ML20094M768
| ML20094M768 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/27/1992 |
| From: | Leslie Hill, Leonard J LONG ISLAND LIGHTING CO., LONG ISLAND POWER AUTHORITY |
| To: | |
| Shared Package | |
| ML20094M752 | List: |
| References | |
| PROC-920327, NUDOCS 9204020002 | |
| Download: ML20094M768 (12) | |
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Joint Contingency Plan Of The Long Island Lighting Company And Long Island Power Authority Required By NRC Order Approving Shoreham License Transfer - February 29, 1992 ts Lb e? h/ .Y'7/hi
< h Appr6ve : J. D. Leonard, Jr. gati Ap'p' roved : L. M. Hill, 'D a tie Vice Pre ident - Office of l Reeident Manager Corporat. Services and ,
/ Shoreham Nuclear Power
/ GE Tiesident - Office of Station, Long Island Nuclear, Long Island Power Authority Lighting Company m-
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- - 2 pint continoency Plan Of LILCO And LIPA i
I. Purpose /Obiective This Joint Contingency Plan establishes the overall framework whereby LILCO shall retain and maintain adequate capability and qualifications ,
to promptly take over the Shoreham NRC license in the event that LIPA either ceases to exist or is otherwise found to be unqualified to hold the license. This Contingency Plan fulfills the requirements of the NRC Order Approving Transfer of License that was issued to LIPA and LILCO on February 29, 1992. This Contingency Plan shall remain in effec ~t until the Shoreham Nr4 license has been terminated.
The Contingency Plan was developed to ensure a' safe, smooth and orderly transfer of control of Shoreham, including any ongoing physical activities, from LIPA to LILCO if required. The followit.g sections of the Contingency Plan address now such a transfer of control would occur, ,
including:
- 1) The immediate actions that would be taken n' the tims 't is determined that transfer of control of St.crenam to LILCO is required;
- 2) The means whereby LILCO shall maintain adequais capability and qualifications to implement such ime.saitts act1'ns; and
- 3) The features in place and the ene ".ing actions that have been or are being taken by LILCO and L!PA tt;t will facilitate prompt implementation of such immedi *.e actione II. Achievino A Safe,~ Smooth And Orderly fransler Achieving a safe, smooth and orderly transfer from LIPA to LILCO, with.
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no lapses.in attr. tion to applicable safeguards, would entail the following immediate actions o Qualified .7L'O personnel'(or qualified contractor perronnel under LILCO supsc. sion) would assume the professional, technical, j managerial, and administrative positions and functions of the LIPA 1
Shoreham organization;
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' Essential' functions provided by contractors, labor organizations,
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- andLof f site agencies in support of the Shoreham Possession Only, License (POL) and. Technical Specifications obligations would be transferred to LILoo;-
o Regulatory authorization to conduct activities essential for ~
compliance with.tho Shoreham POL and Technical Specifications would be transferred to LILCO. ,
Each-of these' areas is addressed below.
A) Assumption of the professional, technical, managerial, and administrative positions and functions of the LIPA'Shoreham oraanization by LILCO or cont racter tersonnel LILCO or contractor personnel presently hold nearly ninety percent of the professional, technical, managerial and administrative j positions in the LIPA Shcreham organ l n. These positions are largely -identical to-or similar to the positions held by such-personnel under LILCO's previous ownership of Shoreham. LIPA requires that all personnel at Shoreham, including LILCo and contractor personnel, maintain suitable qualifications to hold their positions, and-that-appropriate qualification recordo be kept in the LIPA Shoreham Training and Qualification System. This administrative tracking system was developed by-and is administered by LILCO's Office of Corporate Services (Training Department).
Thus, as a practical matter, qualified LILCO and contractor personnel'are inherently being maintained at Shoreham, and are available to assume nearly ninety percent of the LIPA professional, technical, managerial, and administrative positions on an im;aediate basis. It would therefore be LILCo's intent to have these LILCO and contractor-personnel continue in their present positions if the Shoreham license were to revert to LILCO. _(See Section below-for ' '
details regarding how contractor personnel would be aosigned to LILCo.)
_. . The balance of the LIPA Shoreham professional, technical, managerial and administrative organization presently consists of seven upper management positions held'by coemployees of LIPA and the New York Power Authority.(NYPA); and sixteen management and technical staff personnel of NYPA. The LIPA/HYPA coemployee positions are Executive Vice President of Shoreham Project; Shoreham Plant Resident' Manager; Operations and Maintenance Department Manager; Decommissioning Department Manager; Nuclear Quality Assurance-Department Manager; Licensing / Regulatory Compliance Department
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Hanager; and Radiological' Controls Division Manager. The sLtteen managerial and technical---staff positions occupied by NYPApersonnel(i.e. non-coemployees) consist of nine positiono in the.
Decommissioning Department; 3 positions in the Finance and.
Administration Department; 3 positions in the Operations and Maintenance Department; and 1 position in the-Nuclear Quality Assurance Dcpartment.
LILCO has available and will maintain available seven qualified LILCO personnel capable of assuming the positions of the seven l LIPA/NYPA coemploye,,r identified above. The LILCO individuals i designated to fill the coemployees' positions will be required to _
establish and maintain their capability to assume these' positions as follows*
o LILCO position'opecifications have been created in the Shoreham Training and Qualification System which are identical to the LIPA position specifications for the LIPA/NYPA coemployaes' positions.
o The designated LILCO employees' qualifications shall be documented to establish how they presently meet the requirements of the coemployees' position specifications, o 'The designated LILCO employees shall maintain their
-qualifications for the coemployees' positions up to date for as long as the position is required under the Shoreham license.
- Should any designated LILCO individual leave LILCO or otherwise become unavailable to fulfill this commitment, another qualified LILCO individual will be designated, or if necessary, a qualified contractor will be engagad.
With regard to the other NYPA-occupied positions described above,
- nine of the sixteen positions are in the Decommissioning Department and, as suen, are not.eesential to meeting the requirements of the POL and Technical Specifications. LILCO would therefore not necessarily seek immediate replacements for these personnel upon license transfer. Similar1;, the remaining seven NYPA-held
. positions in the Finance and Administration Department, Operations and Haintenance Department, and Nuclear Quality-Assurance Department are also not essential to meeting the requirements of the POL and Technical Specifications, i.e. they are not control room positions or otherwise associated with fulfilling specific license obligations. Vacancies in these positions would therefore also not
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ic bel required to be filled by LILCO on an immediate ' basis. LILCO
-would, however, take actions to fill these positions on a timely basis to the extent necessary.
B) Transfer of essential functions prcvided by contractors, labor organizations, and offsite agencies in support of POL and Technica,. Spec,1fications oblications -
Essential functions provided by contractors in support of LIPA's POL ,
and Technical Specifications obligations, which would be required to be immediately transferred to LILCO, include
- 1) LIPA-staff contractors in the positions of Radwaste Engineer, 11ealth Physics Engineer, Independent Review Panel members, and other professional and technical staf f consultant positions;
- 2) General contractor support servid t such as security guard force, maintenance workers, health physics technicians-and engineering support;
- 3) Task-oriented. services such an-laboratory analyses, radiation medical consulting, and specialized equipment maintenance.
LILCO would be capable of assuming the rights and obligations of LIPA contracts as identified above (*. well as other LIPA contracts) by virtue of LIPA having secured the vendors' written concurrences to assign such rights and obligations to LILCO. LIPA has requested such concurrences from all vendors, and is expecting to receive acceptance within ten days. A copy of a typical LIPA letter.
requesting assignment rights to LILCO is provided in Attachment 1.
A listing of contracted services for which LIPA has requested assignment rights is provided in Attachment 2. In order that LILCO is assured maximum flexibility to safely continue any ongoing decommissioning activities initiated by LIPA, all LIPA decommissioning-related contracts have'been included, and any future
- _ LIPA contracts.in Hupport of decommisoioning will include an assignment clause.
Similar consent for assignment is expected to be obtained shortly from offsite agencies holding agreements with LIPA for Shoreham, such as fire departments, police, ambulance services,'and hospitals.
With respect to labor organizations, no assignment of agreements would be required. Labor union agreements which support LIPA's
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Shoreham activities are either with LILCO or with LIPA's contractors. LIPA has no agreements with any labor unions.
C) Transfer of regulatory authorization to conduct activities essential for como113nce with the Shoreham POL and Technical S pe c i f i c a t _i_.on s
%ne following licenses, permits and easements were either newly issued to LIPA or transferred-from LILCO in order to support LIPA's
-POL and Technical Specificatione obligations. LILCO would secure these licenses, permits, and easements as-described belows o There are_four Federal Communications Commission (FCC) radio licenses which support radio control of the Reactor Building, Radwaste Building and Turbine Building cranes; use of portable radios by security, fire / safety, and other station personnel; and base station frequencies for offsite radio contact of emergency response-services such as police, fire and ambulance services.
These radio licenses are covered by an " involuntary assignment" provision in FCC regulations whereby the licenses can be automatically assigned to a new owner in the event.that the
-license holder is " legally disabled" from utilizing the licenses.
LILCO would exercise this provision should it become necessary.
o There are four environmental permits from the New York State Department of Environmertal Conservation (NYSDEC) covering 4 overall discharges' associated with station operations; specific discharges from operation of a welding hood; operation of three groundwater wells; and registration of hazardous substance bulk-storage facilities (administered by Suffolk County). Three of ,
these permits are assignable to a new owner upon notification to NYSDEC. The Suffolk County-admir vtered permit would involve re-registering LILCO as the owner e, .e storage facilities in place of LIPA.
m o An underwater land easement from the New York State Office of General Services covers the ownership of the. diffuser pipe which extends into Long Island Sound from the Shoreham intake canal.
This easement requires prior agency approval for assignment.
However, the Office of General Services was extremely prompt and supportive of LILCO's request to secure apprival of assignment of this easement to LIPA, and is expected to be equally so in the event that LILCO is obliged to reobtain this easement.
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' o There.are two radwaste shipping permits which have been or will be issued to LIPA by.the State of South Carolina and the State of washington,.respectively. These permits ce.n not be transfeermd to LILCO until LILCO is in possession of the Shoreham NRC license. Based on LIPA's experience, however, the response time for transfer /reissuance of these permite ranges from three to five weeks. Thus, if the Shoreham licente were to revert back to LILCO, all' planned shipments of radioactive waste to either the Barnwell (South Carolina) or Hanfor' (Washington) burial facilities would need to be suspended uc.til the appropriate permits were received by LILCO.
III. LILCO Administration of thp LIPA Technical SDecifigptions As noted above, LILCO would utilize the bulk of the present Shoreham staff and designate seven IILCO personnel to assume the seven upper management positions within the LIPA organization that are currently filled by LIPA/NYPA coemployees, in the event that the Shoreham license was returned to LILCO. Thus, the organizational structure and nomenclatures as delineated in the LIPA Technical Specifications would be maintained by LILCO using LILCO or contractor personnel. In addition, LILCO would utilize the policies, programs, and procedures which are developed by LIPA to suit the LIPA Technical Specifications.
Aside from organizational structure and nomenclature, these LIPA Technical Specifications are identical to the LILCO POL Technical Specifications, and the entire LIPA Technical Specifications are well known'by the LILCO personnel at Shoreham. Thus, at the time the license P
is transferred back to LILCO, the principal change in administration of the LIPA Technical Specifications would be the change in the individuals holding the seven LIPA upper management positions. The duties aerociated with the positions themselves would remain unchanged.
In this way, no additional licensing actions would be needed to effect re-transfer of the Shoreham license back to LILCO in the event it.
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becomen necessary. Should LIPA cease to exist, LILCO would immediately notify the NRC that it has assumed the license under this Contingency Plan. If there were a final determination that LIPA was no longer
-considered qualified to hold the Shoreham license, LILCO would immediately assume control of the Shoreham license in accordance with this Contingency Plan upon receipt of such information from the.NRC.
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IV.- Indgraifieation Cover,ang LILCO remains-the policyholcer for all insurance coverages at Shoreham, including nuclear liability, noneral liability, and property coverages required by 10 CFR Patts 140; 50.54(w); and 50.75(e). (LIPA is presently a named insured o. all LILCo insurance policies at Shoreham.)
Therefore, should the license revert back to LILCO, no immediate actions would be necessary to ensure proper insurance indemnification coverage.
V. Additional considerat_igna Becauae the transfer of the Shoreham license to LIPA involved primarily a change in upper management personnel, the immediate impact of 1.turt.ing the license to LILCO in the middle of any on-going physical work would be limited. Essentially, the immediate impact would be limited to changes in the organizational reporting chain and other administrative changes. There would be no need to immediately disrupt physical work activities and, more importantly, no unsafe conditions would result _ If necessary, activities other than those essential-for complying with the POL and Technical Specifications would be temporarily suspended in a safe and orderly manner, much as they_ are on a twice-daily basis, at the end of the shift in progress.
On a general level, LILCO personnel at Shoreham are active in and informed of LIPA's Shoreham activities on a daily basis because of their ,
direct involvement in LIPA's activities. LILCO personnel hold the majority of positions in LIPA's Shoreham organization, including many-key supervisory and division manager positions, and membership on the LIPA Site Review Committee. Moreover, LILCO, under U.~.e terms of the Site Cooperation and Reimbursement Agreement between LILc0 and LtPA, may designate site representatives to observe activities at Shoreham, and has access to LIPA records.
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. ATTACILCET 1 h L@9 Shoreham Nuclear Power Station L$tmC-1916 ln.a P.O. Box $?B
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TYP1 cat
Subject:
Shoreham Decommincioning Project Agreement flo. C91L1154 The Long Island Pownr Authority (LIPA) has been directed by the !JHC to prep. ire-a contingeriey plan for rt turn of the Shoreham !Juclear a Power Station (SlJPS) to the Long Inland Lighting Company (LILco) unculd unforeuten eventa preverit LIPA from comp l et irig the '
decommicsioning activitieu at SNPS.
In the unlikely ovent that SilPS 10 returned to LILeo, LIPA's outstar. ding SilPS Att reements / Pu rcha se Ordern will be assigned to LlLUU. For thiu renuon we are includintj as an amendment to the cabject Agreement / Purchase order the following "Ausignment Proviuionu". ,
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tio+.w i t h s , 1 ding any other provicion of this Agreement, in the event that the 14RC license f or Shoreham reverts to Long Islan 1 Lighting Company ("LILCO"), all of LIPA's righto and obligatiorsa under thiu Agreement may be transferred a nct acuigned to LILCo. The contractor shall receive written notice of any uuch acnignment and transfer. Upon acceptance of the a cc a g r.mos.t by LILCO, LIPA chall be relieved of any further, liabilities or obligations hereunder."
It is not our intent to revise the Agreement / Purchase Order at this time. Should the need occur to rovine thic Ag re ement./ Purchaue OrJer tor other reasons, we will then add this provision.
Please acknowledge receipt and acceptance of this requirement by signing (below) and returning this letter within ten (10) days.
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If you have any quections regarding thin matter, please contact !!r.
L.F. Ordille at telephone number (516) 929-8300, Ext. 2448.
Very truly yours, R.J. llaggerty Procurer.ent & Contracts Adminintration Division Manager RJil:sf ec: L. 11111 S. Maloney 1 C0!JCUR:
Signature:
Print ! Janes,
Title:
Date: _
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t hrTACHMENT 2 f i i List of LIPA awALded contract services for which assionment riahts are !
included pr have_been recuq11gj ;
i o Site Security Guard Force !
o Consulting Services of Health Physics Engineer, Radwante Engineer; and i Staff Engineers in Health Physics Section, Nuclear Engineering Division, l Quality Assurance Department j o Health Physics Technicians l o -Hadweste shipping j o ceneral (Haintenance) Services contractor o Temporary Clerical Support o Independent Review Panel Members
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o Decontamination Consultants o Radwaste Treatment Services o_ Radiation Honitoring o Hazardous Waste Transportation, Dispo*.t;
-o Elevator Haintenance o Metallurgical Testing o Emergency Medical Assistance j
- o. Non-Noclear Diving Services o Breath Test Program o Aquatic Sampling o Emergency Planning o camma spectroscopy o Heteorological Tower Instrument Calibration o Radioact.ivity Studies i o Uniform Rental And Laundry S3rvices o Background Screening o Fire Extinguisher Servicing !
o Lab Equipment Calibration Services o Hobile Demineralizer
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'o Fitness For Duty Consulting And Testing Services o Psychological Screening o Liquid Waste Removal o Dosimetry Software Haintenance o Card Reader Maintenance o Computer And Printet Parts and Servicing o Offshore Buoy Maintenance o Dosimetry TesLing o Water Chiller Haintenance And Inspection j
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4 Vage 2 of 2 ATTACHMENT 2 o Respirator /Pegulator Haintenance o Photocopier Haintenance o Lut-e 011 Analysis o Hiscellaneous Calibra' ,a services o Halon Tank Refill /For.3, o 011 Sampling o Air San.pling o *echnical Representative For Counting Equipment o Cleaning Services o Technical Representative For Laundry racilities o Dosimetry Servicing o Wet Chemistry Cross Check Calibration o Spectrophotometer Service / Repair o Chem Lab Balance Certificates o Torque Wrench Repair / Calibration o Chem Lab Certification o Well Water Testing o Title 10 Subscription o Fuel Oil Analysis o Industrial Waste Analysie o Air Monitoring Li st o f decophile.p1D2-IPag'.f ic cont ra ct s t hat LIPA has or will recuen assianment riahuR o Reactor Vessel Shell Segmentation o Reactor Internals segmentation o Engineering Services o Radwaste Volume Reduction And Burial o Radwaste Transportation And Burial o Vendor Laundry Services
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