ML20086U198

Testimony of Mc Cordaro,Na Hobbs,Wf Renz,Wg Schiffmacher & Ja Weismantle on Phase II Emergency Planning Contentions 55,56,57 & 59

ML20086U198
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/02/1984
From:	Cordaro M, Nicholas Hobbs, Renz W, Schiffmacher W, Weismantle J LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20086U072	List: ML20086U069 ML20086U078 ML20086U089 ML20086U105 ML20086U113 ML20086U123 ML20086U135 ML20086U152 ML20086U176 ML20086U198 ML20086U214 ML20086U224 ML20086U235 ML20086U246 ML20086U258 ML20086U286 ML20086U292 ML20086U309 ML20086U315 ML20086U323 ML20086U327 ML20086U329
References
OL-3, NUDOCS 8403070190
Download: ML20086U198 (39)

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LILCO, March 2, 1984 i 1

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

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

) (Emergency Planning Proceeding)

(Shoreham Nuclear Power Station, )

Unit 1) ).

TESTIMONY OF MATTHEW C. CORDARO, NORMAN A. HOBBS, JR., WILLIAM F. RENZ, WILLIAM G. SCHIFFMACHER, AND JOHN A. WEISMANTLE ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTIONS 55, 56, 57 AND 59 Hunton & Williams P.O. Box 1535 707 East Main Street Richmond, Virginia 23212 (804) 788-8200 8403070190 840302 PDR ADOCK 0500032

LILCO, March 2, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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

) (Emergency Planning Proceeding)

(Shoreham Nuclear Power Station, )

Unit 1) )

TESTIMONY OF MATTHEW C. CORDARO, NORMAN A. HOBBS, JR., WILLIAM F. RENZ, WILLIAM G. SCHIFFMACHER, AND JOHN A. WEISMANTLE ON BEHALF OF LONG ISLAND LIGHTING COMPANY ON PHASE II EMERGENCY PLANNING CONTENTIONS 55, 56, 57 AND 59 PURPOSE This testimony discusses Contentions 55, 56, 57 and 59, which deal with notification to the public. The testimony demonstrates that the LILCO Transition Plan provides for notification to the public in compliance with applicable regulations and guidelines.

Contention 55 alleges that the decision to activate the si-rens might be delayed by factors alleged in Contention 26. In fact, the Plan provides that the sirens will be activated prompt-ly, if circumstances warrant, whether or not certain command and control personnel have been reached.

Contention 56 asserts that the LILCO Transition Plan does not provide adequate backup in the event of a failure of the siren system. The Plan, however, does provide adequate Dackup in the event of.such a failure, even though this is not r,equired.

Contention 57 contends that the use of tone alert radios in the LILCO Transition Plan does not provide adequate means for

notifying special facilities. The tone alert radios, however, will provide notice to special facilities by broadcasting EBS mes-sages upon activation by WALK-FM Radio.

Contention 59 alleges that the notification methods outlined in the agreement with the U.S. Coast Guard, contained in the LILCO Transition Plan, provide insufficient notice to the public on the waters within the 10-mile IPZ. The Contention alleges that the U.S. Coast Guard cannot notify the public on the waterways within 15 minutes and therefore that LILCO's plan for notification of the public on the waterways does not comply with 10 C.F.R. Part 50, Appendix E, IV.D.3. The requirement of notifying the public with-in 15 minutes, however, does not apply to the public on the water-ways of Long Island Sound. " Extended water areas with transient boats," such as Long Island Sound, are covered by an exception to the 15 minute notification requirement which permits a special alerting method. (See NUREG-0654, Appendix 3). The LILCO Transi-tion Plan complies with the guidelines for the special alerting method described in NUREG-0654, Appendix 3, thus providing proper and sufficient notification to the public on the waterways within the 10-mile EPZ.

TESTIMONY

1. Q. Please state your name and business address.

A. [Cordaro] My name is Matthew C. Cordaro. My business address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York, 11801.

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[Hobbs] My name is Norman A. Hobbs, Jr. My business address is HMM Associates, 336 Baker Avenue, Concord, Mas-l sachusetts, 01742.

[Ren:] My name is William F. Renz. My business address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York, 11801.

[Schiffmacher] My name is William G. Schiffmacher. My business address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York, 11801.

[Weismantle] My name is John A. Weismantle. My business address is Long Island Lighting Company, 100 East Old Country Road, Hicksville, New York, 11801.

2. Q. Please summarize your professional qualifications and your role in emergency planning for the Shoreham Nuclear Power Station.

A. [Cordaro] I am Vice President, Engineering, for LILCO.

My professional qualifications are being offered into evi-dence as part of the document entitled " Professional Qual-ifications of LILCO Witnesses." I am sitting on this panel to provide the LILCO. management perspective on emer-gency planning and to answer any questionc pertinent to management. My role in emergency planning for Shoreham is to ensure that.the needs and requirements of emergency planning are being met, and that the technical direction

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and content of emergency planning are being conveyed to.

corporate management.

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[Hobbs] I am an Emergency Planning Consultant with HMM Associates. My professional qualifications are being of-fered into evidence as part of the document entitled " Pro-fessional Qualifications of LILCO Witnesses." My famil-iarity with the issues raised by these Contentions stems from my experience in emergency planning, communications systems design, and public information.

[Ren ] I am employed by the the Long Island Lighting Com-pany as Offsite Emergency Preparedness Coordinator in the Nuclear Operations Support Department and Manager of the Technical Support Division of the Local Emergency Response Implementing Organization (LERIO). My professional quali-fications are being offered into evidence as part of the document entitled " Professional Qualifications of LILCO Witnesses." My familiarity with the issues raised by these Contentions stems from my work in developing and im-plementing the LILCO Transition Plan, particularly my work in developing the communications system.

[Schiffmacher] I am employed by LILCO as the Manager of the Electrical Engineering Department of LILCO. My pro-fessional qualifications are being offered into evidence as part of the document entitled " Professional Qualifica-tions of LILCO Witnesses." My familiarity with the issues raised by these Content?.ons stems frnm my experience in Electric System Planning, Electric System Operations, as l

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well as my responsibilities associated with the installa-tion of the Prompt Notification System.

[Weismantle] I am Manager of the Local Emergency Response Implementing Organization for LILCO. My professional qualifications are being offered into evidence as part of the document entitled " Professional Qualifications of LILCO Witnesses." My familiarity with the issues raised by these Contentions stems from my work in developing and implementing the LILCO Offsite Emergency Response Plan for Shoreham (referred to as the LILCO Transition Plan).

3. Q. Would you summarize the conclusion you have reached on the basic issue raised by these Contentions?

A. [Cordaro, Hobbs, Renz, Schiffmacher, Weismantle] Yes.

The Plan and Procedures provide for prompt notification to the public by means of sirens, tone alert, radios, the U.S.

Coast Guard, and certain backup systems. These provisions are designed to comply with applicable regulations and guidelines.

4. Q. Would you summarize the central issue posed by, and legal standards cited in, Contentions 55, 56, 57 and 59?

A. [Cordaro, Hobbs, Renz, Schiffmacher, Weismantle] The cen-tral issue posed by Contentions 55, 56, 57 and 59 is whether the LILCO Plan adheres to regulations and I

guidelines by providing for prompt notification to the public.

The Preamble to Contentions 55-59 reads as follows:

Preamble to Contentions 55-59. 10 CFR Section 50.47(b)(5) requires that means be ectablished to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ.

The public notification system should be capable of essentially completing the ini-tial notification of the public in the plume exposure pathway EPZ "within about 15 minutes." 10 CFR Part 50, Appendix E, Section IV.D.3. (See also NUREG 0654,Section II.E.6 and Appendix 3 thereto).

Intervenors contend that under LILCO's Plan, there is no assurance that the pub-lic will receive notification of an emer-gency within 15 minutes, and as a result, there is no assurance that adequate pro-tective actions can or will be imple-mented, as required by 10 CFR Section SO.47(a)(1) and NUREG 0654 Sections II.J.9 and J.10. The specific deficiencies in the LILCO Plan are set forth in Conten-tions 55-59.

The legal standards cited in the Preamble are the following:

10 C.F.R. S 50.47(b)(5)

Procedures have been established for notifi-cation, by the licensee, of State and local-re-sponse organizations and for notification of emergency personnel by all organizations . . .

and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established, 10 C.F.R. Part S 50, Appendix E, IV.D.3 A licensee shall have the capability to no-tify responsible State and local governmental agencies within 15 minutes after declaring an emergency. . The licensee shal1~ demonstrate that the State / local officials have the capability to make a public notification. decision promptly on being informed by the' licensee of an emer-gency condition . . . . The_ design objective of_the prompt public notification system shall

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, be to have the capability to essentially com-l plete the initial notification of the public j within the plume exposure pathway EPZ within l about 15 minutes. The use of this notification capability will range from immediate notifica-tion of the public (within 15 minutes of the '

j time that State and local officials are

' notified that a situation exists requiring ur-gent action) to the more likely events where-there is substantial time available for the State and local governmental officials to make a judgment whether or not to activate the pub-lic notification system . . . .

i NUREG-0654, II.E.6 Each organization shall establish adminis-3 trative and physical means, and the time re-quired for notifying and providing prompt in-

.structions to the public within the plume exposure pathway Emergency Planning Zone.'(See

! Appendix 3.) It shall be the licensee's re-

sponsibility to demonstrate that such means

! exist, regardless of who implements this re-t quirement. It shal] be the responsibility of the State and local governments to activate

! such a system.

{ Appendix 3 of NUREG-0654 describes acceptable.means 1

-1 for providing prompt alerting and notification of re-sponse organizations and the population.

• Contention 55 i

l 5. Q. Please address specifically Contention 55.

i A. [Cordaro, Renz, Schiffmacher, Weismantle) Contention 55 reads as follows:

i Contention 55. Under the LILCO Plan, a ,

l system of 89 fixed sirens will be used to

!- alert the public to an emergency at the

! Shoreham plant. (Plan, at 3.4-6). Howev-

. er, as a result of the deficiences noted l in Contention 26, LILCO will be-unable to 2

contact its key command'and control _per-I sonnel in a timely manner, thus poten-( tially delaying the decision to activate-l-

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-s-the siren system,.in violation of 10 CFR Section 50.47(b)(5), Part 50, Appendix E,Section IV.D.3, and NUREG 0654,Section II.E.6 and Appendix 3.

Contention 26, cited in Contention 55, alleges that i .

lack of adequate equipment and personnel will hinder notification of key LERO personnel. The issues raised

in Contention 26 are LJdressed separately-in testimony-

on that issue. The testimony on Contention 26 demon-strates that the sirens will be activated promptly, l

j whether or not " key command and control personnel" can i be reached.

6. Q. How does the activation of the sirens take place?

i A. [Cordaro, Renz, Schiffmacher, Weismantle} OPIP 3.3.4

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describes the actions necessary to activate the Prompt Notification System, which consists of 89 sirens as

! well as tone alert radios and the Emergency Broad-casting System. This process is described in greater detail in the testimony dealing with Contention 26.

! Notification from the Shoreham Control Room that an emergency has been declared is received by the Customer Service Operator. He than pages the designated Direc-i tor of Local Response, who is the person'who ordinarily directs that the Prompt Notification System be acti-vated.

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In the unlikely event that the initial 1: tification from the plant is a General Emergency for which protec-tive actions are recommended and the Director of Local Response cannot be reached within 10 minutes of receipt of notification from the plant, the Customer Service Operator will, under OPIP 3.3.4, page 3, have the siren system activated. Additionally, if the Customer Ser-Vice Operator cannot contact the Coordinator of Public Information within 10 minutes the Customer Service Op-erator will coordinate the activation of EBS with the activation of the sirens.

Accordingly, even in the absence of the Director of Local Response and the Coordinator of Public Informa-tion, the Prompt Notification System will, if needed, be activated in a timely manner.

Contention 56

7. Q. Please summarine the issues raised by Contention 56.

A. [Cordaro, Hobbs, Renz, Schiffmacher, Weismantle] Con-tention 56 alleges that the LILCO Transition Plan's provisions for Route Alert Drivers as a backup to the LILCO siren system are inadequate and that some persons will not hear or understand the broadcast message.

Specifically, the contention states that:

Contention 56. The LILCO Plan does not l provide adequate backup in the event of failure of the LILCO siren system. LILCO

relies upon public address systems or loud-speakers, mounted on LILCO vehicles driven by " Route Alert Drivers," to provide backup to the sirens. (Plan, at 3.3-4 and 3.4-6; OPIP 3.3.4, at 4). However, the proposal to drive vehicles equipped with loudspeakers through the non-activated siren areas to alert the public is impractical, unworkable, and will not provide notification within 15 minutes as required by NUREG, 0654 Appendix

3. (See Contention 27.) In addition, some persons will not hear the broadcast message (such as persons with impaired hearing, per-sons outside the EPZ), and other persons will not understand the broadcast message (such as children, and non-English speaking persons). Route alert drivers are also re-quired to abandon a route if dosimetry

! readings exceed specified levels. (OPIP 3.3.4, Attachment 1). Accordingly, there is no assurance that persons in the EPZ will be promptly notifed of an emergency, and entire segments of the population may never be alerted at all, in violation of 10 CFR Sec-tions 50.47(a)(1), 50.47(b)(5), Part 50, Ap-pendix E,Section IV.D.3, and NUREG 0654, Sections II.E.6 and Appendix 3.

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8. Q. There are a number of regulations and guidelines cited in Contention 56. What regulations and guidelines govern the issues raised by Contention 56?

A. [Cordaro, Hobbs, Renz, Schiffmacher, Weismantle] The

standards cited in Contention 56 are the following

10 C.F.R. 5 50.47(a)(1) l [N]o operating license for a nuclear i power reactor will be issued unless a find-ing is made by NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a ra-diological emergency.

10 C.F.R. S 50.47(b)(5)~

Procedures have been established for.no-tification, by the licensee, of State and

local response organizations and for notifi-cation of emergency personnel by all organi-nations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear in-ctruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

10 C.F.R. Part 50 Appendix E, IV.D.3 A licensee shall have the capability to notify responsible State and local govern-mental agencies sitbin 15 minutes after declaring an emergency. A licensee shall demonstrate that the State / local officials have the capability to make a public notifi-cation decision promptly on being informed by the licensee of an emergency condition . . . The design objective of a prompt public notification system shall be to have the capability to essentially com-plete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes. The use of this notifica-tion capability will range from immediate notification of the public (within 15 minutes of the time that State and local of-ficials are notified that a situation exists requiring urgent action) to the more likely events where there is substantial time available for the State and local governmen-tal officials to make a judgment whether or not to activate the public notification system . .

NUREG-0654, II.E.6 Each organization shall establish admin-istrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone (See Appendix 3.) It shall be the licens-ee's responsibility to demonstrate that such means exist, regardless of who implements this requirement. It shall be the responsi-bility of the State and local governments to activate such a system.

The Contention also cites NUREG-0654, Ap-pendix 3.

9. Q. How does LILCO propose to comply with the regulations and guidelines cited above?

A. [Cordaro, Hobbs, Renz, Schiffmacher, Weismantle] LILCO proposes to comply with the regulations and guidelines concerning prompt notification of the public within the plume exposure pathway EFZ by activating the Prompt Noti-fication System which includes the Emergency Broadcast System. By means of the sirens, tone alert radios, and EBS messages, LERO has the capability of notifying the public within fifteen minutes and providing an instruc-tional message. The procedures for activating the Prompt Notification System and the Emergency Broadcasting System are outlined in OPIP 3.3.4 of the LILCO Transition Plan.

The Prompt Notification System has the capability of being activated within 15 minutes.

10. Q. Do the regulations or guidelines require a backup power supply for the sirens?

A. [Cordaro, Hobbs, Renn, Schiffmacher, Weismantle] No. The regulations and guidelines do not state that backup power must be available for the sirens. Nonetheless, as is dis-cussed at length in LILCO's testimony on Contention 95.A.,

LILCO is committed to restore power to the sirens on a priority basis. LILCO's Systems Operation Department is developing procedures to ensure prompt restoration of l

power to the siren system following a widespread loss of power generation.

11. Q. Does LILCO provide any other backup in the event of fail-ure of the siren system?

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A. [Cordaro, Hobbs, Renz, Schiffmacher, Weismantle] The LILCO Transition Plan, OPIP 3.3.4, provides for Route Alert Drivers as means as notifying perecns in any area where it has been determined that a siren has not func-tioned. As discussed in LILCO's Testimony on Contention 95.A., telephone surveys and a review of the electric cir-cuits that power the sirens will be used to locate sirens thich have failed to function.

12. Q. Contention 56 states that using Route Alert Drivers as a backup to sirens is an unworkable proposal. What provi-sions has LILCO made to ensure that the use of Route Alert Drivers will be practical and will provide adequate noti-fication to the public?

A. [Cordaro, Hobbs, Renz, Weismantle] As outlined in OPIP 4

3.3.4, the proposal to use Route Alert Drivers as a means of notifying persons in areas where the sirens have failed to function is a detailed workable proposal. In addition, the proposal outlined in OPIP 3.3.4 is similar to those procedures currently in use at several other sites.

First, Route Alert Drivers will report to their respective stacing areas at the Alert level. Thus, these drivers will be in place in the event the emergency escalates from an Alert to a Site Area or General Emergency requiring the activation of the sirens. Once the Route Alert Drivers arrive at the staging areas they will obtain their dosimetry, and mount and test their public address system in their vehicle to ensure that they will be ready to be dispatched immediately if they receive notification that a

siren has not functioned. The procedures provide for the Lead Traffic Guide to dispatch Route Alert Drivers to the areas in which any siren has malfunctioned. Route Alert Drivers will be dispatched to drive routes (Attachment 1) through the area covered by one siren. On his drive through the route alert area, the Route Alert Driver will broadcast a message over the loud speaker system attached to his vehicle. The message will notify residents of the area that there has been an accident at the Shoreham Nu-clear Power Station and that residents should turn to their local emergency broadcasting station for further in-formation. The message broadcast on the public address system will be recorded on cassette tapes.

13. Q. Do the regulations and guidelines require that the Route Alert Drivers provide notification within 15 minutes?

A. [Cordaro, Hobbs, Renz, Weismantle] No. The regulations and guidelines simply require that the design objective of the prompt notification system be to have the capability to complete initial notification of the public within about 15 minutes. The Route Alert Drivers will not pro- l vide notification to the public in areas where the sirens have failed to function within 15 minutes; however, the regulations do not require that the backup notification provided by the-Route Alert Drivers be accomplished within 15 minutes. Indeed,-no backup notification mechanism.is-required. The 15 minute criterion is satisfied by the

I siren system and Emergency Broadcast System, which are the primary methods of notification. The design objective and the capability do exist to provide initial notification to the public in the plume exposure pathway EPZ within 15 minutes through the use of the sirens and the Emergency Broadcast System. The Route Alert Drivers merely provide a backup method of notification in the event that the si-rens do not function.

14. Q. Contention 56 also asserts that the hearing impaired and persons outside the EPZ will not hear the message broad-cast by the Route Alert Drivers. What provisions has LILCO made for notifying these people?

A. [Cordaro, Weismantle] First, it is true that persons out-side the EPZ may not hear the messages broadcast by the Route Alert Drivers. The regulations do not require that persons outside the EPZ receive prompt initial notifica-tion of an accident at the Shoreham Nuclear Power Station.

Second, LILCO has made special provision for.the hearing impaired residing in the EPZ to receive notification in a manner that will accommodate their handicap. The LILCO Transition Plan (see OPIP 3.3.4) provides that, if shel-tering is the recommended protective action, Route Alert Drivers will notify both' ambulatory'and non-ambulatory hearing impaired people by driving to the residence of each hearing impaired person and informing the hearing im-paired person of the accident at Shoreham and the protec-tive action recommendation by means of a card with a

message that has protective action recommendations on it.

If evacuation is the recommended protective action, Route Alert Drivers will notify the ambulatory hearing impaired as described above. Ambulance /ambulette vans will notify the non-ambulatory hearing impaired by arriving at their residences to evacuate them. In addition, the Public In-formation Brochure that will be sent to all residents of the EPZ suggents that persons who are hearing impaired ar-range with a family member or neighbor to notify them if the sirens sound. The brochure also urges the hearing im-paired person to register with LERO se that they can re-ceive special notification.

15. Q. What provisions has LILCO made for persons who will not understand the broadcast message, such as non-English speaking persons and children?

A. [Cordaro, Renz, Weismantle] At this time, LILCO does not intend to broadcast its informational messages in any lan-guage other than English. The results of a survey con-ducted by LILCO as well as a review of the 1980 census data indicate that the non-English speaking population is so small (less than 5% of the population residing in the EPZ speaks any one language other than English) that no provision for translation is warranted. (See LILCO's Tes-timony on Contention 21.C.) However, LILCO has made spe-cial efforts to contact Spanish-speaking individuals residing in the EPZ to determine whether they need special assistance to evacuate.

The Contention also suggests that children may not un-derstand the import of the EBS messages. Children within the EPZ who would not understand the messages are likely to be in the care of a responsible adult: their parent, some other adult who is supervising their activity, or in school. School officials will receive notification via tone alert radios and/or commercial telephone. Other adults who are supervising children will be notified, as will the rest of the general public, through the Prompt Notification System. Thus, LILCO has provided adequate means for notifying the populace within the plume exposure pathway EPZ.

16. Q. The Contention implies that Route Alert Drivers will not provide effective notification because they will abandon their routes when dosimetry readings exceed specified lev-els. What procedures will a Route Alert Driver take prior to abandonment of his route because of radiation exceeding specified levels?

A. [Cordaro, Renz, Weismantle] Route Alert Drivers are to notify the Lead Traffic Guide by telephone if the reading on the dosimeters goes beyond 200 millirem. At a reading of 3.5 rem, Route Alert Drivers are to inform the Lead Traffic Guide of their dosimeter reading and to prepare to

leave the area. The purpose of notifying the Lead Traffic Guide is co that a replacement can be sent for the Route Alert Driver whose dosimetry equipment displays a reading of 3.5 rem. If directed to leave the area, or at a reading of 5 rem, whichever occurs first, the Route Alert

Driver is to return to the emergency worker decontamination center at Brentwood for monitoring and possible decontamination. Therefore, the fact that Route Alert Drivers are required to abandon their routes if their dosimetry reading exceeds the level of 5 rem will not prevent backup notification from taking place.

Contention 57

17. Q. Have you also analyzed Contention 57?

A. [Cordaro, Hobbs, Renz, Weismantle] Yes. Contention 57 concerns the tone alert radios. It states:

Contention 57. The LILCO Plan provides that special facilities and organizations with a large number of personnel (such as schools, hospitals, nursing homes, handi-capped facilities, and major employers) ,

will be equipped with a tone alert radio which, upon activation by the EBS signal from WALK radio, is to broadcast automat-ically the emergency message. (Plan, at 3.3-4 and 3.4-6 and OPIP 3.4.1, Attachment 1). However, sirce notification would co-sincide with notification to the general public, these special facilities and orga-nizations would not have any additional alerting or preparation time (for evacua-tion, sheltering, or implementation of other protective actions). Moreover, the tone alert radios depend upon the EBS sig-nal broadcasting from WALK radio station.

Should the EBS signal originate from other stations, the radios would not activate and there would not be automatic transmis-sion of the EBS message. Further, WALK radio does not broadcast on its AM fre-quency 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Thus, there is no assurance that tone alert radios will provide adequate notification of an emer-gency to special facilities and other or-ganizations within the EPZ, in violation of 10 CFR Sections 50.47(a)(1) and 50.47(b)(5), Part 50, Appendix E, Section

IV.D and NUREG 0654, Sections II.E.5, E.6, and Appendix 3.

18. Q. What have you cencluded with respect to this Conten-tion?

A. [Cordaro, Hobbs, Renz, Weismantle] The applicable reg-ulations and guidelines do not state that notification of special facilities need be in advance of the general public. Thus, this Contention is without any basis.

The Contention focuses on the signal activating the tone alert radios. First, the LILCO Transition Plan provides that this signal will originate from WALK-FM Radio, not from any other radio station (Plan at 3.3-4). Second, the assertion that WALK-AM Radio does not broadcast 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day is not relevant, since the EBS signal is transmitted over the WALK-FM broadcast which is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

Contention 59

19. Q. Please summarize the issues raised by Contention 59.

A. [Cordaro, Hobbs, Renz, Weismantle] Contention 59 ques-tions whether, under the LILCO Transition Plan, the Coast Guard can provide prompt notification to the gen-eral public on the waters. Specifically, Contention 59 states:

Contention 59. Under the LILCO Plan, the U.S. Coast Guard is relied upon to provide public notification to the general public on the waters within the 10-mile EPZ. (Plan at 2.2-2). However, the Coast Guard does not have the' capability of no-tifying the public within 15 minutes and

thus the LILCO Plan fails to comply with 10 CFR Sections 50.47(b)(5), 50.47(b)(6),

Part 50, Appendix E, Section IV.D and NUREG 0654, Sections II.E.5, E.6 and Ap-pendix 3.

20. Q. Contention 59 states that the LILCO Transition Plan fails to comply with 10 C.F.R. $$ 50.47(b)(5),

50.47(b)(6), Part 50, Appendix E, 5 IV.D and NUREG-0654, SS II.E.5, E.6, and Appendix 3. What are the standards for notifying the public as set out in these regulations and guidelines?

A. [Cordaro, Hobbs, Renz, Weismantle] The regulations generally require that the design objective be to have the capability for prompt notification of the public and for providing an informational or instructional message to the population, on an area wide basis throughout the 10-mile EPZ, within 15 minutes.

21. Q. Do these requirements apply to Long Island Sound?

A. [Cordaro, Hobbs, Renz, Weismantle) No. NUREG-0654, Appendix 3, B-2 allows for special requirement ex- l ceptions to the notification design- objective that re -

quires the capability to provide both an alert signal and an informational or instructional message to the.

population, on an area wide basis throughout the 10-mile EPZ, within 15 minutes. This exception, which recommends notification of the.public within 45 minutes, applies to extended water areas.with transient.

boats such as the Long Island Sound.

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22. Q. What are the requirements for this special alerting method exception?

A. [Cordaro, Hobbs, Ren , Weismantle] FEMA's interim Standard Guide for the Evaluation of Alert and Notifi-cation Systems for Nuclear Power Plants, FEMA-43, out-lines the criteria for a special alerting method. The FEMA criteria require that both a description of the method for distributing the information and a written agreement with persons implementing the special e alerting method be in the Plan. The special alerting method itself must provide an alert signal to ensure coverage of the population who may not have received initial notification.

23. Q. Have arrangements been made for a special alerting method to cover Long Island Sound?

A. [Cordaro, Hobbs, Renz, Weismantle] Yes. The LILCO Transition Plan, Appendix B, includes a letter of agreement with the U.S. Coast Guard to provide a spe-cial alerting method by broadcasting on marine radio frequencies and by direct contact with boats. (Attach-ment 2). The Coast Guard will receive notification ei-ther from the EOC utilizing the Federal Teleccmmunications System in the Shoreham Control Room, 6

TSC, or EOF, or from the LERO Evacuation Coordinator on a commercial telephone line at an Alert level or higher. In addition, a marine-band radio will be in-stalled at the EOC that will provide another method for communicating with the Coast Guard.

24. Q. Will this method provide notification to the popula-tions on the waterway in the EPZ?

A. [Cordaro, Hobbs, Renz, Weismantle] Yes. The larger boats generally have radios and the smaller boats are normally close enough to shore to hear the sirens. For boats without radios far from shore, the Cc;st Guard boats will make a concerted effort to contact them.

25. Q. Are there any other nuclear power plants using similar special alert notification methods for alerting the public on the waterways?

A. [Cordaro, Hobbs, Renz, Weismantle] Yes. The adequacy of the LILCO Transition Plan's special alerting methods is confirmed by the fact that the notification method for Long Island Sound as described in the LILCO Transi-tion Plan is essentially identical with the State of Connecticut Radiological Emergency Response Plan for the Haddam Neck and Millstone Power Stations. These are two operating nuclear power plants adjacent to Long Island Sound. (Attachments 3 and 4). Moreover, recent Licensing Board decisions in Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), LEP-82, 16 NRC 756, 773-75, 815 (1982), and Southern California Edison Company (San Onofre Nuclear Generating Station, Units 1 and 3), LBP-82-39, 15 NRC 1163, 1205, 1268-69 (1982), have approved, as a special alerting method, notification of ships and boats at sea by the U.S. Coast Guard through the use of marine-band radio and boats.

26. O. Are there any other methods by which the public on the waterways could receive notification of an incident at the Shoreham Nuclear Power Station?

A. [Cordaro, Hobbs, Renz, Weismantle] The sirens are ef-fective to give notice to boaters and swimmers out to about two miles into Long Island Sound. It is likely that boats farther out from shore would have communica-tions equipment that would permit them to receive word of an emergency, while boats closer to shore would have the benefit of the siren coverage. As the Licensing Board stated in Southern California Edison Company (San Onofre Nuclear Generating Station, Units 2 and 3), LEP-82-39, 15 NRC 1163, at 1268 n.62 (1982), this type of notification meets the guidance of NUREG-0654.

9 0

ATTACHMENTS ,

ATTACHMENT 1 Typical Route Alert Driver Maps for Area Covered by One Siren ATTACHMENT 2 July 11, 1983 Letter of Agreement from United States Coast Guard Relating to Emergency at Shoreham Nuclear Power Station ATTACHMENT 3 State of Connecticat Radiological Emergency Response Plan Provision Relating to Notification of Public on Long Island Sound ATTACHMENT 4 June 2, 1981 United States Coast Guard Letter of Agreement Relating to Emergencies at Millstone or Haddam Neck Nuclear Power Stations t

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DEPARTMENT OF TRANSPORTATION ATTACHMENT 2 87 UNITED STATES COAST GUARD Captain of the Port 120 Woodward Avenue l New Haven, CT 06512

, Tel:(203)773-2464 3440

, 11 July 1983 Mr. William F. Renz l Cffcite Emergency Prepardness Coordinator j Long Island Lighting Company ,

175 E. Old Country Road i Hicksville, New York 11801 Re: Coast Guard Response to Radiological Emergencies

Dear Mr. Renz:

This letter will supersede Captain of the Port (C0TP) New Haven's letter of cgreement dated November 14, 1978.

Should an emergency arise at Shoreham Nuclear Power Station, COTP New Haven will provide the following response:

a. Marine Traffic Control.

b. Voice safety broadcasts on marine radio frequencies.

c. Vessels for radiation monitoring during marine traffic control patrols.

d. Liasion personnel at LILCO's Emergency Operations Center in Hauppauge Lane Island.

To insure the effectiveness of our support and safety of our personnel, the following equipment / training must be provided by Long Is1cnd Lighting Company.

a. Direct Reading and Thermoluminescent dosimeters for all boat crews.

b. Radiation level monitoring devices for each boat.

c. Ongoing refresher and updated training of Coast Guard personnel in perconal safety and use of monitoring devices.

C2 cat Guard response to a declared emergency will be initiated upon notification by Shoreham Nuclear Power Station personnel that the emergency exists. Notifica-tien should be made to the Captain of the Port duty officer at (203)773-2464 or 773 2400.

h E.W. WIEG Captain, U.S. Coast rd Captain of the Port, New Haven Copy: CCGD3(m) l COTP NY APP-B-8 WE\

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ATTACHMENT 3

ATTACHMENT 3 R2visita 2 Date: 10/82 ,

State of Connecticut In the event of an incident at the Hillstone Nuclear Power Station, the DOT. Bureau of Waterways, will communicate with the U.S. Coast Guard bases at New London and Montauk. The U.S. -

" Coast Guard will then alert all ocean going, shipping, and

- Tboating traffl.c within affected areas, via radio or public address systems. to take the recommended Protective Action. In "the event og an incident at the Maddas Neck Plant, the Bureau of Waterways will communicate with the U.S. Coast Guard base at._

New Haven in addition to the Harbor Masters within the affected Connecticut River areas _. River going traffic will be alerted,

• via radio or public address avstama. to amptement the recommended Protective Action.

As Evacuation actions are completed, the DOT Commissioner will notify the CPD through the State EOC. As Access Control actions are completed, the DOT Commissioner will notify the CSP Commissioner through the State E0C.

D. Parallel Actions The DOT is a support State agency for Radiation Exposure Control. DOT personnel entering affected areas (i.e., bus drivers) will be issued dosimeters by one of the Department's ten Radiological Defense Officers. They will receive them at the maintenance garages in either Lisbon or Old Saybrook.

After being relieved of duty, DOT personnel will report to the Department of Health Service's laboratory in Hartford for a dosimeter readout and a thyroid scan, if necessary. Dose records will be maintained for DOT e'ergency m workers at DOT's Rocky Hill and Norwich district offices. Dose records will later be forwarded to the Department of Health Services. ,

The DOT personnel will implement their Standard Operating Procedures for decontaminating personnel, equipment and vehi-cles in accordance with the Section 402 Common Procedures.

Decontamination facilities will be established at the Norwich State Hospital for emergency workers, and the nearby Department of Transportation (D07) bus facility in Preston for vehicles i and equipment. In addition, decontamination facilities for l emergency workers, vehicles and equipment will be established l at the Rocky Hill Materials Testing Laboratory and, as alternates, the Lisbon and Old Saybrook maintenance garages, which are also operated by DOT.

The DOT, as a support State agency for Reentry and Recovery, will provide transportation for rentering evacuees. If needed, the DOT Commissioner will coordinate these assigned activities

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with the Connecticut National Guard and Connecticut State Police to facilitate the movement of available transportation resources, and will notify the Connecticut State Police Commis-stoner, through the State E0C, as assignments are completed.

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ATTACHMENT 4

DEPARTMENT OF TRANSPORTATION C:ptain of th3 Port

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8 UNITED STATED COAGT GUARD c/o Fort Trumbull New London, CT e6320 (203) 442-4471 16450 ATTACHMENT 4 2 June 19e1 Mr. Fralhk Mancuso i {gg~

State Director, Department of Public Safety Office of Civil Preparedness

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Office of CMI Propaedness

Dear Sir ,

The purpose of this letter is to confirm that USCG New London will respond to a request for assistance regarding emergency response actions that may be required in case of an accident at Millstone or Naddam Neck nuclear power generating plants. .

Concept of Operation ,(Emergency Measures Provided).

USCG New London supports emergency planning zone towns and islands by supporting access control actions in the waterways, if requested.

USCG New London, upon request of the State of Connecticut, or the utility, will provide boat transportation for a radiological monitoring team. The Coast Guard boat crew (4 personnel) will require the same level of protective clothing and equipment as that cf the radiological montoring team. This will be provided by the agency providing the montoring team.

USCG New London will receive emergency notification (alert) from either State of Connecticut or the utility and maintain telephone communications with the state.

USCG New London will support, upon request, one of the coastal communities involved, by providing access control support, in the event a small area is involved. Otherwise, such support will be coordinated through the state Emergency Operations Center.

USCG New London will support evaluation and take shelter protective action within capabilities.

Application. Support provided by USCG New London may be provided directly to local communities, (coastal communities), to the utility, or according to priorities to be determined by the State of Connecticut.

Criteria For Implementation.

a. Access control of boat traffic to be accomplished on the boundaries of

'a plume exposure zone within the 10-mile EPZ as required. (Departures from towns in the zone is a local police matter).

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-_-___--_-_-___---_-__J

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I 16450 2 June 1981

b. Provision of one boat, en sequest, to transport a radiological monotring team.

e. Communications, following an alert, will be maintained between tonnecticut Emergency Operations Center and USCG New London. Alternate means of comumnication will be through the City of New Iondon Emergency Operations Center. (

Arrangements for Exchange of Information. .

a. USCG New London will require periodic frequent updates of the situation from the State of Conneciteut in order to conduct operations and control exposure of personnel. *

b. USCG New London will report the access control situation, if implemented, periodically to the State Emergency Operations Center.

c. In the event USCG New London is supporting a radiological Wontoring teams, raw readings will be passed from USCG channels promptly to the State Emergency Operations Center.

Implementation Authorities / Points of Contact.

a. For the State of Connecticut: Implementating authority is the Governor or his Director of the Office of civil Preparedness, Telephone Number 558-3180. Routine point of contact is State Emergency Operations Center, Operations Officer, Telephone Number 566-2074 or through New London NAWAS

. for alternate emergency communications only.

b. For the USCG New London: Implementing authority is the Captain of the Port (the undersigned), telephone number (203) 442-4471. Routine point of contact is the alternate Captain of the Port (Station Executive Officer) or Operations Officer at the same telephone number. After normal hours, the above can be reached through New tendon Station's Duty Petty Officer at 442-4471.

Training of key Coast Guard personnel will be provided by the State and/or facility, USCG New London will be included in training exercises conducted by the State and/or facility.

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M. A. DAY A

Lieutenant C ander. USCG Commanding Officer / Captain of the Port Copy to:

Commander, Third Coast Guard District (des), (m) , (o)

Commander, USCG Group Long Island Sound 2

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _