marked emptration date No modtiteetter.
the labeled empiratica date, heuever, FDA has granted estenatone for its use. h preceduree shou'd reflect FDA estensione, of June 1965. N validity of this date was vertfled by telephone conversation with the manufacturer. The entension of shelf life referred to in the FEMA comment is no longer applicable to any esteting El tablets.
J.13.") bre to as legend om Ftpre 9, Zone A (page tv-76, Appendia A) defining The American Red Cross of Suffolk County has infotued Ll!ED that the tien p.4.1-1,3,4 the destgestors for SWif, b!XIC and 30GS es relocation centers. However, following locations would serve as the primary relocettone centers: Figure 4.2.1 it hee been estimated that only the 30GS relocation cetter to at least Center Approx. Distance from SNPS five allee beyond the 10-stle EFE, Note Additional St. Joseph's College 16 miles changes will be BOGS - teltp 20 miles made in the Dowltas College 21 miles procedures and StBrY Farmingdale 32 miles Appendia A.
Additional locations would be activated as the need became apparent.
J.10.*_(1) Pre emergency plemming fer ones removal en the evacuation routes be further h snow removal efforte provided under public low, referred to la No modification developed to include admintotretive procedures, Sora, etc.
the plan are not coordinated with the emergency response. Except in emergency scenarios having very long lead times, the time required in a severs snow storm to clear all the extensive side streets and drivemeye would be too long to be seeningful assistance, IERO wo uld thus be recommending a protective action of shelterins in most cases regardless of the availability of snow removal services.
(2) h WEROG crose-reference should Stat Procedure OPIP 3.6.3 as a citation h NtmEC-0654 crose-reference has been modified. Plan p. sit for element J.10.b.
Page 8 of 12
, item No. BAC Cement Resolution
_ Peace of Plan / Proc. Affected J.10.e(1) h pies does not specify udnether 120 hee accident assessment personnel See I.8(t) edeo can metah the plant's o stue from an operational view to developing OPIP 2.1.1 proteettve acties receammedettene (see caement I.8). Att. 2 and l (2) The off-site cemettiene (men-redtological) are not specifically addreened. Non-radiological information such as road conditions will be Plan p. 3.64 in that the Evacustlan Coordinator, who should have information regarding any off-site cemetratets to protective actions, to not involped in the provided to protective action decteton-meking by the Evacuattom CPIP 3.6.1 Coordinator.
doctetene. Section 2.5 5.1.14 5.2.2 (3) h m-06% creae-referseca should be revloed to include Precedere CPIP 3.6.1 as a ettetton for element J.10.e. The NUREC-06% cross-reference has been modified. Plan p. xvt J.11 (1) 1he inctesten of made Island within the 50-mile EPZ ohould be reevolmeted, etace h de Island une tecluded in a previous revision (see Rhode Island to over 50 miles from the ette and therefore not No modification included in the 50 mile EPZ.
comment for critetta element P.1.b).
(2) h plan to met specific for impostas protective procedures such as 8W docentamtmatten, proceostag, decay, product diversion, h Shoreham 50 mile EFZ eatende into Connecticut and New York. Plan p. 3.6-8a and preservetten. LilED has a letter from Connecticut uhtch indicates they will provide an ingeotton pathway emergency response, within their boundaries, upon notificetten by a licensee. Within New York State, the primary means of food interdictice will be radio messages identifying areas of concern and offers to compensate anyone with economic losses due to food being withheld from merket. 'In addition, aid may be requested from the USDA, EPA and DOC to aestet in food interdtetten in accordance with their reopensiblittles under the Federal Master Plan.
(3) hre are no mape referenced for recording survey and aanttoring data, hey land use date, diertes, feed processing plante, water shede, etc. If hplanhasbeenrevloedtoincorporatereferencestotableslisjng Plan p. 3.6-Ba '
detries, forse and food processing plante thich have been inserted CPIP 3.6.6 Lil40 has access to the State maps, this should be referenced in the plan.
In OPIP 3.6.6 and mope of the 50 mile EPZ uhtch are housed at the Section 5.1.1.2 EOC.
5.1.2.3 5.1.3 5.4 5.4.1
Pope 9 of 12 ften No. BAC Camment Resolutton
_Paaes of Plan / Proc. Affacted (t) hee are also no lists of food procesotag facilities located outside the in the New York metropolitan area, virtually all food flows OPIP 3.6.6 50 mile EPZ, dich process feed aristneting within the 50 mile EPZ. touards New York City. h e, la it unlikely that any food Att. 9 through 16 processing outalde the EPZ uould take food from inside and seed it fusther suey. The list of food processors, hauever, does identify facilities as far as 70 miles from SNPS to ensure that all potentistly contaminated food to contained.
J.12 (1) h member of decantasteetten kito evellable, and their place of storage at The monitoring and decontamination equipment will be stored at Plan p. 4.2-4 each location could not be located in the plan. relocation centers.
(2) Seemd on a restou of the ogstyment leventory listed la the plan, it is h plan calle for a total of 90 radiation monitoring persons to No modtittation gamettenable whether the number of potential relocatees could be be deployed to relocation centers. Assuming 2 minutes or less to monitored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. monitor an individual, approximately 32,400 people could be processed in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This is more than the 20% of the EPZ population for dich relocation center capacity is established, even in a worst case, full 10 mile evacuation.
(3) The procedures aheeld describe clearly understood measures dich, to the CPIP 3.9.2 has been revised to clarify that only evacuees with OPIP 3.9.2 greeteet estemt practicable, statetae the likelthood for potentially a " clean" tag may enter a relocation center. Section 5.9 contamtmeted persene to gain access to a relocation center where evacuees are to be housed, fed and cared for.
(4) More teformation to aseded on the Red Croce responsibilities and procedures h American Red Cross procedures for operating relocation cente.. Plan p. 2.2-1 at the centers. are detailed in ARC 3050 N issater Services Regulatione end Procedures, Disaster Bealth Services". This is a public document e tch need not be reproduced in the LERO plan.
(5) There are no regtetrattan forum (other than esposure) oupplied with the plan. The registration forme are supplied by the American Red Cross No modification and for the reason cited in J.12(4) not included in the LERO plan.
M) 1here eheute be precedures for complettag registretton forme for non- The procedure has been revised to provide that non-contaminated OPIP 3.9.2 contaminated individuals, individuals sign out on a " clean" Emergency Worker /Evaeuse Section 5.9 Monitoring Record Form before proceeding to an ARC relocation center for regletration there.
(7) The procedures should also specify where evacuee monitoring records will OPIP 3.9.2 has been revised to include that evacuee monitoring OrtP 3.9.2 ultimately be metatained, recorde are kept at the equipment storage areas until moveJ Section 5.1.7 to the EOC for permanent storage.
C) The asettable equipment shoun for moottertog evacuees may not be suffletent See J.12 (2) No modtitcation to meet the 12-hour time limit within uhtch all evacuees arriving at relocation centers must be monitored.
Page 10 of 12 Item No. RAC Comment Resolution Paaea of Plan / Proc. Af fected (9) The NURgC-06% crose-reference should be resteed to include Procedure 4.2.1 se a citation for element J.12. The NUREC-06% cross-reference has been modified.
Plan p. zwt' E.3.0 (1) De teventory lista in OPIP 5.3.1 show that taeufficient numbers of chargere The doetmeter chargere are shared by the emergency workers to Plan p. 3.9-2 are avellable. The plan should clarify whether doetmeter charges will be teamed to each emergsacy worker, or whether doelmeters will be seroed sero their dosimetere et the staging areas. The chargere are and distributed at the emergsacy morter staging areas.
not taken into the field.
E.5.s (1) Por all open wtadow reedtage. 091 should be used, rather than er/hr.
CPN values have been tacorporated for all open window readings. Table 3.9.1 (2) The data in Procedure OPIP 3.9.2 do not correspond to the listings in Table 3.9.1 for ekte, batr, clothlag, and vehicles. the data in OPIP 3.9.2 and Table 3.9.1 have been made constetant. OPIP 3.9.2 Att. 7 (3) The threshold for decantasteettan is Table 3.9.1, and the values for rolesse shoun la Table 3.9.2 do set agree. Table 3.9.2 gives the NBC The values for decontamination found in Table 3.9.2 and OP!P 3.10.1 No modification '
are for general ares, ground and building surfaces. Ll!40 has been surfaca contaminetten levels for decentestening nuclear power plante, uhtch are too low for practical application under emergency creditions. unable to find ofilctal documentation of allowable levels other than Reg. Cutde 1.86 If PEMA will provide officially acceptable levels other than these, LilED will replace the ones presently used.
S.5.0 (1) The correct thyrote contamination number should be identtited and used consistently. OPIP 3.9.2 uses only .13 mR or 150 CP90 as a thyroid contamination No modification limit.
(2) The W 270 prete identified in Procedure OrlP 3.9.2, Section 5.5.la to unable to detect alpha activity. The referenced procedures does not provide for the seene to measure No modtitcation alpha particle activity because none of the isotopes of interest are uniquely alpha eettters and thus would be identified via beta gamme measurescate.
(3) Radtelegical docentaminetten equipmmet, supplies, and storage and disposal capability for contaminated unste aseactated with the deca 1tamination proceso OPIP 3.9.2 has been modified to include provisions for transferring OPIP 3.9.2 could not be located la the plan or procedures. radioactive westes to the Shoreham ette for disposal. Section 5.1.8 (7.) Monttertag eqstyment tecludtag liste of empplies used for decontamination The decontamination equipment inventory liste to contained la Plan p. 4.2-4 at the decentamination centere eheute he itemised, as well as quantitles OPIP 5.3.1. The list identifies total equipment evallable for available, all relocation centers. This table le now referenced in the plan.
(5)
No indicotten of first aid admintetration or avalleble kits could be found ISO emergency workers are neither trained in first aid ner expected No modification in the plan or procedures.
to provide such assistance. Thuw, there to no first aid equipment provided in their kits.
Page 11 of 12 Item No. RAC Comment Besolution Paees of Plan / Proc. Af fected L.I. (1) The capability /esperttee of medical facilities and personnel at Stony Brook Hospital and Central Suffolk Boopital that will be used to evaluate radiation A letter of agreement stipuisting the factittles and capabilittee of No modtitcation these hospitete to being puroved. -
uptakes and exposures should be doecribed. No indication that personnel from these hospitale are prepared to handle contaminated individuate could be found in the plan.
L.3. (1)
Pr=-ae=e CPIP 4.2.2 centaine a tiet of keepitato capable of. treating contaminated A new Itating of hospitato e tch can treat contaminatedlinjured OPl? 4.2.2 tajored individuales hausver, the !!sttag does not include their capacity and any indivinale with the number of beds and personnel has been opecial radiological capabilities. Attachment 1 incorporated in OPIP 4.2.2.
(2) Precedure OPIP 4.2.2 should be referred to in Section 3.7, to ensure that the 1.350 OPIP 4.2.2 se now referenced in plan section 3.2 Plan p. 3.7-1 maalth Servlees Coordlaster and staff are emere of these additional resources in the event they are needed.
C.I. (1) Attmehamme 3.10.1 and Section 3.10 (Recovery /Re-entry) give no consideration to 2here to no Attachment 3.10.1. It to assumed that item M.1(1) No modification plant comettions, such as the prehability of additional significant releases, below addresses this concern.
continuing or totermitteet few level rolesees, etc.
(2) Attactment 3.10.1 refers to ecceptable levels for unrestricted release of property See E.5.s(3) during a decentestentag of a factitty (per Reg. Cetde 1.86) and are not related No modificetten to recovery free se emergency.
(3)
Procedure CPIP 3.10.1 notes that the plant amat be stable, no significant releases CPIP 3.10.1 has been revised to include a Nuclear Engineer in OPIP 3.10.1 occurring, etc. as precautione for setering Recovery. However,there to no the Recovery Action Comittee who will review the plant status indicatten of no deterstase detter these conditions have been settaf ted. Sections 5.1.1, and ensure that the plant to stable, etc.... 5.2 and 5.3.1 (1) An evectetten to not necessertly a prerogulette for recovery. Evacuation has been rearmed as a prerequisite for recovery OPIP 3.10.1 from OPIP 3.10.1.
Sections 4.1 & 4.4 (5) It stauld be indicated to Section 3.11 that post-emergency phase activities EPA has been identified as the lead federal agency for long Plan p. 3.11-1 are a responethitity of EPA as per the PWur, ters operettone.
C.S The plan abould estahlteh a mothed for estimating total population exposure, A procedure has been developed to calculate total popuistica Plan p. 3.10-2 not merely state that se orgentsattom will be estabitehed for thle purpose. exposure and to referenced in Section 3.10 of the plan. OPIP 3.10.2 C.1.b. Trataing should be of fered to *all local law enforcement egenetes and fire Lacal law enforcement agencies, fire departmente and snow OrtP 5.1.1 departments within the 10-mile EPZ," dich are anticipated to carry out their removal agencies will be offered overview emergency response mormal emergency response functione during a radiological emergency at SNPS. Section 5.1.3.4 and radiation fundamentale training.
Page 12 of 12 Ites me. RAC Causet Resolution
_ Penes of Plan / Proc. Affected C A.b. No provistaa hee base included for tretetas of Radiological Nealth Nanagers, the plan now makes provisions for tratatag peroommel do will Fina p. 5.1-7 nor for anyone in 1230, to evoleste the implication of plant conditions in fill the positions of Radiation Nealth Coordinators and Nuclear protective aceton recommendettone. Pisure 5.1.1-& 5.2.1 Engineer la this area. This training will orient these persons to the detstle of the procedures that they will need to implement.
LERO will not, however, be providing technical training in areas these persons are already qualtfied.
~
CA.d. Police, security and fire fighttag peroommel are to be filled by personnel see A.3.(6) with nahum L112/LERO does eat have a mutant sie agreement supported by a No soottleetton letter of agreement.
P.g. (1) h crose-reference should be reviaod to teclude the citettons that are not The NUREC-06% crose-reference has been modified, se identified Plan p. atti to todoned as noted in the stove ceummets. above.
3,111 (2) h applicantlity of the fellestag references to the NUREC-06% critetta elements listed belaw should be clarified, or these references should be deleted from the The NUREC-06% crose-reference has been modified, se appropriate. Plan p. sitt to 3,111 NUROC-06% crose-reference submitted with the plan.
N-06%
Element Reference cited to Plan C.2.s Section 3.11 - attachment 3.11.1 J.10.h Appendia A - Pig. 9 Zone A J.10.] Precedure OPIP 3.3.2
).
Items Creded Adequate Provided the Necessary Revisions Are Mode to Maintain Their A&pg 5/10/04 Page 1 of 3 lten me. RdC Cement Pages of Plan /
Resolution Proc. Affected 4.1.t3 The specific individuel(s) ehe will perform the responetbilities of the Radiation llealth Coordinator to identtited by title and affittation. WUREC crose-reference has been modified to reference the Plan p. sitt IlfEli Corporation contract with LILCO under uhtch the services of the Radiation Realth Coord'nator and the
, Nuclear Engineer are provided.
C.1.b. Specif te ressucces and espected timme of arrival are identified for the U.S. Comet Guard (see section 2.2, page 2.2-2). Any additional A new attachment has been added to Sectlen 2 of the plan Plan p. 2.2-1 which provide the response time and mobilitetton locations federal resemeces, includtag espected times of arrival to be furntehed Attachment 2.2.2 for the federal support agencies including EPA, NRC, USDA thraup the PIERP (see Section 3.11, page 3.11-1) or other arrangemente, and othere.
should also be specifjed (e.g., EPA IAC, 55D4).
3.1 The motificetten list of perseme/stempe/orgentsations to be notified et general emergency is added to the plan. Pisure 3.3.4 has been resteed to serve se the notification list Plan Figure 3.3.4 for both a $tte Area amergency and a General emergency E.5 Per clarity, the system developed by 1820 should use different la accordance with 47CFRl73.935 and 673.937 "this ERS may be No modtiteetion nemenclature to diettapsteh it from the FCC sanctioned EDS system.
activated...at management's discretion, in connection with day to day emergency situatione posing a threat to the safety of life and property". Thus, it is within the boundo of ESS regulations for Llla to request the radio station management to activate the EBS system. This would not require the involvement of any government of f tetal.
P.1.b Arrangemente are established for comunications with Rhode Island.
Sie portion of the State of Rhode Island is within 50 miles of No modification the Shoreham Nuclear Pouer Station. Consequently, there is no plan to include Rhode Island in the planning process.
P.I.o The motificatten list of persons /groupe/orgentrations to be notified See E.1 at general emergency to added to the plan. Plan Pisure 3.3.4 P.3 The Lits Westeer Operettene Support Departmoet Procedures contain the required frequency of stres toets. the plan hoe been meditted to include the frequency of stren Plan p. 3.4-7 test es provided in the Lit a procedures.
C.4 (1) The Radiation Realth Ceardinator should be included in the emergency eell checklists in Procedure OPIP 3.3.2. 0FIP 3.3.2 Attachment 2 has been resteed to include the OPIP 3.3.2 notification of the Radiation Health Coordinator and the Artachment 2 Nuclear Engineer.
(2) Per analysts comment E.1 and P.1.e, Pisure 3.3.4 does not include See E.1 a list of peraame/ groups /organisatione to be notified for mobiltration Plan Pisure 3.3.4 et general emergency.
Page 2 of 3 fras No. RAC Ceement Pages of Plan /
Resolution Proc. Affected (3) h plea and Procedure CPIP 4.1.1 appear to be contradictory. It le met necessary to delay nottiteettene to the BOP and New York State The notifications of the EOP and New York State are not Plan p. 4.1-1 delayed until tthe local EOC to activated. They are '
estil full activattaa of the local 30C to cacyleted (as stated in initially nottfled from the alte via the RECS network.
Section 4.1.A of the plem). Procedure OPIP 4.1.1, Section 5.2 indicates As the local EOC to activated according to OPIP 4.1.1, that the Director of lace! " . will make these nottitcatione upon the EOP and New York State are called by the Director of errival at the local EOC, Sectica 4.1.A of the plan should be changed to 12R0 to establish this new point of contact with the LERO agree with the implementing procedure. .
organ tastion. - The plan has been revised to clarify this.
N.7 Clartiteetten of emnership and reopensibility for malatenance of the OR$ hiet are specified. h ORS kits at Brookhaven are cuned and maintained Plan p.3.5-2 by DOE. Should additional kite be necessary, LIIIO has and 3.5-2a 3 ktto dich they maintain in Brentwood. All radio Attactment 2.2.1 equipment for the DOE-RAP tease to provided by ICE-RAP.
C.11 (1) The equtymmet list en page 4.4-11scludes only one str sampler. LIIIO maintaine 3 sets of backey equipment in Plan p. 4.4-1 De plan eheuld state dether back-up samplete are ovellable et Brentwood. The inventory list in OPIP 3.5.1 has been the staging area. It abould be tekem into consideretton that OPIP 3.5.1 endtfied to list the equipment uhtch is contained in Att. 3 redtetodine sampling capability la toet in the event of pump fatture, one complete kit.
New does the Itot on page 4.4-1 relate to the list in Procedure OPIP 5.3.1, unich includes multiple air sempleret Also, are there radiation meters to go with the GI detectore listed in Procedure OPIP 5.3.1 as ovellable at the leest 50Cf (2) Camemntcatione equipment on page 4.1-4 should include redte linka Radio equipment for the teams to provided by DOE-RAF. Plan p.3.5-2a between the field teams and BOC.
This communicatione link to between the field and p.4.1-4 teams and the DOE-RAF team Captain who may be at either BNL or the EOC depending en radiolegical conditions.
I7 Precedure OPIP 3.5.1 and the equtyment list la Attachment 2.2.1 h information provided in Attachment 2.2.1 to the equipment No modification of the plan do not colmeide. The plan la adequate la addresetag in the DDE-RAP team kite. h equipment in OPIP 3.5.1 to in thte element provided that these tuo liste are reconciled. the L11EO ORS hite, i J.10.4 h directory of mem-tastituttamelland settlity impetred individuele has been completed, The listing of non-institutionaltred mobility tapetred No modification individuate to being placed into LiliD computers in order to expedite updating and retrieval. A sample output of thle program will be provided upon completten.
J.14.f the precedures for screening emergemey mortere who would be given El are included in the plan, The plan has been revloed to describe that during training. Plan p. 3.9-1 all LERO emergency workere do might enter the EPZ are provided information on the use of El and its side effects.
If an allergy to suspected, the 12R0 personnel is directed to cenault with his/her personal physician and to not take the El if it to distributed.
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- I J L N P
1 Enclosure 3 MAY 11.1984 MEETING OF FEMA. RECION II )
RECIONAT. ASSISTANCE COMMI m i (n Ad WITH LONG ISLAND LIGHTING COMPANY' (LILCO)
Name Organization Telephone No.
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V MAY 11.1984 MEETING OF FEMA. REGION II RECIONAL ASSISTANCE COMMIrt rF (R Af*)
WITH LONG ISLAND LIGHTING COMPANY (LILCO) l Name Organization Telephone No.
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g LILCO, May 15, 1984 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
(Emergency Planning Proceeding) Docket No. 50-322-OL-3 I hereby certify that copies of a letter from Donald P.
Irwin to James A. Laurenson, Esq., et al., dated May 15, 1984, with enclosures, were served this date upon the following by first-class mail, postage prepaid.
James A. Laurenson, Secretary of the Commission Chairman U.S. Nuclear Regulatory 4
Atomic Safety and Licensing Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing East-West Tower, Rm. 402A Appeal Board Panel 4350 East-West Hwy. U.S. Nuclear Regulatory Bethesda, MD 20814 Commission Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East-West Tower, Rm. 427 Washington, D.C. 20555 4350 East-West Hwy.
Bethesda, MD 20814 Bernard M. Bordenick, Esq.
David A. Repka, Esq.
Mr. Frederick J. Shon Edwin J. Reis, Esq.
Atomic Safety and Licensing U. S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory 7735 Old Georgetown Road Commission (to mailroom)
East-West Tower, Rm. 430 Bethesda, MD 20814 4350 East-West Hwy.
Bethesda, MD 20814 Stewart M. Glass, Esq.
Regional Counsel Eleanor L. Frucci, Esq. Federal Emergency Management Attorney Agency -
Atomic Safety and Licensing 26 Federal Plaza, Room 1349 Board Panel New York, New York 10278 U. S. Nuclear Regulatory Commission Stephen B. Latham, Esq.
East-West Tower, North Tower Twomey, Latham & Shea 4350 East-West Highway 33 West Second Street Bethesda, MD 20814 Post Office Box 398 Riverhead, NY 11901 L
g -
'1 ,
l l
Fabian G. Palomino, Esq. Ralph Shapiro, Esq.
2 Special Counsel to the Cammer & Shapiro, P.C.
Governor 9 East 40th Street
' Executive Chamber New York, New York 10016 i
Room 229 State Capitol James B. Dougherty, Esq.
Albany, New York 12224 3045 Porter Street Washington, D.C. 20008 l Herbert H. Brown, Esq.
Lawrence Coe Lanpher, Esq. Jonathan D. Feinberg, Esq.
Christopher M. McMurray, Esq. New York State Public Service Kirkpatrick, Lockhart, Hill Commission, Staff Counsel Christopher & Phillips 3 Rockefeller Plaza
- 8th Floor Albany, New York 12223 i 1900 M Street, N.W.
l' Washington, D.C. 20036 Spence W. Perry, Esq.
Associate General Counsel Mr. Marc W. Goldsmith Federal Emergency Management
. Energy Research Group Agency 4001 Totten Pond Road 500 C Street, S.W., Rm. 840 Waltham, Massachusetts 02154 Washington, D.C. 20472 f MHB Technical Associates Ms. Nora Bredes 1723 Hamilton Avenue Executive Coordinator Suite K Shoreham opponents' coalition 1 San Jose, California 95125 195 East Main Street l Smithtown, New York 11787 Mr. Jay Dunkleberger i New York State Energy Office Martin Bradley Ashare, Esq.
i
. Agency Building 2 Suffolk County Attorney Empire State Plaza H.' Lee Dennison Building Albany, New York 12223 Veterans Memorial Highway l' Hauppauge, New York 11788 Gerald C. Crotty, Esq.
Counsel to the Governor l Executive Chamber State Capitol Albany, New York 12224 ,
A.l
~
) )*-
Donald P. Irwin Hunton & Williams
- 707 East Main Street Post' Office Box 1535
- - Richmond, Virginia. -23212 DATED
- May 15, 1984 t