ML20084S662
| ML20084S662 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/11/1984 |
| From: | Federal Emergency Management Agency, LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20084S654 | List: |
| References | |
| NUDOCS 8406060334 | |
| Download: ML20084S662 (95) | |
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MEETING OF FEMA, REGION II l
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LONG ISLAND L I G IIT I NG COMPANY (LILCO):
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13 1, - i May 11, 1984 l
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!h 15 Before:
Raymond De Simone, a Certified Shorthand i L'E ili 16 Reporter and Notary Public, at the offices of A.h e
17 Federal Emergency Management Agency, 26 Federal 1E 18 Plaza, New York, N.Y.,
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20 Fi I l 21 TAYLOE ASSOCIATES l
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1 A '~ P P E-A R.A'N~C E S:
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ROGER B.
KOWIESKI, Chairman
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(' Attendees on attached sign-in sheet.)
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MS. CAMPAGNONE: 'I guess I will start 2
the meeting by-introducing myself.
My name is 3
Maryjo Campagnone.
I am a licensing proj.ect 4
manager with the Division.of Licensing at the 5
Nuclear Regulatory Commission.
I an an assistan't 6
.to the project manager, Ralph Caruso.
7' Joined with me today from the NRC is 9
Mr.
Bernard Bordenick.
He is our legal counsel, 9
and maybe'not~ at this time but'he will 'b e here 10 shortly, Dr. Bellamy :ron the Region I orrice.
11 I will say that I am well aware that 12 the press is present and I have a request that 13 they not use lights during the meeting, although 14 they may film, as they get to be pretty hot and 15 uncomf o rt a ble'.
16 This meeting is held pursuant the 17 meeting notice that went out from the NRC office la on May 2,,,19 c 4, and I will read you the purpose of 19 this meeting.
20 Fo r the representatives of the Long 21 Island Lighting Company,,LILCO, to briet the 22 representatives of the Federal Emerengency 23 Management Agency, known as FEMA, Regirn II, 24 Regional Assistance Conmittee, the RAC Committee, 25 on the LILCO proposal to renedy dericiencies t
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1 identified by the RAC in the LILCO off-site, 2
emergency plans for the Shoreham Nuclear Power 3
- Station, s
4 F E '1 A is c o o rdi n a t. i ng the review ror 5
the LILCO otr-site. plans'and is conducting this 6
meeting in response to a request from the Nuclear 7
Regulatory Commission in accordance with Section.2 R
(4) -1900 FEMA Memorandum of Understanding.
9 The next order of business is we are 10 going to discuss the ground rules of the meeting.
11 The' meeting is being held by NRC and 12 FEMA.
The participants will be FEMA, the Nuclear 13 Regulatory Commission and LILCO only.
The meeting 14 is open to the' public f o r obse rvation, and 15 observation only, not for.public participation.
16 The public will be allowed to comment 17 at the close of the meeting and to only comment.
is Any questions at the close of the 19 meeting can be sent to the NRC, but our purpose 20 and function here today is not to respond to 21 questions from the public.
This meeting will be 22 transcribed, everything that we say here is on the 23 record.
24 At this tine I will turn the meeting 25-over to FEMA.
S
'l MR. KOWIESKI: Th'a n k you.
My name is 2
Roger Kowieski.
I am the chairman or the Regional 3
Assistance Committee.
First let me introduce 4
members or the RAC Committee.
Our consultints, I-5 consultants,to FEMA, and F.E M A staff rrom FEMA 6
. regional office as well as national office.
~7 On my left is Dr. Robert Bores of NRC, 8
RAC member; Herbert Fish from DOE; Joyce Feldman-9 rrom EPA; " Ro n a l'd Bernacki from FDH and RAC 10 administration; Cheryl Malina trom US Department 11 of Agriculture; Paul L:utz from the Department of 12 Transportation, Coast G u a'r d ; member of my starf, 13 Robert Acerno; my boss, chief, National I
14 Technological Hazards Division, FEMA Division II, 15 Philip McInti' retire; consultant to FEMA, Joseph 16 Keller trom the Idaho Nuclear Engineering 17 Laboratory; Dr. Thomas Baldwin from Argon National 18 Laboratory.
19 STu Glass, regional counsel; Mary 20 Jackson, our public inrormation orficer.
21 We have Spence Perry, associate 22 general counsel trom FEMA headquarters office.
We 23 have a Maria Vorel trom the Congressional Liaison 24 Orrice; and Dave Deone, Public Afrairs Orrice.
25 Did I miss anyone?
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1 I am sorry, Rose Walsh, who i s,
'2 helping us today from our FEMA' Region II ortice.
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~3 Maryanne Jackson is here, Public.
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Inrormation Orricer.
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Before we start our discussion, get 6
to o ur. discussion, I.suggest t'h a t the LILCO
-7 representatives introduce themselves, and also we 9
would like
,t o know who is in the audience.
We 9
would also like the audience to introduce
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10 themselves so we know who will be listening to us.
11 12 MR.
IRWIN: Let me introduce the LILCO 13 representatives.
My name is Donald Irwin.
I am 14 one of counsel for Long Island Lighting Company.
15 Since this is a technical meeting and I am a 16 lawyer, this will be about of the last thing I say 17 all day today.
11 On my right is chuck Daverio, who is i
19 with Long Island Lighting Company and is the 20 deputy director or LERO or LERIO; John Weisman, 21 who is the director of LERIO is on the witness 22 stand this morning.
Otherwise he would be here.
23 with me on my left is Brant Aidikorri, la who is also with LERTO.
He is with Stone &
i 25 Webster.
Brant has been working on the emergency i
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plan continuously from day one.
He and Chuck have 2'
been primarily responsible for developing comments 3
on the RAC review and responses to them.
M I believ.e although they are rew in 5
numbers, they are.long on knowledge.
6 MR. KOWIESKI: Let's start.with you, 7
sir.
Will you introduce yours?
8 MR. CHANNAHAN:.Jeffff Channahan with 9
the As s o c 'i a t e d 'P r e s s.
10 MS. HANSKI: Karen Hanski, with 11 Channel 11.
12 MR. PRINCETON: Harvey Princeton with 13 the Public Service Commission.
14 MR. BIALIK: Ezra Bialik with the New 15 York State Attorney General's Ofrice.
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16 17 MR.
LAWFORD:
Larry La wf o rd with the 18 Kirpatrick rirm representing Surrolk ecunty.
John 19 Birkenheier is from my firm also.
20 I delivered a letter this morning to il Mr. Glass this morning, which states that suffolk
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22 County rcrmally objects to this meeting.
We want 23 to make it clear we have requested meetings with i
1 24 t r.e RAC over and over since early this year and 25 FEMA, for whatever reason, has declined to allow z,
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1 us to
. ave.that kind of meeting between o u r.
2 experts and the RAC experts.
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We f o rmally reiterate that request.
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W e' think it is very surprising, arter all our i
5 requests have been turned d o w n',
that LILCO is 6
granted this meeting.-
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One other thing I would like to just
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~ say.
While I understand that comments from the q
9 p'ubiic shouldn't be entertained, Suffolk County is 10 not just t h'e public.
We have been an active 11 participant and we think that we should be allowed 12 to make comments also on this meeting.
13 MR. KONIESKI: Sir?
14 MR. BRAND: Rick Brand, Newsday.
f, 15 MR. KOWIESKI:You gentlemen with the 16 camera?
17 A VOICE:
Channel 11 news.
4 1
t le MR. KOWIESKI: Berore we start our i
19 discussion, RAC comments on the LILCO Transition
' f 20 Plan, Divison III, let me give you a brief 3
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Il oackground on the RAC review of the LILCO b
22 Transition Plan for Sho reham.
23 On December 30, 1083, LILCO provided 24 RAC members and FEMA with a complete set of plans, 25 revision three.
By January 16, 1984, RAC comments
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on the LILCO Transition Plan 'fo r Shoreham were 2
received by our FEMA regional office.
FEMA a
3 initiated consolidation of RAC comments.
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4 on January 20, 1984, the Regional-Assistanc'e Committee and our consultants met in 5
6
.New York C'i t y to deliberate and consol'idate 7
planning and review' comments.
8 The RAC reached consensus o,n. i t s plan 9
review d o c um e rit.
Between. January 20 and February 10 10, 1984, the ddeument was carerully reviewed ror 11 consistency and finalized.
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12 On February '21,
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1984, Frank Patrone, 13 FEMA Reg io n II director, transmitted the RAC 2
14 comments to FEMA headquarters office.
15
'I n early March FEMA headquarters 16 office transmitted the RAC comments to the Nuclear 17 Regulatory Commission.
And then NRC furnished 18 LILCO with a copy of the RAC comments.
19 As was already stated, LILCO t
20 reviewed the RAC document and requested this 5
21 meeting.
22 What I suggest today is that we go 23 over the RAC comments element by element.
Any I
24 1 discussion will be limitd to NUREG 0654.
I still 25 maintain that we review only t r. e LILCO plan and we s
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will entertain comments only from LILCo.
A,n y 2
other parties willing to meet Qith this committee, 3
or FEMA, I would s u g g'e s t again the discussion will 4
ce' held my. counsel, FEMA counsel, and counsel ror 5
the party who would like to participate.
6 If you people from LILCO, if you do 7
not have'any comments or questions on any P
particular element rated adequate or inadequate 1
9 with need for additional work, you s t'a t e so, 10 saying that we would like to receive a 11 clarification of what needs to be done.
l 12 As I stated, we will not review a'ny 13 material.
Any new material has to be submitted to 14 NRC and only NRC through FEMA NRC Steering 15 Committee may request the a f o rmal RAC review.
16 Let me proceed then to NUREG 0654, 17 planning criteria.
Whenever you are ready, please 18 let me k n c,w.
19 MR.
IRWIN: I think we are ready.
I 20 have two preliminary observations.
First of all, 21 we are grateful for this opportunity to meet with 22 the RAC.
We understalad that there are going to be 23 no approvals of any kind, conditional, final or 2/
whatever.
What we are interested in is a 25 technical interchange on the items indicated in t
t
11-1 the ' RAC revkew and LILCO's provisional responses 2
to them.
3 We have prepared a matrix which goes
-4 down the RAC review item-by-item and which 5
indicates by summary the nature of LILCO's 6
. provisional response.
We believe that this'would 7
be a useful working document to help us go down 3'
the meeting.
You should not, consider it a rormal 9
submittal'.
We would be happy to take it back 10 arter the meeting o r do whatever you want.
It i s' i
11 simply a working document that we have assembled 1
12 to grade our work.
13 LILCO has done a considerable amount 14 of work since receiving the RAC review and we hope
!t 15 this meeting 'will help expedite the. correction of 16 those deficiencies that are necessary before a 17 rully graded ~ exercise can be conducted, as was 18 foreshadowed in Mr. Speck's letter of April 26.
19 So, Dr. Kowieski, if it would be 20 useful ror us to pass it out to any members of the 21 audience, or whoever else.wants to receive a copy 22 or this matrix, we will be happy to do it.
We-23 think it will help ceganize the meeting.
If you I
24 would rather not, we can proceed also.
l 25 It is your call.
We are prepared to 5
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start from the beginning.
-2 MR. KOWIESKI: Let's recess for a 3
moment.
4 (There was a short recess.)
5 5
MR..KOWIESKI: Ne can resume the 6
discussion.
I request the RAC members, as well.as
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7 our consultants, FEMA staff, not to mark up a copy 8
of this. document, which will be returned to LILCO
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9 r'epresentatives at the end of our discussion.
10 MR. DAVERIO: If I might, if I could 11 explain what it is that's on here, it may help and
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12 everyone will understand what we have done.
13 No actually have two tables here.
14 The first twelve pages of which address items 15 rated inadequate in the RAC comments.
And at the 16 end of those twelve pages there are another three 17 p a g'e s which discuss items graded adequate out that 18 necessary. revisions had to be made to nake it 19 adequate.
So we have broken it out into the two
' 20 items.
21 If you let me go across the columns I 22 will explain what we did to make this table up.
23 A
1-A, as we all know, is the NUREG 24 OG54 retcrence, a rid I assume that's the order you 25 intended to go down.
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1 MR. KOWIESKI: Th'a t ' s correct.
2 MR. DAVERIO: The parenthetical.
3 expression 1 through 4 were the four items that 4
- LILCO, in i t s' review or the RAC comments, relt 5
were required to be modified to make A 1A adequate, 6
. from the inadequate stage.
7 It is also, just so no one feels that 3
we tried to copy'the RAC comment, that it is our 9
interpretation of what wo think RAC was looking 10 ror.
It may not exactly fit what RAC was looking 11 tor, and that is part of what we would like to, of 12 course, determine today.
13 The next column which says " Resolution" 14 is a brief description.of the anticipated actions, 15 or actions already taken in draft form, by LILCO to 16 the LERO plan to respond to the RAC comment that 17 is to the.left of it.
18 The tourth column called Pages or 19
" Plan / procedures effected," it is just that.
It l
i 20 is what we intend to revise in the manner 21 discussed in the resolution.
I think that may 22 help everyone understand what this table tries to a
23 do.
24 It Anyone has any questions on that, i
f 25 I will be glad to answer them.
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MR, KOWIESKI: If I u n d e r s t a n d,. you 2^
did not necessarily use our comment directly.
You 3
tried to paraphrase, or in an abbreviated f o rm you-4 presented this in the column "RAC connent."
5 MR.
IRWIN: That's correct.
In most 6
cases i t-is a verbatim excerpt.
What we have done 7
item-by-item in the RAC comments is to take 8
item A 1A as an example, what you will see is that 9
the rirst two paragraphs don't appear at all in 10 this matrix t r. a t we have prepared because we 11 understood that to be foundation from the RAC 12 comments.
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13 The first observation or an observed 14 dericiency appears at the beginning or the third 15 paragraph.
That has become item one on our item A 16 1A.
So what we have done is we have looked at 17 your comments, tried to analyze what we thought le you had in mind when you said there was a 19 dericiency, and proceeded from there.
20 MR. KOWIESKI: Your interpretation is 21 correct.
22 MR.
IRWIN: Why don't we just start at 23 the beginning.
24 MR. DAVERIO: Mr. Kowieski, I don't 25 know what you intended to do now.
Did you want us
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to start at one or did you wa'nt us to start 2
somewhere?
We have some basic concepts of what we 3
thought the RAC comments had.
If you have a 4
dirrerent way that you want to proceed, we will 5
proceed however'you would like.
6 MR. KOWIESKI: Have I suggest that you 7
explain to.us as to what you intend to a c c o m p l i s h~.
8 MR.'DAVERIO: In g e n e r a l-terms?
9.
MR. KOWIESKI: In general terms, and
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10 s o m e r. o w again paraphrase what you are saying here 11 so we will understand.
12 MR. DAVERIO: 'Just as a summary 13 purpose ve had, besides going through this, felt 14 that the RAC comments really rell into six broader 15 categories t h~a n each of these items.
And what we 16 categorized as interrelationship of actual or 17 potential. groups participating in the plan was one lo categcry we lumped a bunch of RAC comments in.
l 19 Examples would be the actual Federal 20 response comments you had or the potential 21 participation by Suffolk County or New York State 22 comments, which you did have.
23 We generally saw three protective 24 action decision-making general c o m r.c n t s, ono or 25 which had to do with radiological assessment and 5
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monitoring; one had to do with plant p r o t e c.t i v e 2
actions based on plant conditions rather than 3
radiological conditions; and the third one had to
.4 do with the ingestisn pathway protective actions.
5 The third broad category of comment 6
we saw was letters of agreement and all the things 7
that could fall out
'o f that.
That appears many 8
places in the R A C - r.e v i e w.
9,
.The fourth one basically tell into 10 what we called the decontamination in hospitals.
11 The fifth basically had to do with 12 potassium i o d'i d e and its potential use during an 13 emergency.
14 The sixth general category we saw was
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15 relocation.
16 At this po i nt we are willing to go 17 down the items in the 0654 reterence one-by-one 18 with you in the two categories I have just 19 discussed.
p 20 Fo r the record, I would like to note 21 there was a third category of adequate with 22 suggestions.
We have not had the time to go into 23 t.. c s e.
Ir you intended to discuss these, we are 24 tio t prepared to discuss those today.
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25 We are willing to do it either way,
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1 go one-by-one, or we have already in our'own mind 16 planning er.iteria 2
broken the.16 categories conhider two 3
and all the subparts into what we 4
categ: ries,- items which we would like turther i
5,' '
clarlfication on, or items we believe important 6
and should be pointed out to RAC for their 7'
potential. comment or clarification.
3 We can do it that way or we can go e
9 down it o n e-b,y-o n e.
We have already prioritized 10 which order we would like to talk in but we can go 11' one-by-one.
1.
12 (There was a pause in the proceeding.)
13 MR. KOWIESKI: I suggest that we take 14 the second option and just discuss the items on 15 which you need'our clarification.
16 MR. DAVERIO: The way we have broken 17 it
..wn, it will work out somewhat similar though
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13 we won't go th ro ug h every paragraph of 0554.
Ne 19 will talk planning criteria A,
and pove to B.
We
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20 will talk specifically on certain sentences in 0554 21 and we may talk in genera 1 about something because 22 it falls in three or four different places within 23 0554.
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14 So, under planning criteria A,
which 25 is Assignment of Responsioility, the rirst place t
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1 that we'need some clarification from the RAC, 2
. t h o ug ;n based on our interpretation we have down on 3
our table what we think would respond.
RAC, in 4
its cpements, said we should address federal l
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.5 agencies 'In t.e r m s of'their response'tc'the
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emerg,encies.
W'e have characterized that Al-A3.
6 21, What we intend to do for that it 7
R is o n' the top or page 2 of 60 of the RAC review.
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9 What we intended to do to address that item is to 10
.basicsly put into the LERO plan a summarization of 11 the feheral radiological response plan as 12 contained,in the Federal Register Notices, that e
13 used do ce called the Master Plan.
What we need to know from RAC, were
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14
.c 15 those the types of things that you were looking at ti 16 or ary you looking for a different type of k (
17 response in that area?
A 10 MR. KOWIESKI: That's the type or 19 response wefare looking for.
And whatever you are T
wo u l'd 20 proposing appears reasonable.
But again we 21 have to review the document.
22 MR. CAVERIO: We understand the exact 2'
language has to be reviewed.
k' e are 1 coking for s
24 t r. c plann16g concepts so we know w h e t r. e r to go 25 back and start at ground zero or are we heading on f
t.
19-1 the'right track.
I think what we were 3
looking ror also there is if any ind iv id ual a
agencies specifically were going to be called in 5
to support, that those resources be identitied.
I 6
think you have a c.ouple of agendies that you do 7
specifically identify.
8 So if there were any other ones, 9
identity 'those.
10 I think as far as the FRERP was 11 concerned, I don't think you need to go in and de 12 that because that is available.
13 MR. DAVERIO: It is my understanding 14 the plan as it now exists has a description of the 15 rederal agencies we would consider as needing
'16 assistance from.
I read the RAC comment to go 17 turther and say:
Well, what if you needed lo a s s i s t a n c e., what would they be able to do and how 19 wculd you contact them?
20 What we plan to do is put a step in 21 that "if you need to n o t i. f y, " and I won't say this 22 is the example, but Aggers & Marx, there is a 22 phono number and a slight description tron t r. e 24 master plan of wr. a t they could do ror you.
That's 25 the type, or thing we are looking at right now.
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1 The second major area, though.this 2
one is one that falls sort of n o t. to one speciric 3
RAC comment, though it is mentioned in many RAC it is A3, but 4
c:mments as letters or agreement 5
it'is also mentioned many. times for many diffe. rent 6
things.
7 MR. KOWIESKI: Fo r Element C and 9
others.
9 MR.
DEVERIO: I am only going to try 3
10 to address i t-once and then we won't talk about 11 letters of agreement again.
12 And the clarirication we have to the 13 get from RAC is we have or we will propose a 14 concept of three different types or support
~~
15 organizations, as we see it, that could be 16 construed as supporting the LERO plan.
The first 17 of which would be what we call contracts.
And 13 what we will derine contracts in the next revision 19 to the plan, as it stands right now would be 20 private companies providing services on short 21 notice.
22 Examples of that would be bus 23 companies that we de have contracts with and 24 ambulance companies that we have contracts with, 25 helicopter services which we have contracts witn.
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i The second categ'ory would the letters s
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or agreement / memoranda or understanding.
.This 3
would be with nonprotit public o r g a r. i z a t i o n s or h
4 other utilities.
It wouldn't be a contract.
It
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'would be some type of letter of agreement or S.
.m'e mo r a n d um of understanding.
7 The third type of support 3
o rg a ni z a t i ors would be the federal mandated E
3 9
organizat' ion, and that we just previously L:
10 discussed.
a 11 I guess the problem we are having 12 with letters of agreement'or understanding is 2
and I will use an example to see if RAC 13 best ij 14 can give us some guidance on this.
The American 15 Red Cross b e i'n g the example that I will use, l
16 though we could probably talk about others.
17 From my discussions with the American 18 Red Cross.and other people's discussions with the 1
19 American Red Cross of Suffolk County, their 20 chapter, they teel that they are mandated to 21 provide relocation c e n t e r, s e r v i c e s if a disaster 9
22 occurs.
'And because or that position did not feel 23 it necessary to provide LERO or LILCO with a 24 letter or agreement stating that they would de 25 that.
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It is their position since t h e.y are 2
mandated to do it, they.would do it, and they j
3 don't intend to, because they don't feel it is n
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2 necessary to, provide us the letter.
.1 5
Tho'second level of that is they have letters of' agreement with relocation centers, 6
7 between the Red. Cross and a specific place.
They
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9-feel that. that is'a private agreement between them
.9 a'n d that person and they don't feel that obligated
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10 to piovide that that to us either, though they 11 said they will activate the Red Cross activate h
12 the relocation centers as the Red Cross would do I
.anywhere, because they are mandated to do it in 13 i 14 their opinion, and would accept a letter from us 15 stating that, which we did send.
16 I believe it was in the plan.
And it 17 came back to us as, I believe, an open item, still.
18 I don't' know how we can pursue L
19 closure on that given the Red Cross' independence 20 from anyone in this room.
We are really looking 21 for RAC guidance on how you approach or what your 22 interpretation is to approach those type of 23 problens.
l 24 MR. KOWIESKI: What I suggest is you 15 submit copies or letters of agreement between j
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various reception centers and the Red Cross for 2
our review.
3 MR. DAVERIO: The Red Cross has told 4
us that's a private agreement between then and 5
that reception center, and we are not privy to get 6
.a copy of it.
But they F. ave given us assurances 7
that they have them and they would activate them.
8 MR. KOWIESKI: So, again, if you can 9
provide us.with'.a copy of that letter saying that 10 letters of agreement exist between various 11 racilities to be used as a reception center and 12 that, however, this is a private matter and we t-13 will not release it to the public.
6 14 MR. DAVERIO: That goes to the second 15 p'roblem that 'they brought up and that they don't 16 reel it is necessary ror them to write me a letter 17 telling me that, because they are mandated to set 13 up reception centers it there is an emergency, or i
j 19 any disaster.
We get in the problem ot the Red 20 Cross-- it states it is the only volunteer 21-legislatively chartered a.gency and its mandate is 22 to help in a disaster and help set up relocation 23 centers.
i 24 MR. K0WIESKI: We do understand your 25 concern.
However, this Regional Assistance 2
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24 1
Committee did not create the requirement.
.It is a 2
requirement or NUREG 0654, whidh is what we are
, going by.
3 l
4.
MR. DAVERIO: I guess you don't find l
I 5
the letter r com us to them confirming it.
I will 6'
explain U at h
we have.
We'have a letter from us to.
7 them explaining what our understanding of what 8
they would provide is; no response back to us 9
against that.
10 MR. KONIESKI: We understand.
11 MR. DAVERIO: The second thing is they 12 sent us a copy of what their national policy 13 unsigned, just sent us a copy or the national 14 policy and said that's what we will respond 15 according to.
16 MR.
IRWIN: As I understand it, that l
17 national policy clearly covers the kinds of 19 actions which we would expect the Red cross to l
l 19 undertake.
F 20 The long and short of it is the Red l
21 Cross has told Chuck any number of times that they 22 will do their duty and their duty consists of such 23 things as opening relocation centers.
They told l
l l
24 us they have agreements with these relocatien l
25 centers.
They don't reel that they can be
>f i'
I
c r
25 4
P c.
i 1
compelled to turn over those' agreements and they
.~
2 don't want to provide us with anything special in 3
writing beyond what their basic policy is.
4 They have told us any n u'o b e r of times c
5 they will execute that. policy.
And we believe
-6
.them.
7 MR. KOWIESKI: The. letter of agreement 8
with the Red Cross is only.one issue.
The second 9
issue ishe l e't t e r s of ag reement between various t
10 racilities to be used as reception centers.in i
11 LILCO.
I 12 MR. DAVERIO: According to the LERO i
13-plan, LILCO doesn't activate any reception centers; i
i 14 the Red Cross activates them.
That's our 15 understanding of how our plan would be c.arried out.
16 MR. KOWIESKI: However, your plan i
I 17 states that certain facilities will be used as i
19 relocatior) eenters or reception centers.
And i
19 according to NUREG 0654 we need the letters of i
i 20 agreement.
{
l 21.
MR.
DAVERIO: The problem is that i
22 those are listed in the plan based on j
23 representations by the Red Cross to us as to what l
2?
tr.ey would activate.
u I,
I 25 MR.
KOWIESKI: You understand our i
=
l i.
26
.I l
1 p o s i. t i o n.
I don't think we are going to re. solve 2
it right now.
3
. ful. IRWIN: L e t.
me make sure I 4
u n d e r s t,a n d your position.
You are not saying that 5
even though we don't have a direct agreement with
. have to get a letter of 6-the relocation. centers, w e' 7
agreement with them?'
We don't have a direct legal S
relationship with those centers; we have a 9
relationship with the R e d' Cross which, in turn, 10 has a relationship with the relocation c e n t e r s ',
11 and the re is no way it would make sense for us to 12 get them.
- -~
13 MR. KOWIESKI: The Red Cross will 14' establish relocation centers.
In addition LILCO 15 or LERO will have monitoring teams checking for 16 possible contamination.
17 MR. KELLER: It is not strictly a Red 19 Cross center.
I 19 MR.
IRWIN: What you are interested in 20 is agreements with respect to the monitoring?
21 MR. KELLER: The use of the facility 22 and making sure evervthing is okay.
23 MR.
D A '/ E P I O : We will go back and 24 discuss this r u r t r. e r with the Red Cross.
25 MR. AIDIKOFF: Let me ask a question e
I 27-1 to clarify.
Are you saying relative to the extent 2
to which LERO would use this relocation center, 3
1.e.,
f o r monito ring, possibly decon, possibly a.
s 4
s to ra g e of t' hat type of. equipment, a letter of 5
agreement to support that effort as opposed to a 6
- letter or agreement to support it as a relocation 7
center, which is in fact ~ done by the' Red Cross, is 9
appropriate?
I 9
I am trying to narrow the issue.
10 MR. K0WIESKI: Our point, and again 11.
let me reiterate, our point is very clear.
We 12 want assurance that a facility identirying the 13 plan will be available as a relocation center
+
14 during an emergency.
That's our concern.
That's 15 what we ask for.
If we ask for letters of 16 agreement with the Red Cross, you said no, they ld e
17 are not willing to release that.
We are asking l4 18 you to let the Red Cross write to us and they are l'
O 19 not willing to do that.
f-L 20 MR. DAVERIO: We may be willing to do 21 it.
Maybe they will write to you, and I have not l-22 broached that question with them.
I will go back 27 and bring that up.
We can pursue that with them, I
l 24 ir that is acceptacle or one alternative.
I 25 MR. K0WIESKI: It is one alternative 5
?.
1
,vw--,
-~.
28 9
1 that we would consider.
2 MR. DAVERIO: I guess one other one, 3
though, under letters of agreement there are a few-4 that we would'like to get some clarification,on.
5 Laboratories.which provide environmental sample it has the listing 6
analysis, that falls under 7
under A1.
8 MR. KOWIESKI: If you can identify the 9
page number.
10 MR.
D AV E RI O :.It is page 10.
11 MR.-AIDIKOFF: We are looking at two 12 different documents.
13 MR.
DAVERIO: It is page 10 of the RAC
~
14 review.
15 MR.
IRWIN: Item 6 of A lA.
16 MR. AIDIKOFF: Page 4 of 12 item A 36 p
17 on the matrix.
18
.M R. DAVERIO: We don't think that's l,
19 necessary or, at most, a reference to our 20 contracts with la bo ra to ri es is part of our on-site 21 emergency plan or the normal LILCO contracts.
It 22-those are the types of things you are looking for, e3 we can do something in that area.
p l'
i
'24 MR. KELLER: I think in the plan you l
[
25 say that these racilities, these companies are l
i I
i i
L
{
__q 29-
~
l available.
There is nothing'in the plan which 2
supports the fact that they are available.
3 MR.
IRWIN: In other words, the 4'
contract that we have with them would be evidence.
5 of that?
6 MR. KELLER: That would be fine.
7 MR. DAVERIO: We can accommodate that.
8 One other one that I know has oeen 9
oroached before, because I was at a meeting where 10 it was discussed, not specific to Shorehan,but in 11-general, the letter of agreement.
At least I
-12 haven't talked to the regional office at 13 Brookhaven recently on this, but it had been their 14 position to us that they would only give us the 15 standard letter that everyone got in the country, 16.
and it appears to us that one-RAC comment -- at 17 least one.of the RAC comments in A 3 and on our 19 l table it a.ppears as our parenthetical number 5 19 MR.
IRWIN: In the RAC report itself 20 it is in the last paragraph of page 9.
21 MR. DAVERIO: The people from DOE have 22 told us that's the same letter they give to 23 everyone in this region, and at the tine we l
\\
24 discussed that letter of agreement with them they i
25 relt that was all that was required to justify tl
j 3n 1
their response.
I don't know that we can get 2
anything rurther from DOE, and I am just looking 3
for RAC guidance in that area.
s 4
MR.
KELLER: I think, and I may not be 5
correct, that Mr. Schweller.of DOE, Brookhaven, 6'
has filed an attidavit with the SLB board, and I 7
think that may resolve the issue.
3 MR. DAVERIO: It mayout it is not 9
considered a letter of agreement.
10 MR. KELLEP: This discussion on t t. e 11 b bottom of page 9 of the RAC review is a 12 claritication, and I think that affidavit may I haven't seen it yet, but it may.
13 indeed 14 MR. KOWIESKI: We have to see it yet.
15 MR.
DAVERIO: I guess one that we also t
16 need some clarification en appears on page 10 of I
17 the RAC comment, the last paragraph, and it 18 relates to our attachment 311-1.
311-1 was put 19 into the LERO plan really just to list the i
l 20 laundromats, the hotels, the restaurants; anything 21 on Long Island, where someone who was on Long 22 Island who didn't know Long Island might want to 23 know where to rind.
Figuring you may need to know, i
l 24 it there was an emergency, ir you wanted to wash l
l 25 elothes, you would want to know where the
[2 I
t I
t
. =
~"
31-1 laundromat is.
2 It appears you are looking fo r a 3
letter of agreement with all those people and I 4
-don't understand that.
5 MR.' KELLER: I think it interrelates 5
.with th'e comment.on the RAC comment C-lC,.or page 7
'12 of the RAC comments, the bottom of 12.
8 MR. DAVERIO:
We.- we r e going to ask for 9
clarifica' tion on that when we got to it.
10 MR. KELLER: This is what it is all 11 about.
If some of the federal agencies respond, 12 and in the case of EPA, which is the example we 13 showec here, had may have some special.
.14 requirements, and their requirements are available 15 to everyone.
They will let you know what they 15 need ahead or time.
If you are going to ask them 17 to respond and to help, they need some help trom 18 you.
19 MR.
IRWIN: So, in other words, this 20 goes back to your observation a few minutes ago on 21
' the delineation of respon.se by federal agencies 22 generally.
23 FR. KELLER: Yes.
24 MR. IRNIN: As to rederal agencies we 25 are specirically intending to rely on, you are i
(
32 1
interested in. making sure that we know in a,d v a n c e 2
what preparations they need us'to take.
3 MR. KELLER: That's right, and if you 4
have taken these preparations and can support them.
'S MR. IRWIN: A-17 and'C-lC are all 6'
based on the original comment.'
7 MR.'KELLER: All, intermeshed.
S MR.
DAVERIO:.So basically you are
~
we might as well do C-lC while 9
l'o o k i n'g for.us 10 we have it nos, becau'se what we have here won't 11 respond, in our matrix, won't respond to that 12 comment we just got trom P.AC's consultant.
13 You are basica31y looking for us for 8
14 the federal agencies we consider a response 15 required, DOE being one, NAA, EPA 16 MR. KELLER: The point is that under 17 FRERP, after the emergency phase is over, the lead 18 role passes from 90E to EPA.
Theretare, EPA is i
19 involved even though you don't have them 20 specirically as a separate agency.
21 MR. DAVERIO: The concern we had, and 22 we can address the EPA ones, is there a master 23 list that is used for the tederal master plan or 24 the new acconym t r. e y have for it, that tells us 25 everytning we should be looking for to assist any i
I
33-i 1
rederal response.
2 MR. KOWIESKI: I suggest you write a 3
letter to each federal agency requesting what they 4.
need in case there would be need for their 5
response.
5 MR, IRWIN: Would you suggest this'go 7
to each of the agencies indicating in the FRERP or 3
simply to the ones that we think are ones we~would 9
actually
'l i k'e to rely on?
There are a lot of 10 agencies in there,'they are available, but we 11 haven't necessarily tactored them specifically 12 into our needs, such as the Department of Defense 13 ror instance.
14 MR. KOWIESKI: We suggest that you 15 send a letter to each federal agency identified in 16 the Federal Emergency Response Plan, and ask what 17 do I need, 18 MR.
KELLER: That they intend to use.
19 MR.
DAVERIO: I think that covers the l
20 broad topic of letters of agreement.
One other 21 comment I guess that RAC had that we have a little 22 bit of a problem understanding exactly what they 23 want, it is on our page three, parenthetical 24 numcer four, wh i ch is on RAC page 9,
third 25 paragrapn, last sentence.
The plan does specify
- t..
g 3 t.
4 s
't 1
1 the number of bus drivers in the o rg a n i z a t i.o n 2
chart contained.in Chapter 2,
specifically figure i:.
~
ll 3
2.1.2--wrong one.
2.1.1.
4
-That rigure'has, in a little box in 5
the right-hand column, the number or bus drivers 6
for a one-shift coverage.
If you look in the 7
right-hand column, it is added.up.
It has e
confused people, including us, ror
- a. period of 9
t'i m e.
10 Let me get to the r i g h't page so I
'c a n 11 do it.
What this chart shows is there are 108 bus 12 drivers that we would have at the Port Jeff 13 staging area to be sent out to drive cuses, 100 at 14 Riverhead and 125 at Patchoque.
15 I As stated.on page 3 of our table, it
-16 is our intent to have 150 percent of that, 17 approximately, trained and lice'nsed with New York 18 State licenses.
19 If that's what would you would like l.
20 somewhere in the plan, we can put it in.
21 MR. AIDIKOFF: It varies.
22' MR. DAVERIO: It varies cut that's the 21 goal, 150 percent.
l-
~
24 MR.
KELLER: Some statement that you 25 nave -- you have 333 bus drivers here.
+
i
~
35-J' L
1 MR. DAVERIO: R i g'h t now we have 450
?
2 licensed New York State ones.
3 MR. KELLER: That you have that many C
4 trained licensed drivers.
5 MR. DAVERIO: We can put that in the
.6
. plan someplace.
7 MR. BALDWIN: It would be helpful to 8
put in 150 percent or the buses. you expect to have.
9 MR. DAVERIO: Just an overall goal,
'10 anything that was a one-shift emergency function, 11 ous drivers, traffic guides, they were staffed to f,
12 approximately the 150 percent level.
Shift work
,i 13 was three shifts.
?
14 MR. KELLER: That would be helpful in 15 a discussion somewhere.
16 MR. DAVERIO: We can put it in the 17 plan and discuss that cencept.
That was a 18 planning goal.
19 That concludes any clarification we 20 relt, t h o u g r., again, dirferent issues jump at 21 diftetent times.
We may. discuss something when we 22 get to H that also ralls in A,
but we saw it more 23 important when we got to H.
6 l
24 As rar as we are concerned, we have i
25 covered what we want in A.
If you have any t
o
1 i
3G I
i 1
questions on anything, we would be willing.to, of 2
course, answer them.
3 MR. KOWIESKI: We don't have a 4
question.
5 MR.
DAVERIO: I mean what we have i
6 discussed, are there any questions before I move 7
on?
8 MR. KOWIESKI: Does RAC have any 9
comments on whatever was said?
~
10 MR. KELLER: I'want to state on the 11 record that even though this matrix has a numoer 12 of resolutions shown that we have not discussed, s
-2 13 we have not evaluated those.
14 MR.
IRWIN: That's absolutely correct.
15 This is a preliminary internal working document 15 that LILCO is using, which we simply passed along 17 today to help organize the discussion.
18 MR.
DAVERIO: Planning criteria B is, 19 or course, recused on-site and it is our 20 understanding that RAC doesn't review for 21 compliance.
22 MR. KOWIESKI: That's correct.
23 MR.
DAVERIO: Moving to planning 24 criteria C,
which is the energency response and 25 resources, we have the only clatirication we 2
I
A
~
- 37-F
!! ~
l needed on C-lC.
So we don't'have anything else to y
n' 2
discuss under C.
3 Planning criteria D,
Emergency d
4 ;
Classirication System, at least trom an inadequate
+
i 5
point.of view there were none.
There may be one J
6
.later on in the second chart when we get to that.
7.
I didn't get to that or correlate them together.
8 We address inadequate from adequate, the necessary l
9 t fixes separately.
l J'
8 i
10 '
Planning criteria E,
Notificacion si',
11 l Methods and Procedures.
Again, as far as inadequate
[
12 we did not see any there.
13 j Planning criteria F,
Emergency 14 Communications, we do have a few to talk about.
I 15 think we have~ generally talked about it earlier, 16 but let me make sure I have it right.
We stated l
17 earlier we were going to put some discussion in on 19 the new FRERP -- I was just getting used to master i
i 19 I plan what we intended, as I previously stated, l
20 was to put a summarization in of that, and in OPIP 21 3.3.2 notirication, we are including for the 22 director of Local Response to call those agencies I
23 with an asterisk, it required.
i l
24 I think we have discussed that, i
t l
25 O.
Turning next to planning criteria I,
l 1.
L.
39 l
I 1
which is Accident Assessment.
There are
- a. couple 2
of things in here we would like to discuss.
One 3
being the concept of PARS, Protective Action 4
Recommendations, based on potential degradatien of 5
plant conditions.
We intend to address that in 6
two methods.
7 First, we have a new position in LERO F
envisioned.for the next amendment entitled " Nuclear 9
E n.g i n e e r.
That service will be provided by a 10 contractor, and they are providing a quali:ied 11 person to fill that position on a 24-hour basis, 12 similar to what we do with our radiation health 13 coordinater.
14 As a matter of fact, it is with the 15 same firm.
16 We also will modify OPIP 3.6.1 to 4
2 17 include a chart that is used as part of the on-18 site pl a n,.wh i ch has predetermined pretective 19 actions to ce considered when a general emergency 20 is considered.
it has four ranges.
It is a it is a chart
(
21 chart -- I don't have it here 22 that has three columns:
The protective actions, 23 core conditions, et cetera.
That is what he would 24 be using to analyze an emergency cased on a l
25 machine status rather than radiological status.
i l
f 1
l
39-l t
1 MR. KELLER: My s'uggestion is you not 2
only revise OPIP 3.6.1, when you talk about who 3
interacts with LERO, this is spliced in there also.
4 MR. DAVERIO: I celieve OPIP 3.6.1 is
'5 whe2 e that would occur.
6-MR. KELLER: You also have the concept 7
7 operations and he has tc be factored in.
8 MR. KELLER: I think also that in 9
your --
I' forget wr. i c h OPIP it is, where your job 10 descriptions are, that his qualitications ought to 11 show up there.
12 MR. DAVERIO: What we will do when the 13 contract is tormalized, it will go into B with the 14 resumes of the people to fill that position.
15 MR. KELLER: You have the thrust.
16 MR. DAVERIO: Moving on, the thrust we 17 got of what we have as parenthetical two, and let 18 me see if.I can MR. KELLER: Page 23 of the RAC review.
19 20 MR. DAVERIO: Thank you.
28 or the il RAC review.
We i n t e r p r e t, this to be the statement 22 in our procedure that says that if there is no-23 core danage, don't worry about reading the filter 24 paper where particulate matter might ce picked up.
25 MR. AIDIKOFF:
I-9.
t t.
Bn 1
MR. KELLER: You jumped to I - 9 ?.
2 FR. DAVERIO: Sorcy, I did.
It is I-9.
3 I am on that one.
Excuse me.
4 MR. KELLER: Fine.
5 MR.
DAVERIO: It was our understanding 6
th.at the concern was that there may be an 7
elemental iodine, or some particulate matter that R
m i'g h t be on that tilter t h'a t we weren't taking 9
account of, and our procedure would be modified to 10 remove that statement so you always check the i l paper for particulate matter.
12 MR. DAVERIO: Is that the thrust of 13 what RAC'was looking at?
14 MR. KELLER: That's the thrust, yes.
15 For that part.
You have more the next page.
16 MR. DAVERIO: There is a second page.
L 17 The second part is I-9-3, I believe, which is the I
1.
19 "rurthermore" statenent, which rollows the I I l
19 statement we have just discussed.
It falls under I
20 two and three, I guess, and it relates to the l
21 nomogram that we have in.our procedures.
l 22 The first one, and this we will t
23 discuss for awhile, we are net exactly sure what t
24 you have listed in the bunch or parameters, and 25 maybe RAC could explain how they see those r i 1
t l
i i
41-1 parameters.
2 It is the end of the f u l l-paragraph, 3
"Such as moist tiltration, distance trom the site, 4
et cetera."
We are are not sure what all that 5
means, particularl.y "et cetera."
6 MR. K EL L E R : I think.that your 7
resolution covers it.
When you prepare a nomogram, 8
this is. simp 3-a way to multiply numbers together 9
graphically,' right?
10 MR. DAVERIO: That's correct.
11 MR. KELLER: You had to make certain 12 assumptions to establish a slope of the name on 13 the nomogram, is that right?
14 MR. DAVERIO: Yes.
15
'M R. KELLER: What this listing of 16 parameters at the end of the RAC comment on page 17 29 alludes to is t r. e fact that those parameters 18 may affect the assumptions that you have used to 19 make your nomogram.
I think what you say in your i
20 resolution is you are going to put the assumptions 21 in.
So now we know w h e r e.
these things came from.
i l
22 Now, insofar as the assumptions you 23 used difrer t ron an accident you may have, there 24 is going to be a bias introduced by the nomogram, i
l 6
l 25 and hence the last line in the RAC comment.
i 3
i
+-
.--e,-a w
a
,,---m
L- :.
..-.L I
42 1
I think we have addressed t h i s, in 2 l another place again all or this is intertwined
~
we have suggested that you 3
as you recognize 4
expedite' the return or sanple media to your place
.5:
-o f analysis.
And it is this suggestion which 6
helps you out of this dilemma.
Beca.use in the
~
7 rield you are there making rapid assessment.
8 However, recognizing there may be i
9 some bias introduced, you get those samples back 10 ror rurther analysis as quickly as possible.
11 Later on, and I can't remember where 12 it is, we.have a suggestion that you expedite that.
13 I think your resolution looks reasonable at rirst 14 o l u s h',
that you are going to list assumptions.
1 15 MR. DAVERIO: It is an overall 16 responce, the on-site emergency planning 17 organization uses the same thing and they probably
- 18 would be getting it back to their on-site lab rast 19 and we would have that data to work from.
We also 20 have a post accident sampling system, they have 21 samples that would give you a feel from the site 22 as to what mix you might have.
23 l So you do have ways of getting it.
24 MR. KELLER: I understand.
The other 25 thing I think should be factored into this, that 1
l l
e:
'..._ :._L. _ _. _
._... _. ~
43 1
you only need to worry about'this concern above 2
some trigger level.
Ir the doses that you project 3
are 1 j MR, 2 MR, there is no great need to do pr'ojecting 4
anything.
Ir you are on the order of 1 5
REM or 5 REM, something like that, then you might 6
.want to have a trigger level to expedite this 7
particular filter analysis.
8 MR. DAVERIO: I think that's very a' d we understand what we have to do to 9
helprul n
10 resolve that.
11 Moving on to what we have as I 10-2, 12 which is contained on RAC~ comments page 30, about 13 the deposition velocity, we believe, as we state 14 on our matrix, we believe that is a conservatively 15 high velocity'.
What it is really used for is to 16 get your field teams to potentially the right 17 places.
19 We also have suggested we will add an 19 IIP 210, rour ground deposition surveys once we got 20 there.
21 MR. KELLER:,I agree that's a high 22 deposition velocity.
The cnly difficulty I see is 23 that ir you use a very high deposition velocity, 24 in ceder to maintain material calance, you put tec 25 much down in close and, therefore, you project l1 t
,..m.
.9 Se 1
less further out.
2 Just consider t h e ' c p t'i o n s.
3 MR.
BORES: When you are dealing with 4
wet deposition, or course the.05 may not be 5
conservative.
6 MR. DAVERIO: Wet deposition would be something you would know about, though, because 4
9 you know it would be raining probably.
9 Are you talking about some other type 10 of wet deposition?
11 MR. BORES: But you are still 12 calculating'a deposition and, first or all, you 13 con't knou whether a.l y t h i n g is deposited.
You 14 have to know what the releases are to rind out
~
4 15 what form they are in to find out whether or not 16 they'are deposited.
So.05 may or may not be 17 conservative.
18 MR. KELLER: The major thing is you 19 r.a v e added a rield survey with your i.
L 20 instrumentation.
Be aware of the calculational 21 assumptions.
'o 22 MR.
DAVERIO: What we understood by it f
23 is it pays to start 1 coking.
It nay net be a I
24 perrect place but it is an estimate of where to 25 start.
If you round you were way of:, ycu would
?
l l"
a
d t
m_.
4 45 1
adjust what you were doing.
2 I think that helps us.
3 That completes any discussion we had 4
on planning criteria I.
5-Moving to planning criteria J,
x did you have any questions 6
. protective action 7
before we move on?
8 MR. KOWIESKI: No.
9 MR. DAVERIO: Sorry.
.J. 2 - 1 I guess is
~
10 the rirst place.
This is one that has caused us 11
.some confusion, particularly because as far as the 12 LILCO on-site plan, which'I think is what you are 13 talking about, when we evacuate any of our on-site i
14 people there are alternative sites within the site 4
15 to miss the p'l um e, but the plan always takes them 16 up one access road.
]
17 What we intend to is to write 18 s c m e t h i n g,. i n the plan that says that.
-By the 19 makeup of our site, that's the plan that we have m
=>
20 had.
iS 21 The reason for that is we have a M
22 remote decon center aceut a mile away at a 23-substation which is on our access road, which we 24 make everyone go oy.
It is on the main road ort 25 the site.
they may not stop there, of' course, if 5
y
.J ik av s
?.
1
.the' plume is there.
We may s'e n d them to other
)
2 remote locations but they all go cuc that one way, d,
3
.always.
N P~
4 That's what we are going to put in S
the plan, g
6 MR. KONIESKI: 'Your response appears 7
reasonable, if you can state this in the plan.
8 MR.
DAVERIO: The next one we would S
9 like to d'iscuss or get clarification, if possible, 10 on, or maybe some help is J10 B-1.
It is on page 11_
32 ot the RAC comments, page seven or our table, 12 and it talks about " Subarea beundaries for q
13 evacuation."
14 Maybe it I have a moment I will 15 explain it.
The evacuation plan, we would never 16 evacuate a subarea within F.
You either evacuate 17 all or F or none or F.
..g.
18 The only reason we have subareas is 19 twofold.
One it simplities the bus routes for F 20 because F is a very'large area, so is K which is 21 the other one you-have re.ferenced.
22 Secondly, because of its large area 23 it orake out that way rcr access for people in 24 those subareas to get to the major evacuation 25 routes.
We have no plan ever to evacuate a sucarea.
?
4
'J t
)
4?
+
/I-l 1
It is either all of F,
all of K,
or none of each 2
or those.
That's what stated in appendix A.
More 1
3, public relations than to be put in the protective A
^
4
' action brochure.
4 u
5 MR. BALDWIN: The background,of 6
information you have given us we could not find in 7
the plan.
8 MR.
IRWIN: It seems like the comment p
9 was proceeding based on a misapprehension of what s
10 was required.
11 MR. DAVERIO: I can put the statement 12 I made into the plan.
We didn't intend to make a
~
13 modification.
14 MR.
BALDWIN: When we evaluated the
~
15 plan we saw the breakdown for areas F and K,
and 16 we were looking, therefore, for a breakdown on the 17 large map, the told-out map, which would then have 19 led us to.the correlation in the plethora of maps.
I 19 MR. DAVERIO: We can put a sentence or 20 two in that summarizes what I said in probably 21 eight sentences.
22 MR.
BALDWIN: And it should De in the 23 cross reference, too.
That gets us to all or it.
24 MR. DAVERIO: Yes.
i 25 One we need clarirication on, J 10 B-2, i
I A.
a ?-
l n
.1 which is the last sentence on page 32 of the RAC 2
comment.
Are you just looking ror a map that 3
s: nows.the-population in each zone?
Because what 2i 4.
we have is a table and a map.
You would like the 5
numbers on that table to appear on the map?
6 MR. BALDWIN: With this clarification, 7
you s e e',
now it becomes evident how it fits
'S together.
t 9
MR. DAVERIO: We have the map done, so 10 i t. is not a problems 11 MR. KOWIESKI: So you will have 12 numoers, population distr'ibution indicated on the
- 4 13 map?
14 MR. DAVERIO: Both in a tabular form
~
15 and on the map.
16 MR. AIDIKOFF:'In each zone.
17 MR. KOWIESKI: The NUREG requires both, 13 the t a b l e..a n d the map.
,3 19 MR. DAVERIO: First we would like to 20 talk about J 10-E, one and two, which basically is 21 the issue of potassium iodide.
22 MR. KELLER: It is shown at J 10-C'on 23 here.
l 24 MR.
DAVERIO: It should be J 10-E.
I 25 The C was a typo.
It is contained on page 34 of 1
I
~
E.
]
9
~
I l
the RAC review comments.
2 l Our plan, in the rie x t revision, we i
3 will give one tablet to each worker as they leave 4
the staging area to go into the field.
As also 5
stated, our tablets right-now have an expiration L
6 date marked or J_ne 1985.
7 MR. KOWIESKI: The last ones we knew 8
were'out.cf date.
[
9 MR. AIDIKOFF: We contacted them.
10 MR. KELLER: No problem.
11 MR.
DAVERIO: Moving to J 10-H, which 12' appears on page 37 of the RAC review.
Based on 13 '
discussions with the Red Cross, we are in the 14 process or modirying the plan because or their not 15 being able to get letters of agreement with, my 16 understanding, stoney Brook or Surfolk County 17 Community College.
They do have an agreement with 19 BOCES, t h e.y have told me, and they have three 19 other places that they have agreements with, all 20 of which are greater than 15 miles away.
21 So the next_ revision to the plan will 22 show no relocation centers less than 15 miles trom 22 the site, approximately.
I 24 I think the nearest one is 25 approximately 16 miles.
t
(
+
-5 0 -
l 1
The Red Cross h a's told us those four 2
are Saint Joseph's, BOCES, Islip, Downing College, 3
and SUNY, Farmingdale.
The plan will ne modified 4
to rerlect that in its entirety.
5 MR. BALDWIN: That's responsive.
What 6
we would also like as an aside to this,.several 7
~ people have mentioned, and'I can speak for myself, 8
I would like ror you to supply a map for scale and t 'se location's of these relocation centers on it.
9 r
10 MR. KOWIESKI:
T'at's very important.
r
}l We try to use engineering skill and there is no 12 way to determine the distance of various 13 relocation centers on the map from the plan.
14 MR. DAVERIO: We will take care of 15 that.
16 I guess the next one that we would
(
17 like to discuss is J 11-1.
Actually it is one, 19 two, three and tour, which basically are ingestion 19 pathway issues.
They are on page 41 or the RAC 20 comments.
21.
I guess the,first one is we are not 22 aware, rrom our maps and our scales, that Rhode 23 Island iu within 50 miles.
I think it is aceut 60, i
24 and we did not intend to include it in the i
25 ingestion pathway.
j t
.. _ _ ~.
51 t
1 MR. KELLER: Agreed.
If you look at 2
the RAC comment, not this one sut later on, it was 3
in one or the earlier plan revisions.
And since 4
there is no map or 50 mile EPZ in the plan, we 5
couldn't t e'l l whether it was'50 miles or not.
6 We have since made some measurements 7
and we agree it is greater than 50 miles.
- However, f
8 I might. suggest that you might want to<put.a map
~
9 of the 450 mile EPZ in the plan.
10 MR. DAVERIO: J 11-2 talks about 11 imposing protective procedures, such as 12 impoundment.
What we intend to do is we have a 13 letter that Connecticut has written to New York 1.4 State basically saying that they would respond to
~
15 a utilities or a licensee's request for assistance 16 in the ingestion pathway.
17 So as far as Connecticut is concerned, 13 we would assume the Connecticut plan would be the 19 applicable document based on that letter.
20 Within the New York State boundaries, 21 the next revision-to the, plan will identify that 22 we will issue radio messages identifying the areas il of concern and offer to compensate anyone with 24 economic loss due to withholding that rood trom 25 the market, i
t' l'
F s,
52-1 In addition, aid could come - th rough 2
the f e d.e r a l response also.
3 MR. KELLER: I think what you are 4
saying is reasonable and that will.be included in 5-the plan, this e x p a n.s i o n ?
6 MR. DAVERIO: Yes.
7 MR. KELLER: If you have this letter 3
trom Connecticut, it belongs in-B.
9 M R'. DAVERIO: Yes.
We got that since 10 the last revision to the plan, il MR. DAVERIO: If I wasn't clear, the 12 letter trom Connecticut is to New York State 13 saying it would respond to a licensee's request; 14 it is not to LILCO.
We will include that letter 15 in the next r'e v i s i o n to the plan.
Just for 16 clarirication.
17 MR. KOWIESKI: We would need a letter 19
- rom Connecticut to you saying that they will 19 respond to your request.
20 MR. DAVERIO: As was pointed out toEus, 21 when we asked for that letter they sent it to New 22 York State.
I don't know if that's tecause they 23 reel that's the proper protocol.
But they may l
24 tell us the proper protocol is to write that 25 letter to New York State.
1 I
i
~1 n
53 1
MR. KOWIEL I: We have to evaluate the 2
letter.
3 MR. DAVERIO: We will provide that 4
letter to you in the next revision for your 5
ev a l u a t i'o n.
6 Turning next to the comment we have 7
as parenthetical three,.we have worked up over 60 8
payments of listings of dairies, farms, food 9
processing plants which are or will be in the new 10 3.6.6.
We also have, for use in our EOC, a map of 11 a 50 mile EPZ boundary, with all of them located 12 by colored coordinated dots and a manual that 13 tells you what each of them are.
14 Those were gotten through working 15 with the Suffolk County Agricultural Extension 16 Office and using computer lists that they provided 17 to us, and then verifying those lists.
19 MR. KELLER: Your resolution appears 19 responsive.
20 Is it possible to supply to RAC a 21 copy or this map o r a reduced version of it?
22 MR.
AIDIKOFF: I can right now supply 23 you with the 50 pages of listings which ecerelate 24 to the map.
The map is about the size of this 25 coard.
I
. --~
.... a.. G.
54-1-
MR.
IRWIN: We will make a photograph 2
'o f it.
3 MR.
DAVERIO: The problem is what we 4
have done on it is correlate the different 5.
facilities in different colors, and it is a hard 6
. board that we did.
We can make a 35 millimeter 7
slide of it-for you.
8 The next one we would like to talk
' hat we call parenthetical 4,
food 9
accut is w
10 processing plants outside the 50 mile EPZ, which 11 which process tood originating.
What we have 12 tried to do is the food processors in the listing 13 that I have discussed are 70 miles from Shoreham, 14 We think this is an appropriate 15 response s i n e'e we don't feel much will be grown 16 inside and sent outside to be processed and 17 shipped back to New York.
By including the extra 18 20 miles we think we can address the RAC's comment
-19 about rocd being sent cut to be processed and then 20 sent back in.
21 MR. KELLER: I don't think you 22 misaocerstood our problem, I don't think.
23 MR.
DAVERIO: J 12-2 would be the next 24 one, on page 42, the second paragraph.
Based, on 25 what we state as page 9 of our table, we have 90
+
s.
l 55 i.
1 radiation monitoring persons deployed to the 4
2 relocation c e n.t e r s.
Assuning about two minutes 3
per monitor, to monitor a person, we envision you 4
could_do approximately 32,000 people in twelve 5
~ hours,Lwhich is more the 20 percent of the'EPS 6
which the relocation center capacity is 7
established for.
That's for a full ten-mile 8
evacuation.
9 The RAC comments seems to say it is 10 questionable that it can be done.
What I am 11.
looking for is as to why that is questionable.or 12 what did RAC have in mind?
13 MR. KELLER: Some of these people in
~ - -
14 relocation conters are monitoring vehicles, 15 according to your plan.
16 MR. DAVERIO: I believe the procedures 17 have them worrying about' people first.
13 MR. KELLER: All we are saying is to 19 evaluate, and as you are going to include some 20 kind or design basis on how many extra drivers you 21 are going to have, put in a rationale of how you 22
'got there trom here.
23 MR. DAVERIO: I think the plan right 24 now has some or that prioritization in it.
I 25 think it says you park the cars in an area, do all t
l
- ~.,.
.--,..-. :;...,_... w..., - _
~.,,,--,--.
l 56.
1 the' people and worry about the cars later.
We 2
will go back and look at it and make it clearer if 3
there is a proolem.
'4 MR. KELLER: Cars are one thing, then 5
you have monitoring ror contamination.
If people 6
.are found to be' contaminated they go under a 7
shower and they are remonitored.
That's separate 8
Iron the people coming in.
9 W h'a t we are saying is, at least the 10 way we look at it, it was questionable whether you 11 had enough there to get the-job done.
What your 12 design basis, what your assumptions were would be
~
13 helprul to ce put into the document.
14 MR. DAVERIO: We will put more of the 15 logic and background in the plan.
KOWIESKI: Ofr the record.
13 (There was a discussion off the 19 record.)
20 MR. DAVERIO:
J.
12-4, I guess the i
il problem we have with that is the Red Cross has a 22 890-page document on disaster services regulation 23 procedures, disaster health services, ARC 305n I
24 that they give us when we asked for this.
Is that 25 what you are looking to be put into our plan, or a a
I 57 I
i 1
reference to it, or something?
2 MR. KELLER: Your tour, tive and six I
1 kind or are meshed together.
~ us.
4' MR. AIDIKOFF:
f
-: 5 MR. KELLER: Again, back.to the 6
discussion from this morning, the American ~ Red 7
Cross, runs these centers but there is a LERO
?
function g o i tig on at the centers.
How is'that 9
interface tied together?
Do the LERO people 10 report to the Red Cross people, do they report to 11 LERO?
What is that interface, which we couldn't 12-
' t i rad in the plan?
13 Secondly, this registration form, you 14 do talk a bo u t what you are going to do with people
~
15 who are found to
'c contaminated.
We think it is 15 equally important to have a reco rd of people who 17 were examined and found to be not contaminated.
13 Part or your problem is that you have J
19 a clean tag, which is new.
That's just part of it.
20 MR. DAVERIO: I think we understood b
il that.
If it is not the ARC 3050 document you want
[
22 but if you want a command and control statement l
27 ;
cetween the two organizations, we then understand I
2 t.
w r. a t you are l o o k i rig tor.
25 MR. KELLER: Yes.
I think if you go f
t
o.
5 59 i*
sy.
1 back to the RAC comment it s a'y s "more information 2
needed on. Red Cross responsibilities and I
3 procedures in the centers."
.4 In light of fact you have these two 5
functions at the.eenter.
6 MR.'IRWIN: What does'LERO do and what 7
does Red Cross do, and if there is is a point ~of 2
9 interface, t-9 M R'. KELLER: Yes.
Another thing comes 10 to mind which may or may not be in the training 11 session.
Because of this interface, as you have c
12' stated the American Red Cross routinely runs 13 relocation cente rs and does a fine job, no
- r..
0 14 question about it.
But this is a little bit 0'.-
15 different sit'uation because of the interface with e
16 LERO functions.
This may get into a training
.i
-17 aspect.
18 MR. DAVERIO: What has occurred in our e
19 training program, we produced a rilm on relocation a
20 center operation and activation, which the Red 21 Cross told us how to do and it was all Red Cross 22 people doing it, that we train our LERO people' 23 w i t r..
24 MR. KELLER: We would like to see in i
int'rface wcrks, and it there is L
25 the plan how the e
2 O
-q v
59 r
K 1
an interface, make sure the training is 2
appropriately listed.
j
?
}
3 MR. DAVERIO: We will take care of'it.
4 Turning to planning criteria K,
5 Radiological Exposure Control.
I figure we could f
4.
6 probably get t h r o. u g h K,and then maybe break.
7 I-think we will discuss K and as we 8
have tour items to, discuss, that will probably 9'
t'a k e us to five to 12.
10 MR. KOWIESKI: How many more questions 11 do you have on L,
M or o?
This will guide us as 12 to whether we should break for lunch around 12 or I
13 rinish.
i
~
14 MR.
IRWIN: I think it would be 15
-sensible to break ror lunch simply oecause we want 16 to try to take up the conditional approval stuff, 17 and there is no way we will be able to get through 12 all that.,
19 MR. KOWIESKI: That's what we are I
20 saying.
It we can rinish with whatever was graded 21 inadequate and then break. for lunch and start 22 tresh.
23 MR. EAVERIO: K SA-3 is the first one, 24 which appears on page 45 or the RAC comments.
I 25 guess the problem we have is we don't know of any f
(
1iWe-a 60 p
1 other rederally or any approved limits to put into 2
the plan except those contained in Reg Guide 106, 3
and are looking for clarification o.r guidance as 4
'a s to.what you-neant by not using those numbers.
5 MR. KELLER: I am just trying'to
+1 6
.rigure'how you broke your one, two, three down 7
here.
8 MR. DAVERIO: Three is the last 9
p a r a g r a p r..
10 MR. KELLER: What we are trying to say 11 is you have two taoles, 391 and 392.
12 MR. DAVERIO: Right.
13 MR. KELLER: 392 are the contamination 14 levels taken out of Reg Guide 1.86, which is the release or licensed activities.
15 16 What we are saying is in 391 you have 17 one level of' contamination.
You have a person who 19 is contaminated ir the count rate exceeds 120 19 counts per minute.
It is a long way f rom 120 to 20 what you say is acceptable ter release.
21 What I am saying is there is a 22 divergence between what you say is contaminated 23 and what you say is acceptable te ce released and i
24 reused.
t s
1 25 MR. AIDIKOFF: What we are trying to e
t
. o a
i 41 J
7-1 explain here on 392 is it is not so much fo r 2
release; it is ror re-entry t o i-ouildings and 3
areas as opposed to a person coming into a
= :.
4 relocation center f o r mo.n i to r ing, a nd then
[,
5 subsequent release after decon.
We would 6
appreciate guidance.
7 MR. KELLER: There is an EPA group who 8
is currently developing recovery re-entry, 9.
relocation, restaffing guidelines.
To my
-10 knowledge, and mayce George can help, there are no 11 specitie numbers available as of yet.
12 I think we understand the pecblem, 13
-there io no guidance, as except for this 1.96.
14 That is a very low number.
I think 15 the point we were trying to make in the RAC 16 comment is that we seem to see a divergence of 17 what you call contaminated and what you call 18 acceptable to release, because I think those words 19 are in the plan.
20-MR. AIDIKOFF: I agree.
We can 21 clarity-that.
4 22 MR. KELLER: That's the RAC comment.
23 There is another issue that we would 24 like to have some guidance on, and that is what 25 L3uld oe acceptacle numbers, and I am not going ts t
t j
w.
ig 52-
}t. '
l 1
answer that.
l 2
MR. BORES: One of the problems with 9
3 9
3 using 1.86, it has oeen designated ror use as c
3 4
decommissioning facilities.
By definition this is c
5 long-lived stuff, been there ror' years and years; 5
.whereas in an accident situation you may have a j
7 population which has been relocated or dislocated, 8
it you will, and you need to get those back in to 9
avoid economic type concerns as well as get the L
10 families back together where they belong, that 11 sort or thing.
12 The second aspect is in an emergency 13 type situation I would guess the culk of the 14 activity might be short-lived stuff.
So you might 15 be dealing wi'th a difrerent spectrum of activity.
16 They are two different things.
17 Whereas the other you have a long 18 time, n o t..a n emergency situation, with 1.96.
I 19 kn w some or the states have developed sone 20 re-entry criteria and maybe that's the way you 21 ought to look at it.
Based on the potential 22-exposure, RAD exposure or REM exposure over the 23 next six months, aver the next year based en 24 re-entry.
25 In other words, you move people out 9-4 e-
+ -, - =
,w-m--+-
,--,,,w,
-,-e++
--*-w
-e-e,
7 63 I
1 based on an exposure potential or the savings 2
potential when you enact the PnGs.
3 So they are.looking at the same sort 4
of concept when you move them back in.
The 5
numbers might be lower, but you may also, in those S
. numbers, weigh the specific aspects of the given 7
accident.
So it is based on exposure rather than 8
contamination levels.
9 MR. AIDIKOFF: Instead of DPM value 10 you are looking ror an assumed exposure value for 11 six months or twelve months, a dose rate at that 12 point assuming. continuous exposure?
13 MR. BORES: If you have short-lived 14 material, decay rate, weathering, whatever it is.
1.5 But you ought to lay out the criteria or the
~
16 assumptions that you are going to be using for 17 that.
19 MR. AIDIKOFF: One cuick question.
A 19 recent FDA document, 1983, rerers to some 20 Department of Transportation values in millirem.
21 I am wondering if you are aware of that.
They are 22 saying there is kind of nothing we know about it 23 except'ror transportation accidents and then it i
24 gives something.
25 MR. KELLER: Is this Schlein's fi t
7..,
64 I
N 1
document?
t 2
MR. AIDIKOFF: Yes.
3 MR. BORES: I can't comment on it.
4 MS. FELDMAN: Joyce Feldman.
I would 5
add one thing.
As far as the EPA draft that was 6
h a n d e 'd out to the Conference of Radiation Control 7
program members, the thrust there is to project 8
total dose for long term exposures.
So you would 9
be depend'ing on the nuclides and based on 10 inrormation on what has been released and what has 11 been deposited in areas rather than any speciric 12 count rate or dose rate, 'because you are looking 13 long tern.
14 MR. AIDIKOFF: You are looking at long 15 term dose.
D'o an isotopic analysis?
16 MS. FELDMAN: Yes.
This is a decision 17 that wouldn't be made in a 24-hour period.
lo MR. KELLER: These tables appear at 19
.wo places in the plan, and the discussion is fine 20 and valid.
But we jumped rrom decontamination of 21 emergency reworkers to recovery /re-entry.
This is 22 decontam levels for emergency workers.
23 M P.. AIDIKOFF: We will clear that up.
24 I agree with that.
25 MR. KELLER: We just jumped into M.
t t
u.
65 l
1 MS. FELDMAN: I am sorry.
2 MR. AIDIKOFF: Thank you for your 3
point.
4 MR. DAVERIO: The next one we would 5
like to discuss is K 5-B,' parenthetical two, which
^'
'S' appears on page 46 of the RAC.
We are not exactly l
7 sure what the concern is over alpha activity
'a MR. KELLER:-Because your plan says 9
that-probe detects alpha activity.
I looked it up
'10 again'and it says that ard I would like you to 11 take it out.
12 MR. DAVERIO: That's fine.
13 MR. KELLER: Since it is inectreet as 14 your modification says.
15 MR. DAVERIO: We will fix that.
16 The next one would be K 5 B-3, we are 17 going to modify the plan to talk about sending is decontamination equipment supply storage or water, 19 I guess, would be there, to the shoreham site to 20 be used excuse me.
21 (There was a, pause in the proceeding.)
22 MR. DAVERIO: We are going to use the 23 Shorehan site to handle solid waste.
As just 24 pointed out to me we would try to dilute the 25 liquid waste and dispose of them.
If they
+
s.
r-
~
66-1 couldn't be diluted, then the'y would be shipped to 1
Shorehan.
3 MR. KELLER: The comment says you have 4
not addressed what you are going to do with waste.
5 Your resolution says it.
6 MR. DAVERIO: The next one would be K 7
5 B-5.
I guess the clarification we wanted is 9
8 that this appears under a section that's really a'out k"i t s.
.Are you just looking for us 9
talking b
10 to provide places where first aid kits would be 11 available in the EOC, the staging areas?
Is that
~
12 the type of intocmation you are looking ror to 13 close this one out?
14 MR. KELLER: If you go back to the 15 criteria elements, it may help clarify the RAC 16 comment.
17 MR.
DAVERIO: We read that provision 18 to be add (essed by our procedure 4.2.2.
19 I an sorry, 3.9.2.92 is 20 decontamination and 4.2.2 is transportation.
21 MR. KELLER:,I t may be that thic can 22 be addressed by a revision in the cross reference 23 and an explanation.
But it seems to me, when I 24 read K 5-8, that you ask ror means for i
25 decontamination purposes, including wounds, t
w-i
-}
t 67
!-t 1
supplies, et cetera.
We understand you are not 2
going to do hospital type-things but first aid 3
kits.
Do you have that available?
4 MR. DAVERIO: II you lock at the 5
racilities at LILCO and there are first aid 6
kits there if you are looking ror us to say 7
that and provide detail what's 'there, we can do 9
that.
9 MR. BALDWIN: I think the -cross 10 rererence shows the equipment list in t f. e 11 procedures is very detailed.
So that would be 12 helprul.
13 (There was a pause in the proceeding.)
14 MR. DAVERIO: I Won't go through L 15 because we have no questions for RAC on L.
I 16 think some or M-1 we have already discussed and we 17 don't need to go into it anymore.
10 The next place is M-4.
I guess while 19 we say in the comment there we have a procedure, 20 let me phrase a question.
Are you looking ror a 21 procedure that is done du. ring the event or are you 22 looking for us to have a model that would allow us 23 to, in hindsight, go back and calculate this?
l l
l 2/
Because we have a procedure now 4
I f
1
\\
an.
1 MR. DAVERIO: Th a' t helps.
2 MR. KELLER: This is a recovery and 3
re-entry criterion element, planning standard.
It 4
is primarily what you are going to do.
My
'he plan you 5
recollection of what we could find in t
6
.said, you wou)3 establish a g ro up to do' this.
7 That really leaves a little thin how you are going 3
to'do it.
4 MR. DAVERIO: Let me explain my 10 proolem.
There are two methods or doing it, in my I am trying to 11 opinion.
The one we have got 12 get some guidance of what you think on the issue.
13 I am not saying it is the tinal.
Trying to 14 calculate the total population exposure during the 15 event.
That would be taking the evacuation 16 coordinator and every hour try to have him 17 estimate what is happening out there.
18 The second method of doing it would 19 be something like using an acronym, the MIDAS 20 system, which has the transportation mode on tcp il or it and at the end of an accident you put the e
22 inputs in and you get a numcer out.
23 I am not s u r's which methodology the 24 RAC Committee is looking tor.
2c MR. KELLER: A methodology rather than t
^
,l
w e.-
=. -.
~
l "9
i 1
none.
This is your plan, right?
2 MR. DAVERIO: Yes.
3 MR.
KELLER: The criteria element is 4
specific, w h i e r, says there should be a way to 5
estimate the-population exposure.
We couldn't 6
rind it in the plan.
7 MR.
DAVERIO: We have two options.
We 3
will to choose one and put it in our plan, I guess.
9 MR.
BORES: Let me indicate, in terms 10 !
of population exposure evaluations, there may be a 11 number of methods tied together because not one 12 method is probably going to get everything ycu 13 need.
There Will be refinements out there 14 procaoly should be some estimate during the event 15 as well as the overall picture.
15 By the time you get to the overall 17 picture there will be 50 estimates provided by 50 I
la d i f f e r e n t..o r g a n i z a t i e r.s.
19 MR.
DAVERIO: After en event everyone 20 will have our own estimate et what happens.
21 MR. A I D I K O F F.:
Part of the input we 22 need is how do you project this number ceing used, l'
and that would give a tine requirenent which would 24 give us an indication of what method would oe more i
25 appropriate.
A i.
k am
70 1
MR. KELLER: I th' ink the criteria
'j 2
element says that you have to describe a method.
C-3 MR. AIDIKOFF: All right.
4 MR. BORES: If you are looking at a 5
frequency, I don't believe an hourly estimate is 6
. going to be practical ~ because your data is going it is going to take you longer.than that 7
to be 8
to gather the data, so you are not going to be 9
precise anyway.
10 So you probably should be looking at 11 it daily, or something.
12 MR. DAVERIO: I think based on where 13 we a r e,.n: could probably finish within the next 14 five minutes, but we would like to take a minute 15 just to talk before we.go on.
16 (There was a pause in the proceeding.)
17 MR. DAVERIO: We are ready.
1 P, We have one general one to cover 19 which we would cover as part.
01-B.
That one 20 appears many times, or at least three times that I 21 can recall across the comments.
It has to do with 22 local law enforcement agencies a id fire 23 departments, and other people, a 1d snow removal I 24 think is anuthe r one that appe.rs somewhere in i
i 25 her.
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We would like to cover, and 1
-(-
2 everything that was in the RAC' Committee on that, E
3 at this point, and not just the training.
- Because, y
4 as I said, they do jump around somewhat.
5 As stated in our plan we do not rely 6
on these agencies'just mentioned to do anything 7
.than their normal function.
Therefore, we did not g,
8 include letters or agreement with them.
Though in
'i 9
t'he next revision to the plan we will make the n
10 orfer tc train them.it they so desire to be 11 trained.
We still do not see the necessity to get 12 letters of agreement with them.
We will offer 13 them training, as stated in our column there, but 14 we don't see a need for the letters of agreement.
S 15 MR.
IRWIN: Maybe the police 1
s l-16 departments and fire departments and your local 17 fire departments on Long Island and snow removal 18 tall into,different categories analytically.
The 19 one thing that is common to all et them is that we 20 don't rely on any of them to perform any special 21 radiologically related duties, and we don't ask 22 them to undertake any special radiological risks 23 Or to expose thenselves to radiation in any 24 rashion dirrerent trom the general puclic.
i 25 That's the framework or the cackdrop f
t
72 l
~
in addition to the 1
against which we perceived 2
ract that the Suffolk County Police Department as 3
an ageney of Suff'olk County is not going to 1
l 4
cooperate with us in any event, or has not t
5
. indicated they are willing to, I think it.is
-. 6
-impo r tant 'tha t you realize we aren't relying.on 7
them for any radiologically related duties.
t 8
That's the backdrop against which all 9
of these comments are framed and maybe we ought to 10
'take them one-cy-one.
That's the reason we don't 11 have letters of agreement with them or any other 12 special arrangements.
13 MR.
DAVERIO: Also in response to the 14 RAC's earlier comments, we are including it they 15 did respond,~ decide to respond, and how they could 16 do it, as an early comment on it.
That's a a
17 separate issue.
19 MR.
BALDWIN: There are really three 19 issues here that we have identiried.
The first is 20 that NUREG specifically says that these groups, 21 local response agencies 22 MR. DAVERIO: Can you give me a page 23 rererence?
24 MR.
BALCWIN: Yes.
75,04 D and G,
25 local support services personnel will be trained.
.L.. Ll,.
i I
l 73 A
i 1
MR.
IRWIN: That's no problem since we 9.
2 van orfer t r a i n i n g.'
You can lead a horse to water; 9
3 you can't necessarily make him drink.
Some of 4
these agencies are, as you understand, agencies of 5
the suffolk County government.
The Suffolk County 6
' government said it will not undertake any 7
cooperation with LILCO.
We can offer them 9
training, but if they refuse.co accept it there i s.
9 not much we can do about t h a t '.
That's our only 10 p r o b l' e m.
11 We are happy to offer the training i
n 12
.and we think they know it.
If they don't, they
- . 3 soon will.
q 14 MR. K0WIESKI: That's our concern.
Ir
~
15 you to rely on the police, Sufrolk County police 16 or. local snow removal agencies, firefighters, we 17 want to make certain they will be tried.
19 MR.
IRNIN: There is a big word in 19 there, two letters long, and that is if."
The
-q 20 important part of our plan is we don't rely on 21 them to perform any duties, other than their 22 normal duties under conditions where the general 23 puolic would be allude to be where they are 24 physically going to be.
That's an important 25 threshold matter.
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MR.
BALDWIN: T h a' t comes to our second 2
concern.
The language in the text does not make.
3 those assumptions clear enough and specifies 4
enough.
5 MR.
IRWIN: All right.
6 MR. BALDWIN: And the third issue is 7
one that is addressed in that response, and that 1
8 is the if they are required to perform their
~
9 normal duties under the conditions of a 10 radiological release, they need to be supplied 11 with radiological equipment, dosimeters, CLDs, 12 they need to know how to read them and they need 13 to know what risks they are exposing themselves to.
14 MR. DAVERIOt Do tney have to know how 15 to read them ~or do we have to provide coverage for 16 them, or is that the same thing?
17 MR. KOWIESKI: They have to understand 18 the procedure.
At a certain level they have to 19 contact their supervisor and ask for direction as 20 to what to do, return, come back to the office, or 21 continue my duties?
22 MR.
IRWIN: We can envision the 23 rollowing kind of sc ena rio.
We continue as we do 24 now not to make any kind of assumptions that any i
25 of these organizations will be available for t
i
75 i
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I 1
service in any area other than those which.are
=
2 accessible by the general public in an emergency.
a 1
They don't fill any radiological functions.
4 Second, they will not agree to accept
' hough t
we offer it 5
any radiological training even 6
at t h 'i s point.
7 In the event of an accident there is 8
a possibility that the services these people night 9
be volunteer, and the question is how do we covar 10 that ir they have not had advanced tra'ining S
11 because they have refused to accept it or for any 12 other reason.
13 One possibility is that qualified 14 personnel could accompany them who know how to 15 read dosimeters.
I 16 That is in fact a way of providing t'em.
That is one thing that we can consider.
17 ror r
18 We will do whatever we can.
You can lead a horse 19 to water but you can't make him drink.
Tr.at's the 20 problem we have.
21 MR. KOWIESKI: We again refer you to 22 the-plan, page 2.2-4 entitled, " Local law 23 enforcenent agencies and fire departnents."
This 24 language was a concern to us and we recommend this 25 has to be some clarified.
s
i l
76-t J
l The way it stands right now it is
(
2 inadequate.
3 MR.
IRWIN: We understand that kind of 4
concern.
We can clarity it both to our degree.or 5
reliance and with respect to offering training, 6
and if necessary.back-up means to insure that 7
qualified personnel accompany these officials if 8
they do help us.
We can do that.
9 Would this be a good point to break 10 ror lunch?
11 MR. DAVERIO: I think that finishes it.
12 (There was a pause in the proceeding.)
13 MR.
DAVERIO: No other discussion on 14 the totally inadequate sections.
We have some 15 more on the a'dequate with modification sections.
16 MR. K0WIESKI: I recommend that we 17 will break for lunch for approximately an hour and 13 a hair and convene 1: 45.
Is this acceptable to 19 everyone?
20 (Luncheon recess)
I 21 i'
22 i
23 24 4
25
~
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77 f
1 A F T E R N O O N S E S S I O N.
1
.MR.
KOWIESKI: Are'we ready to
^
L-3 reconvene our meeting?
Is everybody here?
4 We c a rs reconvene our meeting.
5 MR. DAVERIO: This afternoon we would in'terpreted S
like to talk a b'o u t the items that we 7
as graded adequate but necessary revisions were 8
recommeded or required to make the item adequate.
i 9 I MR.
IRWIN: These are the ones where I
I 10 {
the words " adequate provided that" appeared.
11 MR. KOWIESKI: Fo r the record, I want
- 12 to make it clear that this is adequate provided
?
13 you provide clarification or additional 14 documentation.
You know what will happen if you 15 won't.
16 MR.
IRWIN: We understand.
In most 17 cases it was pretty clear what'the RAC wishes to 18 do but there are two or three areas where we would 19 like to get clarification.
20 MR. DAVERIO: The first one would be E-5 21 and our page one of three of the second table that 22 we handed out this morning, 15 of the RAC 23 !
Committee.
24 Just to give you a little historical 25 inrormation or how the words EBS were chosen, it t
t O
78 I
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1-is my understanding from the' people who worked for 2
us in cetting up this system for LILCo, they went 3
to the local EBS Station, the designated EBS 4
Station for Long Island, which would be, I believe, S
They did not feel that they 6
. wanted to get involved.
They recommended thatNn!
7 try to set up a local EBS Network.
8 What we undertook, and'I believe our
?
people talked to the regional EBS Coo rdinato r, was 10 we undertook discussing the concept of a local EBS 11 With the radio stations in Suffolk County.
As we 1
12 state here, we believe we' don't have to change the
'13 use of the words EBS Based on our reading of the 14 FCC regulations and their use of the words EBS.
15 Don Irwin may want to add some legal 16 interpretations.
He is trying to read the 17 regulation right now.
19 MR.
IRWIN: I think it is fair to say i
l 19 that the FCC regulations distinguish between a L
20 local EBS network and a national or other kind of 21 broader EBS network than a local one.
The l
l --
22 national network is set up as a cesult of an EBS i
23 authorization issued by the FCC.
The FCC's 24 regulation, it I understand them, in section 25 73.913 B,
indicates that an EBS authorization is i
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i 79 l
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.T'at's 1
not needed to set up a local EBS network.
n 2
,t h e basis on which we have been proceeding.
3 As a practical matter, it is a 4
conriguration of stations that tunctions, and you 5
know how it functions.
What we are interested in 5
obtaining, rirst of all, is the nature or the RAC's 7
concern.
Is it that we are using the name EBS 9'
without proper authorization?
Is it confusing or 9
what?
Because we have a very practical 10 consideration; that is, the wo rd E29 and the name 11 emergency broadcast system are just all throughout 12 the plan and procedure.
We will probably have 500 13 changes in one kind of document or another if we 14 need to change it.
15 If we do in fact have to change we, 16 cr course, will, but we want to make sure or the 17 casis which you all believe we should change it 19 bef o re we,,make that kind of a global change.
19 MR. K0WIESKI: In our comments, I
20 obviously we stated this concern that you already 21 discussed, the use of EBS, the term emergency 22 broadcast system, which was commonly used by state l
l 2?
or local government.
I 24 I t r. i n k it would help somehow to 25 distinction, to make it very clear that this f
i e
80 1
system has'been developed w i t'h o u t cooperation of J
2 state and local government.
3 Or I have a second option or 4
suggestion.
If you could get a letter trom FCC 5
stating that they don't have any-objections to 6
. usage of this term EBS as it stands right now.
7 MR. IRWIN: I think the regulations 8
are clear but we will also be willing to explore 9
that with'the FCC.
I don't know whether the FCC 10 typically issues opinion letters or that kind but r
11 we will look into it.
12 MR. K 0 W I E S K I': I cannot speak on l
13 behair'of the FCC but you can ask them to 14 interpret the regulations, j
15
'M R. IRWIN: I just don't know what I
16 their interpretation process is, but we will look j
17 into it.. We wanted to you to be aware that we do 18 have in tact a clear legal basis ror using the f
19 nomenclature we have used; and, B,
that it is a l
20 signiticant practical problem, although not a 21 substantive problem to change the name.
l 22 MR. KELLER: Would you repeat the 23 citation again?
I think it was ditterent than one l
24 you have here.
i i
1 25 MR.
IRWIN: Three sections you ought 1
3 1
)
81 I
1 to look at.
Those two which are cited in the 2
matrix which deal with the actual. activation, and 3
those sections state that basically stations are 4
allowed to activate their stations for EBS
'5 purposes it they are on a local network at the 6
local. management's discretion.
7 The section I referred to is 73.913 B,
3 says that "An EBS authorization, which is the FCC 9
o'r d a r, is not required ih order to participate on i
10 a voluntary organized oasis in a state or 11 operational local area EBS."
i 12 MR. KELLER: 913 B?
~
13 MR.
IRWIN: That's right.
It is set 14 forth further in 73.945.
So we think the-three 15 tie in together.
15 MR. DAVERIO: The next issue we would 17 like to address is H-7 and I-7 at the same time.
18 They tie together.
It is our intent to modify the 19 plan to clear this up.
The plan may have oeen 20 what caused the confusion.
There are actually two 21 sets of kits.
There are a set of kits at 22 Brookhaven National Lab which are owned, 23 naintained, calinrated ny Brookhaven !:ational Labs 24 as part or RAP, the initial response.
Because of 25 t r. e location et B r o o k r.a v e n National Lab within the t
d
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EPZ we have also procured and own, LILCO or LERO 2
kits, which we have sto re at our EOC which we 3
maintain, calibrate, and we will clear up the plan 4
to so specify that t h e'r e is a difference and there 5
are two difterent sets of kits.
They don't move G
. kits.
7 MR. KELLER: I think you know what we 8
were thinking.
There was contusion in reading the 9
plan.
10 While we are on this, whit we were 11 discussing this morning about the particular 12 filter measurements, that's at the end of my 7 I 13 see here.
14 MR.
IRWIN: Yes.
15
'M R. DAVERIO: We would like to go in 16 the middle of the two we just talked about, which 17 is H 11, and we designate two, which appears on 19 page 26 c( the RAC comments.
It appears or we get 19 that you are looking ror communication radio link 20 cetween the field team and the EOC.
In actuality 21 there is no radio communication between the DOE 22 Brookhaven teams and our EOC.
The DOE told us-23 that they aould preter to leave the connunications 24 chain between their f'ield team to their 25 headquarters at the lao and then we have put in a
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i 1
dedicated line from that position to where.the 2
Brookhaven person or the DOE person would be a t.
3 our EOC.
4 We had discussions with Brookhaven on
,5 this, and it is our understanding that that is 6
their preferred method.
Because, if you remember, 7
I think one of the earlier revisions of the plan 9
designated a LILCO frequency for the downwind 9
survey teams.
They did not want te proceed that 10 way 11 MR. KELLER: I don't think there is 12 any real problem.
We do understand the primary 13 link will ce between the field teams and their 14 headquarters with their own frequency and they are 15 not going to use your frequency.
There is a 15 dedicated line from their headquarters.
It is our 17 understanding the RAP team captain will have a 18 hand held, radio on the same frequency, a DOE radio.
19 MR. DAVERIO:
If they intend to leave 20 Brookhaven they intend to bring some hand-held 21 radio or some communications to the EOC.
22 MR. KELLER: The P lan calls for the 23.
RAP tean captain to have a hand-held radio.
24 PR. AIDIKOFF: The next amendment the i
25 RAP team DOE will send a representative to the EOC t'
t
84
.j t
1 who will deal via the dedieated line back to the
.2 Brockhaven area orrice.
The Brookhaven area 3
office does becom'e unavailable, they will relocate 4
to the EOC and work out or there, bring 5
communications with them, and at some time that a 6
larger DOE-FEMA response gets set up somewhere 7
else, they will then relocate to that area.
8 MR. KELLER: There is the other issue 9
that.ohere is t'he potential, at least, for LILCo, 20 LERO, to put out their own tield teams.
What i s 11 the communication between those field teams should g
12 they be put out?
13 I think that's what this comment i s.
a 14 MR. DAVERIO: Ir you are speaking C
15 about the LERO field teams and not.LILCO field 16 teams, which is the on-site teams 17 MR. KELLER: N,o t the teams required in 13 Element B.
19 MR. DAVERIO: There are no other
,1 20 envisioned rield teams except the DOE teams in our 1
21 plan.
3 12 MR. KELLER:
k' e have a problem with 21 that.
That's not what the plan says, and I can i
I 24 rind the reference ir you would like, out it will 25 take me a moment.
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MR. AIDIKOFF: The only field teams that are referred to are
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3 MR. DAVERIO: We have a reference to 1
4 radiological environmental monitoring programs 5
that might go out later but I don't know of any 6
plume pathway tracking teams.
7 MR. KOWIESKI: Let's go to the plan.
8 (There was a pause in the proceeding.)
9 MR. RELLER: Do'you have a copy cf the 10 plan?
1 11 MR. DAVERIO: I have a modified 12 version.
Tell me the page.
13 MR. KELLER: 352, line 2.3.
- 7 14 MR. DAVERIO: Mine doesn't read like 15 that.
^
16 MR. KELLER: Unfortunately we den't 17 have yours.
1B (There was a pause in the proceeding.)
19 MR. DAVERIO: In those wcrds, when we 20 talked LILCO teams, we are talking about the 21 Shoreham teams.
22 MR. KELLER: Unfortunately it says the 23 ORS teams.
The ORG teams are defined as the teans 24 that go into the plume, off-site radiological 25 survey teams.
It says these will be augmented if i
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needed.
We just read it.
s 2
MR. AIDIKOFF: You win.
3 MR.
IRWIN: We can clarify that.
j 4
MR. DAVERIO: We have to clarify that.
5 MR. BORES: As a matter of fact, the apparently that's the reason for S
. ort-site teams 7
the kits'up at Brinkwood.
8 MR. KELLER: Why would you have kits 9
at the EOC it you don't have oft site
.t e a m s ? '
Ne 10 t r. o u g h t it hung together.
11 MR. DAVERIO: The truth is those kits 12 were cought early on when we were going to give i
13 them to Surfolk County.
So he had extra kits.
-s
-14 MR. IRWIN: We will clarify that.
i 15-That's no problem.
f
.16 MR. KELLER: Just a moment.
17 (There was a pause in the proceeding.)
19 MR. KdLLER: Based on the discussion 19 that we had, it sounds to us as though there is a 20 signiricant change in the concept of operations or 1
21 how intend to work with the DEO, RAP captain in 22 particular, et cetera.
23 We think we heard scmething different 24 t r. a n what we t r. i n k is in the plan now and, of 25 course, we will have to evaluate it when it comes t,
e 1
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l in but this may change lots et things.
2 What I am saying is if revision Jour 3
has things in it which do not address these things 4
directly, specirically, you may end up 5
MR.
IRWIN: Spawning a different kind 6
of review than otherwise.
7 What is the change in operational 8
concept tha.t you are referring to?
?
MR.
KELLER: To paraphrase, it seems 1
10 to me I heard you say that the DOE RAP captain may 11 not go to the local Brentwood office.
I am sure 12 that the plan calls for a DOE RAP team captain, 13 dose assessment ind iv id ual, environment assessnent 14 individual, and DOS communicators to report to the 15 Brentwood EOC.
I thought I hea rd you say a minute 16 ago you may only have a liaison there.
That to me 17 sounds like an entirely different nethod of 13 operations.
19 Therefore, we are back into a review 20 mode again.
21 MR. DAVERIO: We can explain that to 22 DOE and see what they say.
It was our 23 understanding they would like to maintain their 24 RAP team captain at the point or control or the 25 teams.
That was why, as things evolved, they may
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suggestions to us also on whit they would like to l ?, 4 2
see happened.
O 3
MR. KELLER: This has evolved since g
4 revision three?
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5 MR. DAVERIO: I can't say.
We will go 6
-Dack and look at it and we understand if we make a 7
major change, you have to review it.
We take no S
exception to that.
~
9 MR.
KOWIESKI: I would appreciate at 10 one point when you suomit your plans to NRC, be 0
11 very specific and clear that what has been changed.
12 I am talking as rar as c o'n c e p t of operations is 13 c o n c e r n e d.'
This w.i l l be very helpful to the RAC.
14 otherwise it will be very hard to Fish and look 15 for it.
16 MR.
IRWIN: I think What we will try 17 to do would be to incorporate a table that would 18 take at least a couple of the columns in this 19 matrix so that we will show the pages on which RAC 20 review elements had been attempted to be addressed, 21 and it will also be covered by at lett.er like the 22 one I wrote in front of Revision 3,
which I hope 13 wsn't r.a v e to be long as that one.
24 MR. KOWIESKI: Somehow if you can i
25 organize your letter, saying the changes in the f,
t.
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l } -
1 concept of operation, that's impo r tant to us.
2 Because we have to then receview it.
3 MR. IRWIN: You say any changes other 4
than changes that are simply in response to the i
5-RAC7 6
MR. KELLER: These also.
S 7
MR. IRWIN: We will highlight them.
MR. DAVERIO: We will go back and 8,
i 1
9 review things in light or your comments.
10 I think we only have one more, and 11 that is N 2-D.
It is our understanding trom t
12 talking to DOE that they would participate in an 13 annual practice, exercise and a TE'tA-NRC exercise i.
J 14 and we will clarify that in the next revision of 1
i 15 the plan.
16 MR. KELLER: That's fine.
17 MR. DAVERIO: Let us just check our i:
19 notes b u t,,I think that about does it.
19 There was one item I was reminded of l
i s
20 and it is J 10-D.
It is on the sheet we just went i
4 21 through, J 10, the d i r e c t,o r of Noninstitutionalized 1
22 Mobilely Impaired Individuals.
23 What we have done is we nailed out a l
I 24 card asking for anyone who needs assistance.
We l
25 have results back and have tried to make telephone i
'l i.
c.
90 1
contact with everyone who safd they needed 2
' assistance, and those people we could not make 3
contact with we are mailing letters to.
4 The problem we have is I am not sure 5
that we would want to provide that list of people 6
.in our plan.
7 Are you just looking for a f o rma t 8
that we will. keep this list in and a concept of wil'1 maintain the list?
9 how we 10 MR. MELLER: And where it is.
11 MR.
DAVERIO: We have the same 12 philosophy in an emergency callout list, which I 13 assume doesn't give anyone a problem.
We don't 14 put everyone's home phone number in the plan, if 15 we can help i' t.
l 16 Now I think we are actually done.
17 MR. K0WIESKI:
Are we checking 18 anything else or did you rinish your presentation?
19 MR.
IRWIN: I think we have tinished 20 what we w' anted to try -- the most important of the 21 areas that-we wanted to try to bring up with you 22 all.
I think that most of the rest or the RAC's 23 comments were clear enough that we t r. i n k we know 24 how to go aoout addressing them.
Whether we will 25 do it successrully or not will remain to be seen.
3
+
n a
1 91 I
1 It questions arise I hope that we may 2
ce able, on an issue-by-issue 6 asis, or which I
- 3 3
would expect there would be very few, to try to 4
get intormal claritication as we go along.
I 5
don't.think there will be much of this.
6 If the RAC has any ooservation is 7
they would like to oring up to us, we will be 8
happy to hear.
I 9 i MR. KnWIESKI: Would you like to add 10 anything that was said today?
11 (No questions.)
12 This concludes the neeting between 13 the Regional Assistance Committee and LILCO to 14 d i s eit s s RAC comments on LILCO Transition Plan 15 Revision 3.
16 At this point wb will conclude the 17 meeting and we will allow other parties, it t r. e y 18 are willing to make their points or view known to 19 the RAC, to identity themselves and then we will 20 think about the time frame, how much time we will 21 allow ror each presentation.
12 Does anybody in the audience wish to i
il be heard?
On behalf of 25 Sutrolk County I would like to repeat the t
t
c -
e 93 1
statement made earlier, that'Suffolk County feels 2
it is very important a n'd requests that its 3
technical experts have an opportunities to meet t
4 with the RAC members in order to conduct a i
5 substantive discussion about the substantive and i
6 technical aspects of the review or the LILCO 7
Transition Plan.
8 MR. KOWIESKI: Definitely this will be.
9 taken into considerati:n,.
10 MR.
IRWIN: Let me note one thing.
I 11 have seen some correspondence trom Curtolk County l
12 to FEMA and I believe to RAC members proffering 13 various documents which I guess are represented as i
14 being of a technical nature.
They appear to j
15 consist largely of Suffolk County's profiled 15 direct testimony in the licensing case that is now 17 going on before the NRC.
I 19 Clearly, LILCO doesn't see any value 19 in a duplicative review ey the RAC of what the NRC l
20 is doing.
There are two different functions being l
l il served that intermesh with one another tc some i
i 22 extent, but we don't think are identical nor do i
23 t r. c y need to be repeated.
I 24 It however, the RAC desires to see 25 any turther material trem LILCO we will ce happy s!
I
1 1
to provide at the RAC's request.
Because all 2
parties tiled testimony on'every one or these 3
issues before the NRC.
We are not going to reille l
4 it because We believe the RAC wanted to review our 5
plan and that's what we have given you.
6 MR. K0WIESKI: Any other comments?
l 7
Before we adjourn, in our meeting 9
notice were mentioned the hours trom 3 to 4 p.m.
r i
5 I that other parties than LILCO will,be allowed, if 10 tr.ey so desire, to make a presentation or 11 statement.
l 12 I don't know if anybody will be 13 present ettween 3 and 4 o' clock but ! think that I
1 14 we ought to have a recess for 45 minutes and then 15 come back for five minutes, ten minutes and see if I
l 16 somebody will be present.
17 Thank you.
L la (Recess at 2:20 p.m.)
t 19 (3 p.m.; meeting resumed.)
l 20 MR. K0WIESK!: Let's reconvene this l
l 21 meeting to allow otner pa.rties than LILCO to 22 present their points of view.
23 As stated in our meeting nctice, "!t i
4 24 time will allow other parties may present their i
25 points at view trom 3 p.m.
to 4 p.m.."
F 4
l
~ce 99 1
Ooviously in the interests of time if wiil like to make a statement, that'they 2
someone l
[
,3 gry to limit themselves to five minutes.
4 T r. e r e t o r e, I am asking it anyone would like to 5
make a statement?
6 MR. BIRKENHEIER:
On behalf of 7
Suttolk County I would once again like to repeat e
the request that Suttfolk County's technical l,
9
' experts ahd the RAC experts De allowed to meet to 10 diseuas the serious problems that Suffelk County 11 believes there is in the LILCo plan.
12 MR. K0WIESKI Any other ecmments?
l 13 Thank you again.
T r. i s concludes the 14 meeting with LILCO and the Regional Assistance l.'
15 Committee, as well as this satisfies our l.
16 requirement stipulated in meeting notice that
}
17 other parties will have an oppertunity to present l
13 their points of view.
19 MR.
I R'.*I I N : On behalt of LILCO I just l ',
20 want to thank you and othe r membe rs o f RAC and RAC's 21 consultants for this opportunity to meet with you 22 all a rid to get t r. e RAC's comments on the LILCO-13 Transition Plan.
l 24 (lle a r i ng adj:urned at 3: 95 p.m.)
2$
=
o 4
95 i
1 C E R T I F I C A T I O N 2
3 4
5 6
7 I,
RAYMOND DE SIMONE, a Certified Shorthand 9
Reporter and a Notary Public, do hereby certify l
9 that the foregoing is a true and accurato f
I 10 transcripcion oc my stenographic notes.
m 11 r p t vC1 W cw/
la l RAYMOND DE SIMONE, CSR u
14 1
15 16 17 18 19 21 22 I i
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