ML20092P727
| ML20092P727 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/03/1984 |
| From: | Cordaro M, Daverio C, Watts R ABB IMPELL CORP. (FORMERLY IMPELL CORP.), LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20092P723 | List: |
| References | |
| OL-3, NUDOCS 8407090315 | |
| Download: ML20092P727 (29) | |
Text
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't LILCO, July 3, 1984
, C ", '. " E T E D UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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Before the Atomic Safety and Licensing Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
) (Emergency Planning (Shoreham Nuclear Power Station, ) Proceeding)
Unit 1) ) LILCO'S REVISED TESTIMONY ON CONTENTION 88 (DOSE CRITERIA AND COST-BENEFIT ANALYSIS FOR REENTRY) PURPOSE Contention 88 states that the LILCO Transition Plan is inadequate because (1) the Plan fails to provide a basis for determining that it is safe for the public to reenter previous-ly evacuated areas, (2) the acceptable surface contamination levels are set forth in disintegrations per minute, rather than in radiation doses to the public, and (3) the Plan does not in-clude provisions explaining how to apply the cost-benefit anal-ysis for reentry called for in the Plan. This testimony will establish that (1) the Plan no longer sets forth acceptable contamination levels for reentry in disintegrations per minute, (2) the radiological criteria for reentry of the public into a previously evacuated area are now set forth ir. radiation doses to the public, and (3) the contamination levels for reentry , PDR
contained in the Plan satisfy NFF regulations and the , NUREG-0654 guidelines. This testimony will also establish that (1) the provision in the LILCO . Transition Plan that decisions = regarding temporary reentry would be based, in part, on the cost-benefit analysis provided in 10 C.F.R. Part 50, Appendix I, Section II.D, has been removed and replaced with a provision that " emergency dose limitations consistent with the Environ-mental Protection Agency Protective Action Guidelines for the general public," and (2) the revised provision satisfies NRC regulations and the NUREG-0654 guidelines. Attachments Attachment 1 OPIP 3.10..), Attachment 1 Attachment 2 Section 5.3 of OPIP 3.10.1 (Revision 4) Attachment 3 10 C.F.R. $ 20.105(a). f Attachment 4 Part I, Section IV.C of the I New York State Radiological Emergency Preparedness Plan Attachment 5 Section 5.5.1 of OPIP 3.10.1 (Revision 3) Attachment 6 Section 5.5.1 of OPIP 3.10.1 (Revision 4) Attachment 7 Table 5.1 of EPA-520/1-75-001 1 e ' H i, m
LILCO, July 3, 1984 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 1 (Shoreham Nuclear Power Station, ) Proceeding)
Unit 1) ) LILCO' S REVISED TESTIMONY ON CONTENTION 88 (DOSE CRITERIA AND COST-BENEFIT ANALYSIS FOR REENTRY)
- 1. Q. Please state your names and business addresses.
A. [Cordaro) My name is Matthew C. Cordaro and my business address is Long Island Lighting Company, 175 East Old Country Road, Hicksville, New York, 11801. [Daverio] My name is Charles A. Daverio and my i business address is Long Island Lighting Company, 100 East Old Country Road, Hicksville, N e w Y o r k ,- 11801. , [ Watts) My name is Richard J. Watts and my busi-ness address is Impell Corporation, 225 Broad Hol-low Road, Melville, New York, 11747. B e n w .- -------.,n y-.r-- -- --y 3 ,, . _ - , , .-3-. . c -r--
- 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 of Engineering for LILCO and have held this position since the spring of 1978. My professional qualifications are being offered into evidence as part of the document enti-tied " Professional Qualifications of LILCO Witness-es." I am sitting on this panel to provide the LILCO management perspective on emergency planning and to answer any questions pertinent to manage-ment. My role in emergency planning for Shoreham is to ensure that the needs and requirements of emergency planning are being met and that the tech-nical direction and content of emergency planning are being conveyed to corporate management. [Daverio] I am employed by LILCO as Assistant Man-ager of LILCO's Local Emergency Response Impic-menting Organization (LERIO). My professional qualifications are being offered into evidence as part of the document entitled " Professional Quali-fications of LILCO Witnesses." In my capacity as
. Assistant Manager of LERIO, I am responsible for developing and implementing the local emergency ,
response plan for Shoreham. r- -m e , -- -
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I am the Health Physics and Emergency
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[ Watts] Planning Supervisor for the Radiological Services Section-Northeast of Impell Corporation. My pro-fessional qualifications are being offered into ev-idence as part of the document entitled "Profes-sional Qualifications of LILCO Witnesses." I have been retained by LILCO to serve as a Radiation Health Cocrdinator for LERO. As such, I am famil-iar with the issues surrounding this contention.
- 3. Q. What is the " Preamble to Contentions 84-91"?
A. The " Preamble to Contentions 84-91" reads as fol-lows: Preamble to Contentions 84-91. The LILCO Plan proposes that short-term and long-term recovery and reentry operations will be performed by LILCO personnel fol-lowing a radiological emergency at Shoreham (Plan, at 3.10-1 and 3.10-2; OPIP 3.10.1). For the reasons specified in Contentions 84-91, Intervenors contend that contrary to the emergency planning standards of 10 CFR Section 50.47(b)(13) and NUREG 0654, Section II.M, the LILCO Plan fails to include general plans for recovery and reentry, including the de-velopment of necessary procedures and methods that are capable of being imple-mented.
- 4. Q. What is Contention 88?
A. Contention 88 reads as follows: t e
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, Contention 88. OPIP 3.10.1 sets forth " Acceptable Surface Contamination Levels" in units of disint'egrations per minute. The Plan does not include a method for converting such information into radiation doses to the public (e.g.,
persons-rems). The Plan also fails to state the dose criteria that will provide the basis for a determination that it is safe for the public to reenter previously evacuated areas. The Plan calls for a cost benefit analysis based on a
$1,000/ person-rem during temporary reen-try (OPIP 3.10.1 at 5), but provides no guidance on how to analyze a situation in order to apply this criterion. Thus the Plan fails to comply with 10 CFR Section 50.47(b)(13) and NUREG-0654, Sections II.I.10, and II.M.1.
- 5. Q. What are the legal ctandards cited in Contention 88?
A. The legal standards cited in Contention 88 are the following: 10 C.F.R. 6 50.47(b)(13) General plans for recovery and reen-try are developed. NUREG-0654, II.I.10 Each organization shall establish means for relating the various measured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key isotopes (i.e., those given in Table 3, page 18) and gross radio-activity measurements. Provisions shall be made for estimating integrated dose from the projected and actual dose rates
, and for comparing these estimates with the protective action guides. The de-tailed provisions shall be described in ,
separate procedures.
NUREG-0654, II.M.I Each organization, as' appropriate, shall develop general plans and proce-dures for reentry and recovery and de-scribe the means by which decisions to relax protective measures (e.g., allow reentry into an evacuated area) are reached. This process should consider both existing and potential conditions. I. Acceptable Surface Contamination Levels
- 6. Q. Is it true that the radiological criteria for reen-try contained in the LILCO Transition Plan are set forth in disintegrations per minute?
A. No, this no longer is true. It is true that the radiological criteria for reentry contained in OPIP 3.10.1 of P3 vision 3 of the LILCO Transition Plan were set forth in disintegrations per minute. Sec-tion 5.3 of OPIP 3.10.1 of Revision 3 of the Plan provided that the Radiation Health Coordinator should refer to Attachment 1 of OPIP 3.10.1 in mak-ing decisions regarding reentry. Attachment 1 of OPIP 3.10.1, which was based on Table 1 of NRC Reg-ulatory Guide 1.86, set forth acceptable surface contamination levels for reentry in disintegrations per minute. Attachment 1 to OPIP 3.10.1 of Revi-sion 3 of the LILCO Transition Plan is Attachment 1 to this testimony. Attachment 1 of OPIP 3.10.1 has recently been removed from the Plan, however, and ~ e
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. replaced with new radiological criteria for reentry .
that are set forth in dose's to the public rather than in disintegrations per minute. The revised radiological criteria for reentry are included in Revision 4 of the Plan.
- 7. Q. What provisions does the LILCO Transition Plan now make regarding radiological criteria for reentry?
A. The radiological criteria that will serve as a A basis for a determination that it is safe for the 4 public te reenter previously evacuated areas are set forth in Section 5.3 of OPIP 3.10.1 of Revision i 4 of the Plan. Section 5.3.2.b provides that:
- b. An area will be considered contami-nated if:
Evaluation of environmental moni-4 toring results, plant data, and/or laboratory analysis of isotopes shows that direct con-stant exposure and inhalation of , resuspended particulates for one year (allowing for radioactive decay) will result in a dose greater than 500 [ millirem) to wholebody or equivalent to any organ. Applicable.models for this calcu-lation are contained in Regulato-1 ry Guide 1.109 and WASH 1400. Also compare results with Attach-
- . ment 1 of OPIP 3.6.6 for inges-tion pathway considerations.
l Section 5.3 of OPIP 3.10.1 (Revision 4) is G
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Attachment 2 to this testimony. As you can see from Section 5.3. 2 .b of OP1P 3.10.1, the ra-diological criteria for reentry are now set forth in terms of an acceptable integrated dose rather than in disintegrations per minute.
- 8. Q. What basis do you have for believing that previous-ly evacuated areas are acceptable for reentry if I
the integrated dose is 500 millirem or less? A. Unfortunately, there are no NRC regulations or NUREG-0654 guidelines that specifically address ac-ceptable offsite radiological levels for reentry. l LILCO's radiological criteria for reentry are con-sistent, however, with both 10 C.F.R. $ 20.105(a) and the acceptable contamination levels for reentry found in Part I, Section IV.C of the New York State Radiological Emergency Preparedness Plan. Section 20.105(a) of 10 C.F.R., which is Attachment 3 to this testimony, requires that any application for a license may include proposed limits of radia-tion in unrestricted areas resulting from the ap-plicant's possession or use of radioactive material and other sources of radiation. S'ection 20.105(a) provides further that the Nuclear Regulatory Com-mission will approve proposed limits'on levels of ~ o 4
radiation in unrestricted areas if the applicant demonstrates that the limits are not likely to cause any individual to receive a cose to the whole body exceeding 0.5 rem in any period of one calen-dar year. Section 20.lO5(a) of 10 C.F.R. is At-
. tachment 3 to this testimony.
Part I, Section IV.C of the New York State Ra-diological Emergency Preparedness Plan, which is Attachment 4 to-this testimony, also uses 500 i millirem as the threshold contamination level for reentry. The New York State Plan provides that
" initiated protective actions for the general popu-lation will not be relaxed as long as the projected dose commitment exceeds 500 mrem."
- 9. Q. Contention 88 states that the radiological criteria for reentry contained in the LILCO Transition Plan do not satisfy 10 C.F.R. $ 50.47(b)(13), NUREG-l 0654, II.I.10, and NUREG-0654, II.M.l. Do you i
I agree?
! A. No. First, NUREG-0654, II.I.10 doer, not apply to recovery and reentry provisions of an emergency plan. Section II.I.10 provides for compr.rison of integrated doses and the protective action
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guidelines for the determination of protective l .5
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_g. actions during the radiological emergency, not dur-ing the recovery and reentry phase of the emergen-cy. This is evident from the fact that actual and projected dose rates are to be compared to the pro-tective action guidelines, which are considerably higher than acceptable radiation levels for reentry by the general population. Recovery and reentry operations are addressed in Section II.M of NUREG-0654. The radiological criteria for reentry set forth in Section 5.3 of OPIP 3.10.1 of Revision 4 ~ of the LILCO Transition Plan satisfy 10 C.F.R. 5 50.47(b)(13) and NUREG-0654, II.M.1. II. Cost-Benefit Analysis of Reentry
- 10. Q. What is meant by temporary reentry as it is used in the LILCO Transition Plan?
A. Section 5.5 of OPIP 3.10.1 of the LILCO Transition Plan addresses temporary reentry into previously evacuated areas. Temporary reentry refers to the situation in which it is necessary for an individu-al to reenter an evacuated zone temporarily to deal with a " pressing matter," such as the need to turn utilities off or on or to attend to livestock. l e
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. 11. Q. Does the LILCO Transition Plan provide for cost-benefit analysis basdd on a $1,000/ person-rem during temporary reentry?
A. No, this no longer is true. It is true that Section 5.5.'1 of OPIP 3.10.1 of Revision 3 of the LILCO Transition Plan, which is Attachment 5 to this testimony, provided that the Health Services Coordinator would base his decision regarding a re-quest for temporary reentry, in part, on "the cost-benefit analysis provided by the NRC in i 4 10 C.F.R. Part 50, Appendix I, Section IID." This provision recently has been removed from the Plan, however, and replaced with a provision that he will consider " emergency dose limitations consistent with the Environmental Protective Agency Protective ) Action Guidelines for the general public." 4 Section 5.5.1 of OPIP 3.10.1 of Revision 4 of the l LILCO Transition Plan is Attachment 6 to this tes-i timony. Table 5.1 of EPA-520/1-75-001, which sets forth the protective action guideliner for the gen-eral public, is Attachment 7 to-this testimony.
- 12. Q. What are the exposure guidelines for the general i .
public set forth in Table 5.1 of EPA-520/1-75-001? e I
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11-l t A. Mandatory evacuation and controlled access are rec- - ommended if the projected ' dose to the whole body is 5 or more rems. See Attachment 7 to this testimo-ny.
- 13. Q. What is the basis for your decision to limit whole body radiation exposure from temporary reentry to less than 5 rems?
A. A person reentering an evacuated area temporarily to deal with a pressing matter would be acting, in effect, as an emergency worker. (The New York State Plan treats such persons as emergency workers. See Part I, Section IV.C of the New York 1 State Radiological Emergency Preparedness Plan, which is Attachment 4 to this testimony.) Thus, emergency worker exposure levels would apply. The exposure level for LERO workers set forth in the i
! LILCO Transition Plan is 5 rems. See page 3.9-2'of the LILCO Transition Plan. Five rems is a conser-vative value for emergency workers. This is evi-dent from the fact that the exposure level for emergency workers set forth in the Environmental 1
- Protection Agency Protective Action Guidelines is l 25 rems.
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. 14. Q. Do the provisions in the Plan regarding criteria to be applied in considering'a request for temporary reentry satisfy the NRC regulations and NUREG-0654 i-guidelines regarding recovery and reentry?
i A. Yes. NUREG-0654, II.M.1 provides that the licensee . "shall develop general plans and procedures for re-entry and describe the means by which decisions to l relax protective measures (e.g., allow reentry into an evacuated area) are reached." Section 5.5.1 of i OPIP 3.10.1 of Revision 4 does exactly what is pre-scribed in NUREG-0654, II.M.1. l 4 1 I I i e n. 1 e
Attachment 1 OPIP 3.10.1 Page 7 of 8 Attachment 1 Page 1 of 2 l ACCEPTABLE SURFACE CONTAMINATION LEVELS Average / (2)(3) Maximum / (2) (4) Removable / (2) (5) 2 2 2 i Nuclide (1) 100 cm 100 cm 100 em l i U-nat, U-235 5,000 dpm (6) 15,000 dpm 1,000 dpm l U-238, and alpha alpha alpha associated decay products Transuranics 100 dpm 300 dpa - 20 dpm RA-226, Ra-228, Th-230, Th-228, Pa-231, Ac-227, I-125, I-129 Th-nat, Th-232 1,000 dpm 3,000 dpm 200 dpm Sr-90, Ra-223 i Ra-224, U-232, ,
, I-126, 1-131,
, I-133 Beta-gamma emitters 5,000 dpm 15,000 dpm 1,000 dpm (nuclides with decay beta gamma beta-gamma beta-gamma modes other than alpha emission or spontaneous fission) except Sr-90 and others noted above NOTES: (1) Where surface contamination by both alpha- and beta-gamma-emitting nuclides exists, the limits established for alpha- and i beta-gamma-emitting nuclides should apply independently. (2) As used in this table, dpa (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate j detector for background, efficiency, and geometric factors i associated with the instrumentation. .. l
. Rev. 0 5/9/83
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Attachment 2 OPIP 3.10.1 Page 3 of 8 I Task , Responsible Individual '
- h. Public Dose Commitment Radiation Health Coordinator
- 1. Environmental Health Services Coordinator Decontamination J. Transportation Evacuation Coordinator
- k. Traffic Control Evacuation Coordinator
- 1. Communicat'.ons Manager of Local Response
- m. Security Support Services Coordinator
- n. Public Information Coordinator of Public Information 5.2.1 The Recovery Action Committee will perform the actions identified in Sections 5.3, 5.4, and 5.5 of this procedure.
5.3 Initial Recovery /Re-Entry Actions 5.3.1 The Nuclear Engineer will review the plant status and ensure that the plant is stable, no significant releases occurring, and other requirements for entering the recovery phase are satisfied. 5.3.2 The Radiation Health Coordinator will:
- a. Direct that surveys of the affected area be initiated. These surveys will include the following as appropriate:
- 1. Air Monitoring
- 2. Ingestion Pathway Sampling - Surface water (including lakes, ponds, and sumps), potable water, milk, crops (vegetables, fruit), forage, fin fish,
. shell fish
- 3. Environmental Survey - Ground, equipment, structures, vehicles
- b. An area will be considered contaminated if:
o Evaluation of environmental monitoring ' results, plant data, and/or laboratory analysis of isotopes shows that direct constant exposure and inhalation of resuspended particulates for one year ' (allowing for radioactive decay) will result in a dose greater than 500 mR to
, wholebody or equivalent to any organ.
Rev. 4
OPIP 3.10.1 Page 4 of 8 o Applicable,models for this calculation are contained in Regulatory Guide 1.109 and WASH 1400. o Also compare results with Attachment 1 of OPIP 3.6.6 for ingestion pathway considerations.
- c. Advise the Manager of Local Response as to the results of the surveys and the indicated actions.
5.3.3 The Manager of Local Response will convene the Recovery Action Committee to discuss the status of tasks enumerated in Section 5.2 in preparation for re-entry. 5.3.4 The Manager of Local Response will indicate to the Director of Local Response when all facets of the re-entry operation are determined to be ready. i 5.3.5 The Director of Local Response will authorize the r initiation of the re-entry operation. I 5.3.6 The Support Services Coordinator advises the 4 American Red Cross to begin deactivation of the ' relocation centers. 5.3.7 All Recovery Action Committee coordinators notify the members of the response organization that l re-entry operations are initiated. 5.3.8 Either the Radiation Health Coordinator or the U.S. Environmental Protection Agency Office of Radiation Programs in accordance with their FRMAP j assessment functions estimates total population exposure. 5.4 Re-Entry - Permanent (Note: Re-Entry / Temporary is detailed in Section 5.5) The Recovery Action Committee gives consideration to the number of people that have been evacuated, the transpor-tation needs (including special), and the logistics at the relocation centers. Re-entry actions may vary depending upon the specific emergency conditions. Following are the three major re-entry scenarios: 5.4.1 The radiological emergency involved an evacuation but did not involve a radiolog'ical release. The
- Manager of Local Response will direct the appro-priate Recovery Action Committee members to idi-tiace these tasks: '
i Rev. 4
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Attachment 3 , 1 Chapter l-Neelser Reguletory Commission f 20.106 protective equipment is first a used i under the provisions of this section. to receive a dose to the whole body in any period of one calendar year in (41 FR 52301. Nov.29,1976. as amended at excess of 0.5 rem, 43 FR 29270, July 1,197s; 47 FR 161s4. As.,r. (b) Except as authorized by the 15.16 21 Commission pursuant to paragraph (a) I 20.194 Exposurvet minors. of this section, no licensee shall pos. sess, use or transfer licensed material (a) No licensee shall possess, use, or in such a manner as to create in any transfer licensed material in such a unrestricted area from radioactive ma. manner as to muse any individual terial and other sources of radiation in within a restricted area who is under his possession: 18 years of aer to receive in any (1) Radiation levels which, if an indl. period of one calendar quarter from vidual were continuously present in radioactive material and other sources the area, could result in his recel ing a of radiation in the licensee's posses, dose in excess of two millirems in any sion a cose in essess of 10 percent of one hour, or the limits specited in the table in (2) Radiation levels which, if an indl. paragraph (a) of (20.101. vidual were continuously present in (b) No licensee shall possess, use or the area, could result in his receiving a transfer licensed material in such a dose in excess of 100 millirems in any manner as to cause any individua] seven consecutive days. within a restrictet area, who is under (c) In addition to other requirements 18 years of age to be exposed to air. borne radioactive material possessed of this I, art, licensees engaged in ura-by the licensee la an average concen. nium fuel cycle operations subject to tration in excess af the limits specified the provisions of 40 CFR Part 190, in Appendix B 'Mle II of this part. " Environmental Radiation Protection For purposes o,f this paragraph, con. ations," Standards for Nuclear Power Oper. shall cornply with that part. centrations may he averaged over peri. ods not greater than a weelt. (25 FR 10914, Nov.17,1960, and to FR 18526. Mar. 25,1981) (c) The provislams of iI 20.103(b)(2) a and 20.103(c) shat apply to exposures I 20.106 Radioactivity in effluents to un. subject to parastaph (b) of this sec. restricted areas. tion except that the references in ll 20.103(b)(2) and 20.103(c) to Appen. (a) A licensee shall not possess, use dix B. Table I, Column 1 shall be or transfer licensed material so as t$ ' deemed to be references to Appendix release to an unrestricted area radioac. B Table II, Coluna 1. tive material in concentrations which exceed the limits specified in Appen.
; 125 FR 10914. Nov.
41 FR 52302, Nov. 29.19761N.1960, as amerded at dix B. Table II of this part, except as authorized pursuant to i 20.302 or
#20.105 Permiselbielevels of radiation in paragraph (b) of this section. For pur.
unrestricted arest poses of this settion concentrations may be averaged over a period not (a) There may beincluded in any ap. greater than one year. plication for a llomse or for amend. (b) An application for a license or ment of a license proposed limits upon amendment may include proposed levels of radiatian in tanrestricted limits higher than those specified in areas resulting from the applicant's paragraph (a) of this section. The possession or use W radioactive mate. rial and other sources of radiation, Commission limits if the will soprove applicant the proposed demonstrates: i Such applications should include in. (1) That the applicant has made a formation as to antitipated average ts. reasonable effort to minimize the ra. diation levels and anticipated occupan. dioactivity contained in effluents to cy times for each unrestricted ares in. unrestricted areas; and volved. The Commission will approve the proposed limits if the applicant (2) That it is not likely that radioac. demonstrates that te proposed limita tive material discharged in the efflu. ent would result in the exposure of an are not likely to casse any individual individual to concentrations of radio. 239 ( . l l
Attactunent 4 New York State Radiological Emergency Preparedness Plan o PART I SECTION IV
- IV. RECOVERY A. INTRODUCTION As provided by the New York State Disaster Preparedness Plan, a Recovery Committee having authority and major responsibilites to make decisions relating to recovery activities will be appointed by the Disaster Preparedness Commission (OPC).
This committee will be comprised of representatives of the Commission's membership, and such other agencies as the Commission Chairman may designate. Specifically included will be representatives of the Departments of Agriculture and Markets, Commerce, Health. Environmental Conservation, Labor, Social Services, State, Transportation Of fice of General Services, State Energy Of fice, Public Service Commission, Division of State Police and Division of Military and Naval Affairs / Office of Disaster Preparedness.
- 8. RESPONSIBILITIES The Committee is responsible for directing State resources and recovery activities and for assisting in the total cooperative ef fort involving roles any or all of the other organizations having recognized in recovery. During recovery operations the Committee is responsible for developing practical time parameters and activities consistent with this plan, and insures that there are adequate communications systems and processes for all State activities. The Committee reports to the DPC and keeps it apprised of all matters relating to the recovery effort.
The New York State Commissioner of Health continues to have the primary responsibility for recommending protective actions; for overseeing the total related radiological program; and for modifying, relaxing, and discontinuing protective actions. The Director of the Of fice of Olsaster Preparedness (00P) coordinates State and Federal assistance and programs with perceived needs and the requests of the local jurisdictions. Local Chiefwith conjunction Executives the Office assess thePreparedness. of Disaster needs of their affected areas in They direct recovery operations in their jurisdictions. TheTitle by Governor may appoint VI!!, Section 802 aofRecovery the u Planning Council (as designated
- a blic Works and Economic I Development Act of 1965, as added by Title V of Public Law 93-288 -
"Therecovery the Olsastereffort.
Relief Act of 1974") to help determine local needs in
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IV-1 Pev2 11/82
C. OPEP.ATIONS Reco'fery operations cocmence as soon as the situation is stabilized - and involves the following four major considerations: e Detemination of the recovery actions to be taken, o Dissemination of infomation on the appropriate recovery action. e Provision of available State and Federal disaster assistance to affected areas. o Pequirements for continued nonitoring.
- 1. A general consideration for lif ting any protective action initiated as a result of the emergency takes into account the benefit received fron the reouction of the projected dose, should the protective measures continue, against the social and economic costs of continuing the action taken. However, initiated protective actions for the general population will not be relaxed as long as the projected dose commitment exceeds 500 mrem.
Certain individuals may be allowe ! eentry to an affected area if : the situation warrants. An example is the famer who must tend his livestock. In this case the famer is treated as an l emergency worker, given personal dosimetry equipment and l energency worker exposure levels apply. In detemining the projected dose commitment all possible , exposure pathways are considered. These include:
- a. External exposure resulting from surface contamination and
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all projected future atmospheric releases related to the accident.
/ b. Ingestion of contaminated milk, or other agricultural .
products, or water,
- c. Inhalation of radionuclides resulting fron resuspenstori of deposited material or from projected atmospheric releases resulting from the accident.
Factors to be considered in assuring that the lifting of protective measures will not ' result in undue risk to public health include the following:
- a. Samoling and conitoring of radiation and evaluation of data by the Department of Health,
- b. Decentamination activities, including waste disposal, under the direction of the Ce1artment of Health, undertaken by the appropriate local agency depending on the method utilized.
, c. Seturity, including police and fire protection for affected areas -- util be provided by State and local police, and local fire agencies. ,,
-d. Availability of medical service -- will be ascertained by State and local health officials.
IV-2 - Rev. 11/63
- e. Availability of electric power and telephone communications
-- will be ascertained by Public Service Commission.
- f. Adecuacy of food and water supply -- will be detemined by -
Department of Agriculture a,nd Markets and Department of He al th. -
- g. Operability of sanitary systens -- will be detemined by Department of Environmental Conservation.
- h. Availability of transportation -- will be detemined by local of ficial s.
- 1. Availability of sources of heat -- will be ascertained by -
State Energy Office.
- j. Condition and needs of the affected population -- will be surveyed and determined by Department of Social Services with '
assistance from the American flational Red Cross.
- 2. nissnenination to the public of infomation pertaining to recovery actions commences after consideration has been given to the following factors:
a. The status of the services and conditions enumerated in the
! preceding portion of this plan. This includes infomation
' and guidance on methods the public should employ to overcome existing deficiencies, i.e., sources of emergency water supplies, restrictions on use of all non-canned foodstuffs, etc. I
- b. The consistency of public announcements between all levels of government.
The Public Infomation Officers and affected I County Public Infomation Officers coordinate such releases with each other before they are issued.
- c. The methods by which these announcements are made depends in large part on the existing situation and the affected areas.
Television and commercial radio broadcasts are the primary means of dissemination. Follow-up newspaper articles are also used. In special cases printed handouts and voice comunications are used for Congregate Care Centers and i similar facilities.
- 3. State an'd Federal assistance can be nade available to assist affected counties in recovering from the effects of a radiological energency.
Article 2-B of the !!ew York State Executive Law provides that when the Governor declares a disaster emergency for an affected area he may direct any and all agencies of the State government to provide assistance under the coordination of the DPC. Such 1 State assistance may include: -
- a. utilizing, lending, or giving to political suodivisions, with or without compensation therefor, equipment, supplies, 4
IV-3 'Rev. 11/83
l facilities, services of State personnel, a-d other resources, other than the extension of credit; I i'
- b. distributing medicine, medica.1 supplies, food and other consumable supplie's through any public or private agency authorized to distribute the same;
- c. performing on public or private lands temporary emergency work essential for the protection of public health and safety, clearing debris and wreckage, making emergency repairs to and temporary replacements of public facilities of political subdivisions damaged or destroyed as a result of
- such disaster; and
- d. making such other use of their facilities, equipment, supplies and personnel as may be necessary, i
The Chief Executive officer of any af fected county which has need of Federal disaster assistance accumulates and submits through ' 1 00P District of fice to the Director, ODP, data as required by Public Law 93-288 and appropriate regulations. This data will be submitted to the Governor through the Recovery Committee and the ! Chairman of the Disaster Preparedness Commission with a i recommendation as to whether the Governor should request the President to declare an Emergency or Disaster as defined by j Public Law 93-288. If such a request is made and granted, the Federal assistance which will then be provided would be administered by the Director. 00P, for the Recovery Committee, appropriate State agencies and local governments in accordance with procedures adopted for use in administering raderal aid for any other type of an emergency or disaster declared by the , , President. In instances where a Presidential declaration is ei';her n6t requested or granted, specific types of Federal assistancy may be i provided by individual Federal agencies acting within their own ] i statutory authorities. The Governor may request such assistance, based on recommendations of the Director of the Office of Disaster Preparedness and the Recovery Committee which will be submitted through the Chairman of the Disaster Preparedness
. Comi s s ion .
- 4. A radiation monitoring pogram for contaminated areas will be
, established by the State Comissioner of Health. This monitoring program may be long term depending upon the type, levels, and extent of the contamination. The monitoring will also take into account the nature of the contamination as well as the area affected. Future activities affecting release of radiation (venting, etc.) will also require monitoring. Other State ' agencies will cooperate and assist the Department of Health in monitoring for long term effects. Monitoring programs will continue until acceptable levels are reached. , l s l Medical follow-up to monitor the ef fects of radiation on the public and emergency workers af ter the incident may be established, if required. Currently, the State Department of IV-4 Rev. 11/83
Health conducts an ongoing study or selected health statistics f or counties with and without nuclear facilities as 'part of its epidemiological program. This program will be enhanced in the event of a radiological emergency. All personnel monitoring equipment distributed during the emergency will be collected, assuring that exposure records for emergency workers are complete. 4 1 1 i l i l
~
' IV-5 p,y, tijg3
c. Attachment 5 OPIP 3.10.1 Page 5 of 8 Use the following procedure'for these situations: 5.5.1 The Health Services Coordinator considers the request to re-e:ter the evacuated area and makes his decision based on the latest radiological surveys, the circu= stances involved, and the cost-benefit analysis provided by the NRC in 10 CFR Part 50, Appendix I, Section IID. CAUTION PERMISSION IS TO BE AUTEORIZED ONLY FOR A SPECIFIC DESTINATION AND TIME PERIOD. 5.5.2 The individual vill be directed to report to a staging area near the destination. The staging area will be advised of the special re-entry pe rmis sion. 5.5.3 The re-entering individual is assigned an escort with a vehicle to provide transportation and radiological so:itoring capability. 5.5.4 The re-entering person is assigned personnel - dosimetry, if necessary. 5.5.5 The group may net deviate from the designated destination nor the allotted time. 5.5.6 Upon exit, the individuals report to the Brentwood Emergency Worker Decontamination facility to be checked. 5.6 The Director of Local Response may halt or reverse the recovery /re-entry operation when a change of conditions warrants such actions. l .i
6.0 REFERENCES
6.1 U.S. Nuclear Regulatory Co= mission, Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors," June 1974. Rev. 3
Attachment 6 i OPIP 3.10.1 i Page 7 of 8 k . 5.5 Re-Entry - Temporary - i . There are situations wharein the evacuated zone must be re-entered by civilians either during the radiological emergency or after it--when the area has not been radio- ' logically cleared for re-entry. Such situations may include the need to turn off/on utilities, attend to livestock, fight a fire, or other matters of a pressing nature. In these instances the individual (s) seeking temporary re-entry contact (s) the Health Services Coor- , dinator at the Local Emergency Response Organization at the Emergency Operations Center in Brentwood. Use the following procedura for these situations: 5.5.1 The Health Services Coordinator considers the request to re-enter the evacuated area and makes his decision based on the latest radiological surveys, the circumstances involved, and - emergency dose limitationa consistant with the Environmental Protection Agency Protective Action Guidelines for the general public. CADTION
~
i PERMISSION IS TO BE AUTBORIZED ONLY FtR A SPECIFIC DESTINATION AND TIME PEEIOD..
\
l } S.S.2 The individus1 vill be directe'd to report to a staging area near the destination. The staging area vill be advised of the special re-entry
- permission.
I
. 5.5.3 The re-entering individual is assigned an escort with a vehicle to provide transportation and radiological monitoring capability.
3 5.5.4 The re-entering person is assigned personnel dosimetry, if necessary. 1 5.5.5 The group may not deviate from the designated - destination ser the allotted time, 5.5.6 Upon exit, the individuals report to the Brentwood En ey Verkar Decontamination facility to be
- , - . - - - - - , , , - - - - ~~
t, . l
.o -
\
' Attachment 7
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LILCO, July 3,- 1984 CERTIFICATD OF SERVI'CE E4 '- -3 P 2 E b In the Matter of . . ;- LONG ISLAND LIGHTING COMPANY UiMM (Shoreham Nuclear Power Station, Unit 1) (Emergency Planning Proceeding) Docket No. 50-322-OL-3 I certify that copies of LILCO'S MOTION TO ADMIT SUPPLEMENTAL TESTIMONY ON CON-TENTION 85 (RECOVERY AND REENTRY) LILCO'S SUPPLEMENTAL TESTIMONY ON CONTENTION 85 (RECOV-ERY AND REENTRY) LILCO'S MOTION TO ADMIT LILCO'S REVISED TESTIMONY ON CONTENTION 88 (DOSE CRITERIA AND COST-BE!!EFIT ANALYSIS FOR REENTRY) LILCO'S REVISED TESTIMONY ON CONTENTION 88 (DOSE CRITERIA AND COST-BENFIT ANALYSIS FOR REENTRY) were served this date upon the following by first-class mail, postage prepaid, or (as fndicated by one asterisk) by Federal Express. James A. Laurenson, Secretary of the Commission Chairman
- U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C. 20555 U.S. Nuclear' Regulatory Commission Atomic Safety and Licensing East-West Tower, Room 402A Appeal Board Panel 4350 East-West Hwy. U.S. Nuclear Regulatory Bethesda, MD 20815 Commission Washington, D.C. 20555 Dr. Jerry R. Kline*
Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission - East-West Tower, Rm. 427 Washington, D.C. 20555 4350 East-West. Hwy. - Bethesda, MD 20814
. 1 s
Mr. Frederick J. Shon* Bernard M.'Borcenick, Esq.* Atomic Safety and Licensing Oreste Russ Pirfo, Esq. Board Edwin J. Reis, Esq. U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East-West Tower, Rm. 430 7735 Old Georgetown Road 4350 East-West Hwy. (to mailroom) Bethesda, MD 20814 Bethesda, MD 20814 Eleanor L. Frucci, Esq.* Stewart M. Glass, Esq.* Attorney Regional Counsel Atomic Safety and Licensing Federal Emergency Management Board Panel Agency U.S. Nuclear Regulatory 26 Federal Plaza, Room 1349 Commission New York, New York 10278 East-West Tower, North Tower 4350 East-West Hwy. Stephen B. Latham, Esq.* Bethesda, MD 20814 John F. Shea, Esq. Twomey, Latham & Shea Fabian G. Palomino, Esq.* 33 West Second Street Special Counsel to the P.O. Box 398 Governor Riverhead, NY 11901 Executive Chamber Room 229 Ralph Shapiro, Esq.* State Capitol Cammer & Shapiro, P.C. Albany, Nev York 12224 9 East 40th Street
- New York, New York 10016 Herbert H. Brown, Esq.*
Lawrence Coe Lanpher, Esq. James B. Dougherty, Esq. Christopher M. McMurray, Esq. 3045 Porter Street Kirkpatrick, Lockhar t, Hill, Washington, D.C. 20008 Christopher & Phillips 8th Floor Jonathan D. Feinberg, Esq. 1900 M Street, N.W. New York State Public Service Washington, D.C. 20036 Commission, Staff Counsel 3 Rockefeller Plaza MHB Technical Associates Albany, New York 12223 1723 Hamilton Avenue Suite K Spence W. Perry, Esq.* San Jose, California 95125 Associate General Counsel Federal Emergency Management Mr. Jay Dunkleberger Agency New York State Energy Office 500 C Street, S.W., Rm. 840 Agency Building 2 Washington, D.C. 20472 Empire State Plaza Albany, New York 12223 Ms. Nora Bredes - Executive Coordinator Shoreham Opponents' Coalition 195 East Main Street Smithtown, New York 11787
s 4 Gerald C. Crotty, Esq.* Martin Bradley Ashare, Esq. Counsel to the Governor Suffolk County Attorney Executive Chamber H. Lee Dennison Building
- State Capitol Veterans Memorial Highway Albany, New York 12224 Hauppauge, New York 11788 o 2 Renee R. Falzone Hunton & Williams 707 East Main Street Post Office Box 1535 Richmond, Virginia 23212 DATED
- July 3, 1984 t
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