ML20093C454
| ML20093C454 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Shoreham |
| Issue date: | 12/28/1983 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Krimm R Federal Emergency Management Agency |
| Shared Package | |
| ML20093C457 | List: |
| References | |
| NUDOCS 8401120539 | |
| Download: ML20093C454 (1) | |
Text
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DEC t 81983 MEMORANDUM FOR:
Richard W. Krimm, Assistant Associate Director
,,,, Office of Natural and Technological Hazards Programs Q
Federal Emergency Management Agency FROM:
- ' Edward L. Jordan, Director
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Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
SUBJECT:
THE FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA) SUPPORT FOR THE NUCLEAR REGULATORY COP 91ISSION (NRC) LICENSING OF SHOREHAM NUCLEAR STATION As promised in my December 22, 1983 memorandum to you, I am transmitting herewith one copy of the Long Island Lighting Company's Revision 3 to the LILCO Transition Plan for Shoreham.
LILCO informs us that they have transmitted 15 copies of Revision 3 to your Regional RAC Chairman.
LILCO has also stated that this Revision does not make significant changes but rather sets forth matters of modification and clarification.
We thank you for your continued support and look forward to receiving your report on February 1,1984 as previously agreed.
Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
Enclosure:
As stated cc w/o encl:
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MEMORANDUM F01:.$ ward L. Jordan
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'4 Dire ~ctor, Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U.S. Nuclear Re story Commission YJ s
- yggy, Assistant Associate Director Office of Natural and Technological Hazards Programs
SUBJECT:
Regional Assistance Committee (RAC) Review of Long Island Lighting Company (LILCO) Transition Plan for the Shoreham Nuclear Power Station On October 27, 1983, the Federal T,mergency Management Agency (FEMA) asked for an-extension of 60 days (i.e., until February 1,1984) to complete a thorough, detailed RAC review of Revision 1 of the LILCO Transition Plan for the Shoreham Nuclear Power Station. Via your memorandum of November 10,1983, the Nuclear Regulatory Commission (NRC) granted that extension but requested that FEMA include Revision 2 in the RAC review.
This had aircady been delivered to RAC members.
In addition, via a letter of December 8, 1983, from Hunton and Williams, legal counsel for LILCO, FEMA received an amended list of effective pages of Revision 2.
Finally, on December 14, 1983, FEMA was notified by Hunton and Williams that Revision 3 of the plan would be received during the week of December 19, 1983.
FEMA vill make every effort to complete the review of the LILCO Transition Plan including Revisions 2 and 3 as close to February 1,1984 as possible provided we receive the required material from LILCO no later than Jauuary 3,1984.
However, based on a preliminary examination of Revision 2 and preliminary information on Revision 3, some additional time beyond the originally projected date of February 1, 1984, will probably be needed to assure a comprehensive.
analysis of the plans by a full RAC review.
In order to give FEMA's analysis q
and finding to NRC as soon as possible, we will need prompt distribution of the Z
Q) collated LILCO Transition Plan to all RAC members no later than January 3,1984, including Revision 3, with appropriate cross-references to NUREG-0654.
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I our. understanding that LILCO intends to provide FEMA and the RAC members with.
comprehensive plans that incorporate both Revisions 2 and 3.
Upon receipt of-
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I these plans and the cross-referencing mentioned below, a full, independent RAC review will begin.
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' k In the interest of efficiency and ef fective utilization of RAC members and FEMA's b
resources, we request that the utility also prepare a matrix which identifies h
page changes affected by each revision of the plan with references to NUREG-0654.
This matrix should be updated with each revision that is submitted in order to S
i i provide all reviewers with a chronological record of changes that have been
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affected. This matrix will facilitate quick reference to specific pages and h
allow reviewers to more readily assess the quality and effect of the changes that have been instituted as the plan and procedures have evolved to their current status.
The suggested format is provided in the Attachment 1.
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.Ni-In addition to ihe above matrix, FEMA also requests that a narrative description of the reason (s);for each change (i.e., actions, clarifications, etc. in response to FEMA comments, contentions, improvements, minor changes, etc.) be. stbmitted with each revisioh 'of the plan and procedures.
This narrative description should also be indexed by NMEG-0654 element.
At present, we have a substantial workload associated with operating nuclear reactors which will have to be postponed if FEMA attempts to meet the February 1,1984, deadline.
s The Regional Assistance Committee has other agency commitments in addition to the REP work for our Region and cannot devote 100% of their time to Shoreham.
As a result of this effort for Shoreham, FEMA /RAC may delay the completion of 44 CFR 350 reports for the operating nuclear reactors in the Region.
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~ Region H 26 Feders! Plaza Deccter 21, 1983 D=ald Irwin, Izq.
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Dear.t. Lvin:
mis '.ec.ar vill c=firt c= cc:rarsatien of this rerning. First, ycu infered te that you ucdd be sending to each w,0 re:-bar a fully assetled e-d collated TM Transitien Plan including Pavisien 3 with aw. # ate i
crcss-referange tc tra.u,-0654.
In a!.ditien, ycu agreed in the interest cf efficiency a:d effec *ha utilizatien cf m e.d U.0 resc=ces that 7"m will prepare a entrix stich ide.tifies page changes affected by aa6 re/isica cf the plan with reference tc tras,-0554. mis retrix sh::cid be updatad to include each re-visic. that has been er will be rdr-itted in crder to previde all redevers with a chrenclogical reccrd cf cha.wss that have been effected. mis rutrix vill facilitate quick reference to specific pages and allcw reviewe.rs to
-cre r**d'ly essess the g.ality and affect cf the changes that hree been instite.ed as the plan and procedures hax reiwd to their current status.
We s' ggested ferat is previded in Attac.:n.t 1.
5 In additien to the abe m retrix, m also requests that a narrative descriptien of the reascn(s) fer ea::h change as previded v.th Pavisiens 1 and 2 te sd mitted with each revisien of the plan and procedures. 21s nana: Ave description abruld centinue to be indexed by it.au-0554 eierent..
b.ank you fer ycc: assistance in this ratter'.
si:u:erely, 4
2, M 3 Stewart M. Gle.ss um w f,)
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L JAN I 31984 MEMORANDUM FOR:
Edward L. Jordan Director, Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission dn FROM:
c ard W. Krima Assistant Associate Director Office of Natural and Technological Hazards
SUBJECT:
Regional Assistance Committee (RAC) Review of Long Island Lighting Company (LILCO) Transition Plan for the Shoreham Nuclear Power Station This is to inform you that the Federal Emergency Management Agency (FEMA)
Region II staff has confirmed the receipt by all RAC members of the revised transition plan for Shoreham.
The plan (one set) consists of four volumes and incorporates revicions 0, 1, 2, and 3.
The FEMA Region II office received four sets of the revised plan on December 30, 1983.
In addition, a revised NUREG-0654 cross-reference was provided along with a clarifying letter from LILCO.
Although the revised cross-reference is helpful, the utility did not provide the matrix (that was requested in FEMA's December 22, 1983, memorandum) identifying page changes affected by each revision of the plan with reference to NUREG-0654.
Members of the FEMA Region II staff have nade inquiries into this matter and expect clarification from LILCO's counsel shortly.
We vill, of course, continue the review of the revised Shoreham plan.
As we noted in our December 22, 1983, memorandum, we vill make every effort to complete the review as close to February 1,1984, as possible, although some additional time may be needed to assure a comprehensive analysis of the plans by a full RAC review.
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Dear Mr. Dircks:
s Given the recent interpretation of Governor Cuomo on behalf of 4
New York State as to the'1egal authority.of Lilco to implement its emergency plan; should FEMA continue, modify er terminate i
the NRC requested review of the Lilco Plan?
Sincerely, u).
amuel W. Speck Associate Director State and Local Programs and Support
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January 26, 1984 Mr. Samuel W. Speck Associate Director State and Local Programs and Support Federal Emergency Management Agency Washington, DC 20472
Dear fir. Speck:
This is in response to your letter of January 25, 1984, inquiring as to whether FEMA should continue, modify or terminate its review of the LILCO off-site emer-gency plan for the Shoreham facility.
In that FEMA's review will be an essential ingredient in the Licensing Board's ultimate determination on the adequacy and implementability of LILCO's proposed emergency plan, I would request that FEMA continue its review of the plan.
In addition, because of the schedule previously set by the Licensing Board in the engoing Shoreham proceeding, I would appreciate y
every effort you could make to insure that FEMA's review of the LILCO plan is completed..by the previously agreed-upon date of February 1,1984.
Thank you for your assistance in this matter.
Sincerely, lib'W Gflm i. c!rr.t-William J. Dircks Executive Director for Operations DISTRIBUTION:
W.Dircks EDO R/F (14006)
E.Christenbury(Chon)
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Executive Director for Operatiou D.'S." Nuclear Regulatory Commission Washington, D.C. j20555
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Der.r Mr. Dircks:
In a June 1,.1983 memoratium, the Unclear Regulatory Cosenission (NRG) invoked Section 11.4 'of the November 1,1980, NRC/ Federal Emergency Mahagement Agency (FDiA) Memorandum ~ of Understanding (MOU) by requesting FEMA to provide the NRC'with findings and determinations as to whether the Long Island Lighting Company. (LILCO)-County plan and/or the interim plans of the Shoreham Wutlear Pm er Station are adequate. and capable of implementation.
As a result of an' Atomic Safety and Licensing Board (ASLB) order, t subsequent memorandum of June 17, 1983, requested that FEMA provide findings and determinations on the LILCO Transition Plan as a first priority.
This Plan, developed and revised wholly by LILCO; 7.roposes to use primarily LILCO personnel to carry out the offsite
, preparedness aspects of.the plan (to include the total direction and centrol fr.netton) in the -case of an esergency involving an accident at the Shoreham Nuclear Power Station.
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on June' 23, 1963, FD'A provided findings on the LILCO Transition Plan.
However, primarily due to the short' time frame available for evaluation of the Plan, it was necessary to obtain the support of Argonne National Laboratory to perforn a technical, review against the standards and evaluative
- criteria of N'JREG-06S4/FDiA-REP-1, Rev. 1.
EIMA Headquarters, assisted by che FEMA Engion II Regional Director and staff, directed this. technical review.
When subsequent developments eventually indicated a change in the ;;imetable for the Shoreham licensing process, NRC requested on September 15,1983, that FDiA initiate a' full and independent review by the Regional Assistance Committee (RAC) of Revision 1 of the Transition Plan.
This request was late. modified to include findings on Revision 3 of the Transition Plan.
Those findings are presented 'in this letter.
The RAC reviewed the Plan against the standards and evaluative criteria of NUREG-0654/IEMA-REP-1, Rev. 1.r Due to the legal authority issues whfch arise when seme NUREG elements are applied to a utility-based plan; we have raarked with an asterisk any aspect of the plan where, in our view,,this legal issue occurs.
The specific legal concern related
'; to that part ei the plan is identified separately in Attachment 2 of the FDiA finding. With the exception of plan aspects relating to NUREG Q a lenent A.2.b. (a requirement to state, by reference to ' specific acts,
- P^t\\. statutes, or codes, the legal basis for the authority to carry out the i
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' responsibilities listed in A.2.a., i.e., all major response functions),
the legalr concerm did not affect the FDfA rating given to the technical or operational items relating to NUREG elements.
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~2-FEMA finds that '!evision 3 of the LILCO Transition Plan has 32 inadequacies based on the standards and evaluative criteria of NUREG-0654/ FEMA-REP-1, 4,
Rev. 1.
The analysis resulting from the full RAC review and relating these inadequacies to_the various NUREG-0654/ FEMA-REP-1, Rev. 1, criteria is enclosed as Attachment 1.
The FEMA approach to evaluation of offsite emergency planning and preparedness under 44 CFR 350 and the MOU has been closely focused on the relationship between State,and local governments and the licensee, as well as State and local plans and implementing capability.
Notwithstanding the legal authority issue and the need for an adequate exercise of the offsite plan, there are many other f actors which we do not evaluate in the course,of our analysis that in our judgement should be concidered by the Commission in a total assessment of whether successful offsite emergency operations at a giveu nuclear power plant are possible in an actual emergency to provide adequate assurance of public health and safety protection.
Among the additional factors to be reasonably weighed are the existence of a Federal radiological response plan and implementing capability for nuclear power plant emergencies; the known legal responsibility of State and local officials to'.' respond to emergencies and known resources available to these entities for making an effective response; and, in the case of the Shoreham nuclear power plant, the
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existence of company plans and resources albeit with the deficiencies noted in the enclosed report of FEMA's Region II.
a It is our belief, for example, that in the event of an accident at the Shoreham site, the Governor would request Federal assistance and the Federal Radiological Emergsney Response Plan (FRERP) could well be activated.
That Federal plan has been under development for several years pursuant to a requirement of Section 304 of the NRC Appropriation Authorization Act, June 30,1980 (P.L.96-295), and Executive Order 12241 that a Federal ' plan for radiological emergencies be prepared that provides assurance of p'ublic health and safety protection.
The FRERP is applicable to all nuclear power plant sites as a supplement to State, local and utility resources.
A full field exercise of.the FRERP was conducted from March 6-8, 1984, at the St. Lucie Nuclear Power Station in Florida, to test more. thoroughly and completely the i
capabilities required by the plan.
The developing capability made available by the FRERP should be recognised when NRC considers the FEMA finding on the technical review of the LILCO Transition Plan.
Al'so,. consist:ent with directions from th'e l resident and.with FEMA's legal i
i mandates under the Federal Civil Defense Act, we are implementing a new emergency planning and assistance concept to enhance State and local capabilities to prepare for and respond to a broad range of natural and peacetime emergencies.
Under title'V of the Act. this applies in particular to improvements in State and local offsite readiness for commercial nuclear reactors and we are now planning to direct significant levels of new emergency management assistance resources"in FY 1985 into this important area.
Key programs vill include O
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' e y-t redirection of 3 tate 'and local emergency services personnel towards projects that support offsite nuclear f acility safety, redirection of assignments to Federal radiological planning officals to concentrate on offsite safety and enhanced programs in training and education for Federal, State, local and utility employees for nuclear safety issues regarding protection of the public.
FEMA is prepared to assist the utility, in conjunction with the NRC, with any technical assistance that it can offer to improve the plan which the company Ralevara FEMA training courses can be made available to utility has prepared.
emergency workers on a reimbursable basis.
We have tried to provide information above on additional factors which may come into play if NRC is to make a total assessment of the offsite preparedness capability at Shoreham.
I would suggest that the Commission may wish to think of offsite safety as a mosaic that may very well be composed of different pieces at di2ferent times and places.
Not all of the potential components will necessarily f all within the ambit of the FEMA plan and response evaluation process in all cases.
If you have any questions, please don't hesitate to call me.
Sincerely, t <N g,
l3amuel W. Speck Associate Director State and Local Programs and Support Enclosures
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