ML20086N023

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Motion for Summary Disposition of Phase II Emergency Planning Contention 49 Re Dose Assessment Methods.No Genuine Issue of Matl Fact Exists
ML20086N023
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 02/13/1984
From: Mccleskey K
HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20086M832 List:
References
ISSUANCES-OL-3, NUDOCS 8402170188
Download: ML20086N023 (8)
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l LILCO, February 13, 1984 UNITED STATLS OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning (Shoreham Nuclear Power Station, ) Proceeding)

Unit 1) )

LILCO'S MOTION FOR

SUMMARY

DISPOSITION OF PHASE II EMERGENCY PLANNING CONTENTION 49 (DOSE ASSESSMENT METHODS) ,

LILCO moves, pursuant to 10 C.F.R. $ 2.749, for summary disposition of Phase II emergency planning Contention 49, which alleges that the Department of Energy's method for calculating offsite doses is too complicated.

I. Contention and Legal Standards Contention 49 reads as follows:

Contention 49: The dose projection worksheets, liquid release worksheets, ground deposition calculations and re-quired conputations used for dose assess-ment projections and downwind surveys (OPIPs 3.5.2 and 3.5.3), require unre-alistically accurate communications of complex data from survey teams to assess-ment teams in order to obtain the re-quired calculated results. There.are no provisions in OPIPs 3.5.2 or 3.5.3 for 8402170188 840213 PDR ADOCK 05000322 O .PDR , -

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r , e dealing with missing data, communications failures, the necessity of converting measurements from one unit to another, or the need for conversion factors if alter-nate equipment is used. Thus, there is no assurance that those procedures will provide reliable data for use in making protective action decisions and, accord-ingly, there is no compliance with the 10 CFR Section 50.47(b)(9) requirement that an adequate method be provided for as-sessing the potential consequences of an offsite release.

The legal standard cited in the contention is this: l t

10 CFR 6 50.47(b)(91 l

l Adequate methods, systems, and equip-ment for assessing and monitoring actual or potential offsite consequences of a l radiological emergency condition are in use.

II. Basis for Summary Disposition j l

The contention states, in essence, that dose assessment calculations are too difficult and complicated to be handled by Department of Energy (DOE) personnel responding from the Brookhaven Area Office. DOE developed many of the dose-assess-ment procedures and equipment used nationwide, and responding DOE personnel are well trained and technically sophisticated and work in nuclear-related fields. There-is thus no basis for contending that DOE could not calculate doses in the event of an accident at Shoreham.

Dose calculations under the LILCO Transition Plan are of two types. The first are calculated dose projections based upon radiation releases and mathematical wind dispersion mod-els. This type of calculation is done by DOE personnel using a

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portable computer with " user friendly" software. The data needed for the calculation are these from the standard New York

, State Radiological Emergency Data Fo'm. These data are relayed by dedicated telephone from the Shoreham site or EOF to the EOC to the Brookhaven Area Office, where the DOE team works. In case some information is not available, the computer software contains site-specific default values for Shoreham. If for some reason the computer is not available, the manual backup

, dose projection procedure in OPIP 3.5.2 can be used.

The second type of calculation is based upon data re-ceived from field monitoring teams. These teams are able to determine whole-body dose rates directly from field instruments and radio the dose rate to the EOC or Brookhaven Area Office.

Thyroid doses, however, require a calculation to account for the decay of certain isotopes. This calculation is not a dif-ficult procedure and is used by many emergency response groups around the country. The information required to do this calcu-lation is sent directly from field monitoring personnel by radio to the EOC or the Brookhaven Area Office, where the cal-culation is done. The field data are gathered by instruments that were developed at Brookhaven National Laboratory and are recommended by FEMA (Attachment 1). The data that must be ra-dioed to the DOE people doing the calculations are these:

The background dose rate How long the air sample was taken (for ex-ample, five minutes)

Two different readings of counts per minute.

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i If either the radios used by the field teams or the dedicated

. phone line from the Shoreham site were to fail for any reason, commercial phene lines could be used to transmit information.

The contention also refers to procedure OPIP 3.5.3, which is used for ingestion pathway calculations. These calcu-lations use data similar to those for the plume pathway proce-dure OPIP 3.5.2 but project doses based on consumption of con-i

. taminated food and water. This calculation too is a simple procedure used by numerous emergency response groups throughou'.

the country. Calculation of projected doses for~the ingestion

! pathway can be done at a more leisurely pace than calculations for the plume pathway, since control of foodstuffs and such in the ingestion pathway is a matter for the days and weeks after 4

an accident rather than the first few hours.

The procedure identified in Contention 49 will be_ tested by LERO and DOE personnel in NRC/ FEMA-observed exercises. Any.

problems in using the procedure revealed by those exercises will be corrected. Thus, there is reasonable assurance that-l these proven and practiced procedures will be implemented cor-1 i

rectly during an emergency.

l The contention mentions "the necessity of converting measurements from one unit to another," but such conversions

, would never be done by field personnel'. If done at all, they would be done at the EOC or Brookhaven Area Office.

The contention mentions "the need for conversion factors.

if alternate equipment is used." But alternate equipment

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requiring conversion factors would not be provided or used

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without a LILCO Transition Plan procedure for using it, and the' procedure would contain any needed conversion factors.

III. Conclusion The procedure for dose calculations for the plume path-way, OPIP 3.5.2, relies on information relayed by dedicated phone lines or radio. There is no reason to believe that the necessary data could not be transmitted by these means. The information that must be transmitted is either (1) a list of data from the standard New York State Radiological Emergency Data Form or (2) a list of four readings (dose rate, time, and two readings of counts per minute) from field equipment. In case data are missing, the computer software used in dose as-sessment contains default values that can be used instead. Ac-cordingly, Contention 49 raises no material issue of triable fact, and summary disposition in LILCO's favor should be granted.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY By .

5JimegN. ChriEt6an

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Kathf E. B. McCleskey Hunton & Williams P.O. Box 1535 707 East Main Street Richmond, VA 23212 DATED: February 13, 1984 l

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.g. m LILCO, February 13, 1984 i

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Annex STATEMENT OF THE MATERIAL FACTS AS TO WHICH LILCO CONTENDS THAT THERE IS NO GENUINE ISSUE TO BE HEARD ON PHASE II EMERGENCY PLANNING CONTENTION 49 (DOSE ASSESSMENT METHODS) i The following are the material facts as to which LILCO contends there is no genuine issue to be heard under Contention 49:

1. The dose calculations made under the LILCO Transi-tion Plan are of two types. The first are calculated dose pro-jections based upon radiation releases and mathematical wind dispersion nodels. The calculation, by DOE personnel, is done on a portable computer with " user friendly" software.
2. The data for this calculation are relayed by dedi-cated phone from the Shoreham site or EOF to the EOC to the Brookhaven Area Office, where the DOE team performs the calcu-lation.
3. In case data needed for this calculation are not available, the computer software contains site-specific default values for Shoreham.
4. If for some reason a computer is not available, a manual backup dose projection procedure is provided in proce-dure OPIP 3.5.2.

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- 5. The data needed for this type of. calculation are those from the standard New York State Radiological Emergency Data Form.

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6. The second type of calculation is based upon data received from field monitoring teams. These teams are able to determine whole body dose rates directly from field instru-ments.
7. Thyroid doses require a calculation for the decay of certain isotopes. This calculation is used by many emergen-cy response groups around the country.
8. The information required to implement the above procedure is sent directly from field monitoring personnel by radio to the EOC or Brookhaven Area Office for calculation.

The field data are gathered using equipment that was developed at Brookhaven National Labcratory and-is recommended by FEMA.

l 9. The data that must be radioed to the DOE people doing the calculations are these:

The background dose rate How long the air sample was taken (for ex-ample, five minutes)

Two different readings of counts per minute.

10. Ingestion pathway calculations use similar data to the plume pathway procedure, OPIP 3.5'.2, but project doses
based upon consumption of contaminated food and water.
11. Tne ingestion pathway procedure is used by numerous;'

emergency response groups.around the country.

12. The procedures identified in this contention will be tested by:LERO and' DOE personnel in NRC/ FEMA-observed exer-cises. Any problems revealed by those exercises will be cor-rected.

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13. Converting measurements from one unit to another (or any other processing of data gathered in the-field) would 5

be done only at the EOC or Brookhaven Area Office, not in the field.

14. " Alternate equipment" would not be provided or used under the LILCO Transition Plan without a written procedure, and the procedure would contain any needed conversion factors.

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