ML20099E375

Forwards Lilco Transition Plan for Shoreham - Rev 4 & Legal Concerns Identified During Review of Revs 3 & 4

ML20099E375
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	11/15/1984
From:	Speck S Federal Emergency Management Agency
To:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20099E378	List: ML20099E375
References
NUDOCS 8411210259
Download: ML20099E375 (3)

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5.. 54- W g Federal Emergency Management Agency Washington, D.C. 20472 IG I 5 884 Mr. William J. Dircks Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr.'Dircks:

On ' July 9,1984, the Nuclear Regulatory Commission (NRC) requested the Federal Emergency Management Agency (FEMA) to conduct a full Regional Assistance Committee (RAC) review of Revision 4 of the Long Island Lighting Company's (LILCO) Transition Plan for the Shoreham Nuclear Power Station (SNPS) and to provide the NRC with its findings. This request was made in accordance with the NRC/ FEMA Memorandum of Understanding (M00) dated November 1980. Revision 4 was submitted to the NRC by LILC0 on June 29, 1984, in response to FEMA Region II's Consolidated RAC Review of Revision 3 dated February 10, 1984. FEMA's findings on Revision 3 were provided to the NRC on March 15, 1984.

A full RAC review of Revision 4 has b'ene completed and the results are contained in the enclosed report entitled "LILC0 Transition Plan for Shoreham - Revision 4, Consolidated RAC Review." The RAC reviewed the Plan against the standards and evaluative criteria of NUREG-0654/ FEMA-REP-1, Rev. 1. Due to the legal authority issues which arise when some NUREG elements are applied to a utility-based plan, we have marked with an asterisk any aspect of the plan where, in our view, this legal issue occurs. The specific legal concern related to that part of the plan is identified separately in Attachment 2 of the consolidated RAC review.

Such legal concerns affect 24 NUREG elements. With the exception of plan aspects relating to NUREG element A.2.b. (a requirement to state,

' by reference to specific acts, statutes, or codes, the legal basis for the authority to carry out the responsibilities listed in A.2.a., i.e.,

j' all major response functions), the legal concern did not affect the FEMA rating given to the technical or operational items relating to NUREG elements.

l-FEMA finds that Revision 4 is a substantial improvement over Revision 3.

! Of the 32 inadequacies identified in the RAC's review of Revision 3, only

! 8' elements remain , inadequate. The deficiencies and recommendations for l improvement are explained in the RAC report. The NUREG evaluation criteria for the remaining 8 elements are as follows. (An asterisk indicates there is also a concern pertaining to legal authority which surfaced in the RAC review. In some of the inadequacies, the legal issues are the majorconcerns.)

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. T(1)' IA[2 N N ESch plan shall contain'(by reference to specific acts,.

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- codes or' statutes) the legal: basis for such authorities '(1.e..' the

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fauthoritiesmentionedinNUREG-0654elementA.2.a.).. L' L

A.3.*5Each plan shall' include written; agreements referring toLthe ' '

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' ^(2)1~ : concept of operations' developed between Federal', State, and local:

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agencies-and other' support organizations'having an. emergency response

o role:within Lthe Emergency Planning-Zones.1The agreements shall:

identify the emergency measures to be provided andithe mutually - -

acceptabl.a criteria for theirlimplementation, and specify the '

arrangements for exchange offinformation..

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C.4.* Each organization shallLidentify nucleariand other facilities.

(3) organizations, or individuals'which can be relied upon'in an

, emergency to provide assistance. 'Such assistance shall be identified c

and: supported by appropriate _ letters of agreement. y, Each organization shall describe'the capability and resources;

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(4). I.7.' '

for. field monitoring within the plume exposure Emergency Planning-Zonei(EPZ) which are an intrinsic part of the concept of operations) for_the facility.'

(5) 1.9. -Each organization shall have a capability to detect and- ,

measure radiciodige^ concentrations in air in the plume exposure -

EPZ 'as low as'.10-I uCi/cc (microcuries per cubic centimeter) .under i .

field conditions. -Interference ~from the presence;of nobleigas and background radiation shall not decrease the stated minimum detectable activity.

(6) 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 1sotopes and gross ' .

radioactivity 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 detailed provisions shall be described in separate. procedures.

(7) J.9. Each State and local. organization shall establish a capability for implementing protective measures based upon protective action '

guides and other criteria.' This shall'be consistent with the recommendations 'of the Environmental Protection Agency (EPA) regarding exposure resulting from passage of radioactive airborne

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plumes and with those of the Departnient of !!ealth'and Human Services /

Food and_ Drug Administration (HHS/FDA) regarding radioactive contamination of human food and animal feeds.

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77 [ (8)' J. ;k.* The organization's" plans to implement protective measures _

Ti the plume exposure pathway shall include: Identification.of and me ns for dealing with potential, impediments 1(e.g., seasonal impass-ability of roads) to.the use of evacuation routes, and contingency

-measures.-

I have 'also e'nclosed a' copy of. a letter (dated October 17, 1984) from the Federal Communications Commission.(FCC) to FEMA Region II RAC Chairman.

' Roger B.:Kowieski clarifying a RAC concern, in connection with the review

, of NUREG-0654 element E.5, as to whether private organizations have the authority to activate the Emergency Broadcast System (EBS). According to the FCC latter, "...the'EBS may be activated at the State and local-level.by AM, FM and TV broadcast stations, at management's discretion.

-in. connection with day-to-day emergency situations posing a threat to the safety of life and property."

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(See Attachment 1, Consolidated RAC-

' Review,~page 16, for review comments concerning the EBS to be utilized by LILCO.) This information was not-available u*cil after the submittal of the RAC finding to FEMA Headquarters.

Finally, additional information has come to our attention since the RAC report was submitted concerning the relocation centers. The enclosed LILC0 letter dated September- 25, 1984, from John D. Leonard,:Jr. to Harold R. Denton, NRC provides' details pertaining to how LILC0 proposes to modify Revision 4 regarding these centers. However, there are three facilities identified on the list of 53 which are State facilities and, therefore, it is not certain whether they will be available for use as relocation centers. They are: Nassau County Board of Cooperative Educational Services Westbury; State University of New York (SUNY), Old Westbury; and, SUNY, Farmingdale.

I hope the enclosed finding is helpful in your analysis of emergency preparedness issues concerning Shoreham. If you have any questions, please don't hesitate to call me.

Sincerely, u). - f

amuel W.: Speck Associate Director r State and Local Programs and Support Enclosures

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