ML20112E282
| ML20112E282 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/11/1983 |
| From: | Hurwitz H AFFILIATION NOT ASSIGNED |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20105B226 | List: |
| References | |
| FOIA-84-250 NUDOCS 8501150081 | |
| Download: ML20112E282 (5) | |
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-Letter from Hurwitz to W. J. Dircks-Axelred, Director of the New York State Department of Health, has not, to m9 knowledgei requested funding for the needed radiological investigatiensi and I am not aware of any Fublications by the New Yo-k State Department of Fublic Health which. justify the explicit rejection of measures to protect the Public frca the large radiological dose connitraents from the EEf!P 11 residential energy conservation prograas, in view of the conscious and deliberate policy of New York State to take no concrete a: tion to protect the public from increased indoor radon due to residential energy conservation eessures retcomended and subsidi:ed in New Ycrk State prograas, it would appear ludicrous to contemplate drastic actions such as asssive evacuation to avoid anticiFated tse C::aitser.ts in the range of a feu tro free a nut!sar at:ident. UnfCrtUrately, the NRO has chosen to ignere the clear indicaticn that b York State is het realls t:nterned about hse ctaitunts below the levels that would cause substantial numbers of ear!9 deaths. In contrast to the 10 to 100 ree range of atteptable &se censitments from energy conservationi the NRC is still thinking in teras of a trigger point for uss evacuation in the range of one to five res. This clearly shows an inarpropriate disregard fc-the dispicpertionately large public interver.iente, hastrris, and risk of transp:Ptatica accidert3 that V:uld b-result frca eVatuatiens triggered b9 ar.titirited kse ccr.r.ittents in this low range.
I hope that, on the basis of the ateve inforsationi scu eill make it clear to the Cuso panel that energency planning for nuclear accidents in Hsu York State should be based on a trigger level for uss evacuation terresFonding to an anticipated dose cosaitment of at least 50 res. In view cf tfe exceedingly low probability of any substantial number of public exposures above 100 ree from even a worst case accident, it is entirely reascLable to establish a trigger level for general l
evacuation at about 10% of the LD50 level. This allcus a i
gererous margin fcr uncertahties in the estiutica of Flausible &se cciaittents. Wnder attident cenditions, tse i
toenitments tend to be overestimated rather than underestiuted.)
A major benefit of establishing a relatively high level for triggering mass evacuation is that tfie conditions that cculd conceivably lead to doses abcve 5B res to large nuaters of pecple are fee in number and easily re:ogri:able. Hence, sitt. a sensibly high trigger leveli the decisien on crdering an evacuation is much simplified.
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-Letter from Hurvit: to W. J. Dircks-Page 3 1 have reFeatedl9 pcinted out in coseunications to NRC consissioners that NF.C preottupation with exceedingly los public exposures distracts attention from the more urgent task of minimi:ing the possiblility of public exposures near ife LD58 range. Furthermore, the NRC preoccupation with public exposures below a few tens of rees sets the stage for escalating litigation concerning health effects that nas be attributed to exposures in this range free the residential energy Conservation programs as they are now being conducted by New York State agencies and utilities.
It is my view that public mistenceptions and hysteria centerning low level radiation are pronoted and perpetuated ts the grossly aisplaced emphasis by the NRC on low level radiological ex;csures. Scy. Cuceo has reccgni:sd the encrocus cost to New York State of shutting dxn or f ailing to start nuclear F:wer plants tecause of disterted putlit fears.
H:pefully, the fCrthco3 frig F5nel vill tile a strong position in favor of adopting consistent and objective criteria for the Frotettica cf put!!c safety and health. Consistency is Only possible if NRC ati:nowledges that significant concern is not justified under accidsnt conditiens in which the eaximun Flausible d:se tenitments to es, tars of the public are telow 50 rem.
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(Dr.1Henryhv i Jr.
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d g Federal Emergency Management Agency Region II 26 Federal Plaza New York, New York 10278 DATE:
June 28, 198':
MEMORANDUM FOR: All RAC Members 4/A MY" FROM:
Roger. Kowieski, P.E.
Chairman, Regional Assistance Committee
SUBJECT:
LILCO Transition Plan for Shoreham Nuclear Power Station The enclosed plan review was completed by FEMA Headquarters with the assistance of Argonne National Laboratories. This review was requested by the Nuclear Regulatory Commission under the terms of NRC/ FEMA Memorandum of Understanding. Since this plan was submitted by LILCO to NRC instead of the State to FEMA as required by 44 CFR 350 a Regional Assistance Committee was not involved in its review. It would be understood that as soon as the Shoreham plan is formally submitted to FEMA by the Governor or his designee, RAC will be requested, as in the past, to perform a comprehensive review of that plan.
The RAC*
recommendation will then be forwarded to the State for review and appropriate action.
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FEDERAL EMERGENCY h
MANAGEMENT AGENCY Office of Public Affairs / Washington, DC 20472 i
For additional information:
R,elease No.:
83-53 Dave Denne Release Date:
(202) 287-0300 Thursday, June 23, 1983 NOIE TO EDITORS:
Attached is the' Federal Emergency Management Agency (FEMA) report to the Nuclear Regulatory Commission on the review of the emergency preparedness plan for the Shoreham nuclear powe'r plant.
The report was delivered to NRC this afternoon.
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Washington, D.C. 20472
,Y JUN 2 3 tgg MEMORANDUM FOR:
Edward L. Jordan Director, Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement U.S. Nucle R
1 story Commission FROM:
Richard W. Krimm Assistant Associate Director Office of Natural and Technological Hazards SUBJECI:
Pindings on the LIICO Transition Plan As Requested by the NRC as Part of NRC Licensing of the Shoreham Nuclear Power Station This is in response to your June 1,1983, memorandum in which you invoked Section II.4 of the November 1,1980, NRC/FDfA Memorandum of Understanding by requesting the Federal Emergency Management Agency (FEMA) to provide the Nuclear Regulatory Commission (NRC) with findings and determinations as to whether the LILCO-County plan and/or the interim plans for the Shoreham Nuclear Station are adequate and capable of implementation.. As a result of an Atomic Safety and Licensing Board (ASLB) order, your subsequent memorandum of June 17, 1983, requested that FDiA provide findings and determinations on the LIIf0 Transition Plan as a first priority. This Plan, developed wholly by LILCO, proposes to use LI140 personnel to carry out the offsite preparedness aspects of the plan (to include the total direction and control function) in the case of an emergency involving an accident at the Shorehan Nuclear Power Station.
First, we would like to indicate how the review process for the LILCO Transition Plan differed from the usual "350" approval process. As you know, under normal processing, the plan review is initiated by a formal request by the Governor of the State in which the nuclear f acility is located, af ter he/she has received and analyzed plans submitted by the local governments in the emergency planning zone surrounding the facility. The request includes the State plan which is site-specific to the applicable power f e411ty, appropriate local plans and a statement by the Governor that the State plan, together with the local plans, are adequate to protect public health and safety of the citir s liviag within the emergency planning zones for the nuclear power f acilities included in the submission by prending reasonable assurance that appropriate protective measures can and will be takan in the event of a radiological emergency for the site.
The FEMA processing of a Governor's submittal includes extensive review by the relevant Regional Assistance Committee (RAC), a public meeting and most importantly, a drill or exercise, including all appropriate governments, to test whether the plan can be implemented.
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-2 In contrast to the process described above, the LILCO Transition Plan was
-submitted, without Suffolk County or New York State endorsement, directly to FDIA Beadquarters through the NRC for review under the terms of the NRC/FDIA Memorandum of Understanding. Because the Plan was not submitted under 44 CFR 350, a RAC review was-not undertaken.' For this reason, coupled with the f act that the NRC needed a FEMA finding within three weeks, it was necessary to obtain the support of Argonne National Laboratories to assist and perform a technical review of the plan against the 16 planning standards and criteria (A-P) listed in NUREG-0654/FDfA-REP-1, Rev. 1.
FEMA. Headquarters, assisted by FEMA's Region II Regional Director and staff, directed this technical review.
FEMA finds that the LIICO Transition Plan has 34 inadequacies in terms of NUREG-0654/FDfA-REP-1, Rev.1.
Our analysis relating these inadequacies to the various criteria is attached.
l There are two preconditions, identified below, that need to be met for a 4
FEMA finding as to whether the plan is capable of being implemented and whether LILCO has the ability to implement the plan.
(1) A determination of whether LIIf0 has.the appropriate legal anchority to assume asnagement and implementation of an offsite emergency response plan.
(2) A demonstration through a full-scale exercise that LIIf0 has the ability to implement an offsite plan that has been found to i
be adequate.
FEMA will continue to review the other plans associated with your June 1 request in anticipation that the ASLB will require FEMA findings on these plans at a later date.
Attachment As Stated i
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ELEMENT-BY-ELEMENT REVIEW OF THE LILCO TRANSITION HODULE of the SHOREHAM NUCLEAR POWER STATION OFFSITE RADIOLOGICAL EMERGENCY RESPONSE PLAN June 22, 1983 3
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5 PREFACE This is a review of the LILCO-transition module of the Shoreham Nuclear Power Station Local Offsite Radiological Emergency Response Plan and Pro-cedures (Rev. O), and Appendix A, Evacuation Plan, with Addendum. The review is presented in a chart format.
The first column, labeled "NUREG Reference,"
refers to those Planning Standards and Evaluation Criteria in NUREG 0654/TEMA-REP-1, Rev.1, section II, which are applicable to st, ate or local governments.
The second column, labeled " Cross-Reference," refers to the section of the Plan corresponding to the NUREG Reference. The third column, labeled "Evalua-tion and Comments," states whether the element is adequate or inadequate and includes relevant comments.
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ABBFH1AT10NS App.
appendix BNL Brookhaven National Laboratory EBS Emergency Broadcast System EOC
. emergency operations center EOF energency operations f acility EPZ emergency planning zone FEhA Federal Emergency Management Agency KI potassium iodide LERO Local Emergency Response Organization LILCO
.Long Island Lighting Company NRC Nuclear Regulatory Commission ORS of f-site radiological survey REPP radiological emergency preparedness plan Sec.
Section SNPS Shoreham Nuclear Power Station O
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O NUREG Cross-Reference Reference Evaluation and Commen'ts I
A.l.a
- Se c. 1.4, p.
Inadequate; first, the plan d oes not 1.4-1-3 specify whether Suff olk County will or will Se c. 2.1, p. 2.1-1-7 not be part of the,overall response organ-
- Se c. 2.2, p.
iz'ation.
Instead, it leaves this as an 2.2-1-4 option, apparently to be decided during an accid ent.
The plan subt define what role, if any, Suff olk County is to have.
Se cond,
the plan gives no explanation of the role New York State is to play. Although New l
York State has written its own Radiological Emergency Preparedness Plan (REPP), this plan does not mention it.
Theref ore, it is unclear whether this plan is to operate in conjunction with the REPP, or whether this plan is intended to supplant it, covering both the State and local response.
If this plan is intended to be integrated with the REPP, it may conflict with the compensating measures of the REPP, which create a special concept of operations for sit'ua -
tions where counties decline or are unable f
to implement their response plans.
A.I.b Sec. 2.1, p. 2.1-1-7 Inadequate; this element is adequate, Se c. 2.2, p. 2.2-1-4 except that it omits a complete description of the operational role of Suff olk County.
In the event of an accident at SNPS, l
Suff olk County's place in the response must be defined in the plan.
Four possibilities exist:
(1) Suff olk County may choose not to respond and may not be ordered to respond; (2) Suff olk County may choose not to respond voluntarily and may be ordered to respond by the Governor; (3) Suffolk l
County may choose to respond in accordance I
with this plan, such as by placing County l
resources and personnel at the disposal of the Director of Local Response; or (4)
Suffolk County may choose to respond in a manner not in accordance with this plan.
While this plan is written on the l
assumption that Suf f olk County either will do nothing or will respond in accordance with this plan (possibilities 1 and 3), the others are not covered. The plan should prepare f or these additional contingencies.
Moreover, the concept of Suffolk County 's
NUREG Cross-Reference Reference Evaluation and Comments A.I.b (Cont 'd )
operations in case it responds in accordance with this plan is not suffi-ciently detailed.
In several places, the plan states that various Suf f olk County personnel will be used if they respond f or certain functions, but does not detail their role.
Thus, arrangements would have to be made to accommodate them on the spot.
Allowing Suffolk County personnel to take over important response functions at the last minute seems certain to cause con-siderable confusion.
A.l.c Se c. 2.1, Fig. 2.1.1 Ad equate.
Sec.
2.2, Fig. 2.2.1 A.l.d Sec. 2.1, p. 2.1-1 Inadequate; the title of an individual Se c. 3.1, p. 3.1-1 LILCO employee who will serve as the Procedure 2.1.1 Director of Local Response is not given.
A.1.e Sec. 3.3, p. 3.3-1 Adequate.
Sec. 3.4, p. 3.4-1,2 A.2.3 Sec. 2.1, Fig. 2.1.2 Inadequate; first, the organizational Procedure 2.1.1 matrix (Fig. 2.1.2) does not include a designation of responsibility f or taking protective actions, although Procedure 2.1.1 states that this is the responsi-bility of the Direct" of Local Response.
The matrix should be changed to reflect this responsibility.
Second, responsi-bility for emergency law enf orcement activities is not assigned (Raference i
A.2.b).
No provision is made f or the likely need for large numbers of l
police officers.
For example, the assignment of traffic control ::esponsi-bilities to persons who are not police officers is inappropriate given the necessity of blocking public thoroughf ares, ordering drivers to follow specified routes, and other extraordinary ~ changes in l
legal driving patterns.
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A.2.b Sec. 1.4, Attachment Inadequate; first, the legal authority 1.4-1 cited in Attachment 1.4.1 to the plan (10 l
C.F.R. 50.47) d oes not specifically grant the necessary police powers to a licensee l
L
NUREG Cross-Reference Reference Evaluation and Comments A.2.b (Cont 'd )
to implement those aspects of an off-site emergency response requiring the exercise of governmental authority.
Second, the underlying assumption of both FEKA and NRC off-site emergency preparedness regulations is that the responsibility f or responding to a radiological emergency at a commercial nuclear reactor rests cooperatively with State, local, and federal governments.
Part I.F. of NUREG 0654/ FEMA-Rep-1, Rev.1, states at p. 22-23 that "NRC and FEMA recognize that plans of licensees, State and local governments should not be developed in a vacuum or in isolation f rom one another.
Should an accident occur, the public can be best protected when the response by all parties is fully inte-grated." Part 1.E. emphasizes at p. 25 that "NRC and FEMA agree that the licensees l
of nuclear facilities have a primary I
responsibility f or planning and implement-ing emergency measures within their site boundaries" (emphasis in original). In designating an emergency response organiza-tion relying exclusively on LILCO employees, this plan contravenes these standards.
A.3 App. B Inadequate; no written agreements are included in this plan.
A.4 Se c. 2.1, p. 2.1-2 Ad equate.
C.l.a Sec. 3.11, p. 3.11-1 Ad equate.
C. I'. b Sec. 2.2, Attachment Adequate.
2.2.1 C.I.c Sec. 3.11, Attach-Adequate; this is primarily a State fune-ment 3.11.1 tion, but the local plan lists additional resources.
C.2.a
C.3 Sec. 2.2,
- Attach-Adequate; however, the availability of ment 2.2.1 radiological laboratories is not speci-Se c. 3.5, p. 3.5-2 fically addressed.
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NUREG Cross-Re f erence Reference Evaluation and Comments C.4 Sec. 2.2, p. 2.2-1-4 Inadequate; no letters of agreement are Se c. 3.5, p. 3.5-2, included in the plan. -
App. B D.3 Sec. 3.2, p. 3.2-1-3 Ad equate.
D.4 App. C-List of Ad equate.
Implementing Procedures Implementing Procedures E.1 Sec. 3.3, p.
Ad equate.
3.3-1-4, Fig.
3.3.2-4 Procedures 3.3.1, 3.3.2 E.2 Se c. 3.3, p. 3.3-1-2 Ad equate.
Procedures 3.3.1, 3.3.2 E.5 Se c. 3.3, p. 3.3-4-7 Adequate; radio station WALK is the Se c. 3.8, p. 3.8-6, primary EBS station to be used..8-1
- Procedure 3.8.2 Se c. 3.4, p. 3.4-5-6 E.6 Sec. 3.3, p. 3.3-4-7 Adequate; however (1) the plan states that Se c. 3.4, p. 3.4-5-6 a dedicated line is to be used to contact Sec. 5.8, p. 3.8-6 the EBS station from the EOC, whereas, in
- Procedure. 3.3.4 Procedure 3.8.2, the Coordinator of Public
- Procedure 3.8.2 Information is instructed to call a regular telephone number. Moreover (2) the two procedures regarding notification and instruction - Procedures 3.3.4 and 3.8.2
- tend to overlap and conflict, especially with regard to the "f ast track" procedure.
The two should be clarified and possibly combined.
Step by step procedures f or the operator should be provided.
In addition, (a) the route alerting procedures in Procedure 3.3.4 and (b) the EBS activation in Procedure 3.8.2 incorrectly identify the
" FEMA operator" as authorized to activate EBS.
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NUREG Cross-
-Reference Reference Evaluation and Comments E.7 Sec. 3.8 Inadequate; the system for identifying the.8.1 areas which are to take protective actions
- Procedure 3.8.2 is inadequate.
The messages designate alphabetical zones and refer listeners to brochures, telephone book inserts, and posters.
The zone designation maps in the poster and especially in the telephone book insert are difficult to read. The written messages should give descriptions of the protective action areas. Evacuation routes rhould also be described in those messages to which they apply.
Reliance on the inf ormation brochure is not adequate.
F.1.a Sec. 3.3, p. 3.3-1-2 Ad equat e.
Sec. 3.4, p. 3.4-1-2 F.1.b Se c. 3.3, p. 3.3-3 Ad equat e.
F.1.c Sec. 3.4, p.
Inadequate; no radio or dedicated telephone 3.4-1,4, links to any federal agencies are listed.
Fig. 3.4.1 F.1.d Sec. 3.4, p.
Adequate; however, the plan leaves uncisar 3.4-1-4, how communications with BNL field monitor-Fig. 3.4.1 ing teams will be ef f ected. Will they be equipped with LILCO emergency band radios?
F.1.e Se c. 3.3, p.
Ad equate.
3.3-1-4, Figs. 3.3.2-3.3.4 Procedure 3.3.2 Se c. 3.4, p. 3.4-4,5 F.2 Sec. 3.4, p. 3.4-3 landequate; the plan essentially repeats the criterion, without explaining how it will be met. Detail is needed with respect to what medical facilities are involved, and how communication with each will be effected.
F.3 Se c. 3.4, p. 3.4-7 Ad equate.
Sec. 5.2, p. 5.2-2
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NUREG Cross-Reference Reference Evaluation and Comments G.1. a-d Sec. 3.8, p. 3.8-1-3 Adequate; however, see evaluation under NUREG Ref erence G.2 f or comments related to the " Emergency Procedures" d ocuments.
G.2 Se c. 3.8, p. 3.8-1-3 Inadequate; the " Emergency Procedure"
- Procedur'e 3.8.1 documents are incomplete.
The brochure is missing all specific information including transmittal letter; other participants in the Emergency Broadcast System; detailed zone and evacuation maps; and identifica-tions of Relocation Centers, school districts and schools.
The response card f or people requiring special emergency assistance d oes not have a line f or the person's name.
G.3.a sec. 3.8, p. 3.8-4 Inadequate; although representatives of the
- Procedure 3.8.1 news media would be at the Emergency News Center, the plan should designate that they will have facilities for their use, and what these facilities are.
G.4.a-Se c. 3.8, p. 3.8-1 Ad equat e.
- Procedure 3.8.1 G.4.b Se c. 3.8, p. 3.8-4-5 Ad equat e.
- Procedure 3.8.1 G.4.c Sec. 3.8, p. 3.8-5 Adequate; however, experience has shown
- Proce. dure 3.8.1 that rumor control activities are more effective if they are operated f rom one centralized location with one telephone number included in all inf ormation distri-buted to residents and available to the transient population.
G.5 Se c. 3.8, p. 3.8-4 Ad equate.
- Procedure 3.8.1 H.3 Se c. 4.1, p. 4.1-1 Ad equate.
H.4 Sec. 4.1, p. 4.1-1 Ad equate.
H.7 Se c. 3.5, p. 3.5-2 Ad equate.
Procedure 3.5.1 Se c. 5.2 E.10 Sec. 5.3, p. 5.3-1-2 Adequate.
5
NUREG Cross-Reference Reference Evaluation and Comments H.11 Sec. 3.4, p. 3.4-1-5 Ad equate.
Se c. 4.1, p. 4.1-3-4 Se c. 4.4, p. 4.4-1-4
- Procedure 5.3.1 5.12 Sec. 3.5, p. 3.5-2 Adequate; data and samples are to be col-lected at the local EOC.
However, the plan should clarify how plume data vill be commanicated to the local EOC.
(What radio system will be used by the BNL ORS teams?)
1.7 Se c. 2.2, p.
Ad equat e.
2.2-3-4, Attach-ment 2.2.1 Sec. 3.5, p. 3.5-1-2 Se c. 4.4, p. 4.4-1 1.8 Sec. 3.5, p.
Inadequate; deployment times of monitoring 3.5-1-4, teams are not estimated and the plan does Procedure 3.5.1 not indicate where to pick up the monitor-ing kits.
1.9
- Se c. 2.2, Attach-Ad equate.
ment 2.2.1 I.10 Precedure 3.5.2 Adequate; however, except f or radiciodine, Se c. 3.5, p. 3.5-3,4 no procedure is described f or determining Sec. 3.6, p. 3.6-3,4 dose rates f or significant isotopes listed in NUREG-0654, Table 3.
.I.11 Sec. 2.2, Attachment Adequate.
2.2.1 Sec. 3.5, p. 3.5.2 J.2~
Sec. 3.6, p. 3.6-8 Inadequate; criterion stipulates that alternate routings be identified f or
" inclement weather, high traffic density, and specific radiological conditions." No such alternates are described here.
The one route described in the referenced section could pass directly through the release plume, or could encounter heavy traffic conditions on the Floyd or Long Island Expressways if an evacuation is in progress.
J.9 Se c. 3.6, p. 3.6-1-8 Ad equate.
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f NUREG Cross-peference Reference Evaluation and Comments J.10.a App. A, Figs. 9-10, Inadequate; while evacuation areas, evacua-12-27 tion routes, and relocation centers in host Se c. 3.5, Fig. 3.5.1 areas are shown, public shelter creas are
- App. A, Fig. 11 not shown.
Fig. 3.5.1 is missing from the
- Procedure 3.5.1, review copy of the plan, but an unnumbered 0 figure entitled SNPS EPZ (Nov 82) is in-cluded which does show where the monitoring points are.
(Ihese points are also listed in Attachment 10.)
J.10.b App. A, Table 3 Adequate; meets criterion as stated. How-Sec. 1.1, Fig. 1.1.2 ever, population by evacuation area is shown in a table rather than on a map.
For two evacuation areas, population is broken out by subarea but maps indicating the boundaries of these subareas should be referenced.
Further, while residential population is apparently shown, total daily population (accounting f or employee popula-tion in the EPZ and peak summer weekend transient population) is not.
J.10.c Sec. 3.3, p. 3.3-4-6 Inadequate; no specific provisions are discussed f or alerting deaf or hearing-impaired individuals.
In the 1,ILCO/ County plan, it is indicated that the Suf f olk Co.
Fire Dept. would keep a list of those who are deaf or hearing-impaired in order to contact them during an emergency. No such i
list is indicated in this transition plan.
Further, while WAlX in listed as the EBS station which will broadcast specific instructions to the public, the other stations which will be broadcasting this inf ormation should also be listed.
In I
addition, Fig. 3.3.6 referred to on p.
3.3-5 is supposed to illustrate procedures in case the initial notification from the plant is of a general emergency; it does not.
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J.10.d Sec. 3.6, p. 3.6-4-5 Inadequate; hospitals, adult / nursing homes,
- Procedure 3.6.5 group homes for the handicapped and cor-
- App. A, pp.
rectional facilities are identified and AII-28-30 procedures for their evacuation (sheltering in the case of the correctional f acilities) l are discussed. Evacuation of invalids /
disabled people f rom, private residences is i
5 NUREG Cross-Reference Reference Evaluation and Comments i
J.10.d (Cont 'd )
covered.
However, specific resources required to evacuate these f acilities (i.e., the number of buses and ambulances required, the numbsr of runs they will make, the number of drivers required, how 4
many trains will be brought in by Long Island Railroad under diff erent scenarios to evacuate hospitals) are not provided.
Further, with respect to evacuation of mobility-limited from private residences, the interim plan apparently assumes that individuals who do not answer the phone (if called by LERO to determine if they want evacuation help) are not at home - which may not always be the case.
J.10.e Se c. 3.6, p. 3.6-5 Inadequate; the quantity stored by LILCO Procedure 3.6.2 is not specified. Furthermore, the use f or j
institutionalized persons in the plume is not discussed.
I J.10.f Se c. 3.6-3,5 Inadequate; the text (p. 3.6-5) says that the radiation health coordinator (BNL) is responsible f or decisions on KI.
Procedure 3.6.2 says that the health services co-ordinator is responsible f or these d ecisions.
It does not seen appropriate to have someone from BNL in charge of deci-sions on the use of KI.
Where is this authority vested, if legal problems arise?
J.10.g App. A, Sec. IV Inadequate; the detail provided with Se c. 3.6, p. 3.6-6,7 respect to the provision of transportation
- App. A, Sec. III, service to the general population without
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- p. AIII-36 access to personal vehicles is excellent:
estimated service demand, neber of buses and runs required, route times, bus routes, and transfer points are provided f or each evacuation area. Ecuever, the specific resources (vehicles and drivers) required to provide this service are not identified:
no f ormal agreements have been made f or l
pr'ovision of the service.
Further, while in general, emergency dismissal of schools with children returning to their homes is the approach to be taken in this EPZ, (a) there is no indication that formal agree-ments have been made with the bus companies
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.w NUREG Cross-Reference Reference Evaluation and Comments J.10.g (Cont 'd )
(if buses are not owned by the schools) and drivers that would ensure that this service would be provided during a radiological emergency and (b) there are a f ew schools (St. Anselm's Nursery School, f or example,
- p. AIV-184) in the area adjacent to the plant that may require buses f or evacuation to a relocation center, but the resources f or these buses are not identified.
Identification of resources to evacuate institutionalized population is also not adequate (see J.10.d).
Further, with respect to the bus service to be provided to the noninstitutionalized population, (a) no indication is given that the route times have been tested and (b) service demand apparently is based on nonseasonal popula-tion:
it may be somewhat higher in the summer.
J.10.h App. A. p. AIII-8 Inadequate; three relocation centers (and Sec. 4.2, p. 4.2.1 two alternatives) have been selected which are at least 5 miles beyond the boundaries of the plume exposure EPZ. Hasever, 1etters of agreement are not provided indi-cating that centers' f acilities will be made available.
App. A, p. AIII-8, cross-referenced in the plan, has no bearing on the NUREG element.
J.10.1 App. A, Sec. III, Ad equate.
Table IV J.10.j
. App. A, Sec. IV, Inadequate; with respect to traffic Figs. 8, 8.1 control, traffic control guides will not
- Sec. 3.6, be able to put signals on " flashing" opera-
- p. 3.6-6,7 tion as could be done by police in LILCO/
- Procedure 3.3.2 County plan (Reference A.2.b).
This is a
- Procedure 2.1.1, disadvantage since existing signals may be
- p. 28 counter to the control stragegy the guide is trying to implement.
The confusion which may be generated by traffic signals differing from traffic control guLde strategies could reduce intersection capacity and increase evacuation time.
Further, with respect to access control, LERO guides will not be perceived by
- 1 NUREG Cross-Reference Reference Evaluation and Comments J.10.j (Cont 'd )
public as having the same authority as policemen. Additionally, perhaps the criteria used in the selection of.the traffic guides should be indicated, i.e., reasonable proximity of their residences to the posts.they will staff is necessary, especially in non-work-hours deployment.
J.10.k Sec. 3.6, p. 3.6-6 Inadequate; no discussion of means f or App. A, p. AIV-9, snow removal is provided.
The number of AIV-86 LERO tow trucks available to respond to
- App. A, Sec. IV, vehicle disablements is not stated.
The Fig. 8.1 plan states " radio f or tow trucks or any
- App. A. p. AIV-5 other assistance required" but does not
- Sec. 2, Fig. 2.1.1 indicate whether such radio communication between LERO and all tow trucks to be used (including private) is available.
Police cars, actorcycles, and helicopters were to have been used in the LILCO/ County plan --
no indication is given that motorcycles and helicopters will be available f or evacua-tion route patrol in transition plan.
Aerial observation would be a far superior and effective procedure.
Another concern is what the response of the general public will be to LERO route patrol vehicles, operating without police sirens and flashers (Reference A.2.b).
According to Sec. 2, Fig. 2.1.1, there would be only 2 evacuation route spotters to patrol 10 evacuation routes. This is insufficient.
J.10.1 App. A, Sec. V Inadequate; time estimates are not shown
- App. A., App. E for the f ollawing distinct groups as
- Procedure 3.6.1, stipulated in App. 4 of NUREG-0654:
pp. 15-18 permanent population, transient population, special f acilities population. The time required. to evacuate the transitdependent population has apparently not been speci-fically incorporated into these estimates though the capacity estimates of the road-ways do account for the presence of buses, ambulances, etc.
Table DES-11 does not include an estimated time for the evacua-tion of.all zones though App. E d oes f or all sectors.
(Table DES-11 is to be used
12 NUREG Cross-Reference Reference Evaluation and Comments J.10.1.
(Cont 'd )
during the course of a radiological i
emergency to determine whether or not to shelter or evacuate various zones.) There is no way to compare the results shown in Sec. V and App. E with those shown in Table DHS-11. The time estimates shown in Table DHS-11 are shown f or weekdays and week-nights, yet the time estimates in Sec. V and App. E, upon which Table DHS-Il pre-1 sumably would have been based, do not make this distinction.
Further, Sec. V indi.
cates the study assumed school was in session even in the summer: why should this assumption be made7 J.10.m Se c. 3.6, p.
Mequate.
3.6-1-4, Fig. 3.6.1 J.11 Sec. 3.6, p. 3.6-7-8 Mequate.
Procedure 3.6.6 J.12 Sec. 3.9, p. 3.9-5-6 M equate.
- Procedure 3.9.2 K.3.a Sec. 3.9, p. 3.9-1-3 M equate.
Procedure 3.9.1 Se c. 4.4, p. 4.4-1 K.3.b Sec. 3.9, p. 3.9-1-3 Inadequate; readings taken at 30-minute intervals may not be f requent enough to allow informing supervisor in a timely fashion that a person has exceeded 150 mR and should leave the radiation area.
Frequency of readings is dependent on the dose rate which the person is receiving.
K.4 Sec. 3.9, p. 3.9-2 M equate.
K.5.a Sec. 3.9, p.
Inadequate; it is not apparent why there 3.9,3,4, are two thyroid radiation levels at which Table 3.9.1, evacuees are sent to the hospital, 0.13 mR/
Table 3.9.2 hr and 10 rads. Furthermore, it is not apparent that cumulative dose will be known f or evacuees.
12 i
NUREG Cross-i Reference Reference Evaluation and Comments K.5.b se c. 3.9, p. 3.9-4 M e qua t e.
Procedure 3.9.2 Sec. 4.3, p. 4.3-1-3 L.1 Sec. 2.2, p. 2.2-2 Mequate; however, it is not clear, whether Sec. 3.7, p. 3.7-1 the trained emergency medical technicians are LILCO empicyees, employees of hospitals, or otherwise employed.
L.3 Procedure 4.2.2 Mequate; however, the 47 hospitals should be listed by rank according to their capability to provide radiation health service s.
L.4 Sec. 3.7, p. 3.7-1 Inadequate; the private ambulance organiza-tions should be listed together with the field medical services they can provide, especially in cases of radiation contamina-tion.
M.1 Sec. 3.30, p.
M aquat e.
3.10-1-2
- Se c. 3.11, p.
3.11-1-2 Procedure 3.10.1 M.3 Sec. 3.10, p. 3.10-1 Mequate.
M.4 Sec. 3.10, p. 3.10-2 Mequate.
N.1.a Sec. 5.2, p. 5.2-3 M equate.
i N.1.b Se c. 5.2, p. 5.2-3 Mequate N.2.a Sec. 5.2, p. 5.2-2 Inadequate; does not provide f or quarterly
- Procedure 5.1.1, testing of communications, with the federal Sec. 5.2.1.5 emergency response organization and states within the ingestion pathway; does not provide f or understanding the content of messages.
N.2.c Sec. 3.2, p. 5.2-2 M equate.
- Procedure 5.1.1, Se c. 5. 2.1. 6 N.2.d Sec. 5.2, p. 5.2-2 M equate.
t-
- Procedure 5.1.1, Sec 5.2.1.2 6
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]4 1
NUREG Cross-R2ference Reference Evaluation and Comments N.2.e(1)
Sec. 5.2, p. 5.2-2 Ad equa te.
4 N.3.a-f Se c. 5.2, p. 5.2-1 Inadequate; does not include provisions to
- Sec. 5.2, p.
allow f ree play f or decision making.
5.2-2-3
- Procedure 5.1.1, Sec. 5.2.3 N.4 Sec. 5.2, p. 5.2-3-4 Inadequate; confusing as to who does the
- Procedure 5.1.1, post-exercise critique and formal written
. Sec. 5.2.3 critique.
The procedures have the critique
- Procedure 5.1.1, done by Emergency Planning Coordinator.
Sec. 5.2.4 This element calls f or a critique by f ederal, state, or local governments.
Federal exercise observers do not comment i
on the, Controller / Observer comment f orns.
N.5 Sec. 5.2, p. 5.2-4 Inadequate; does not provide f or means to
- Procedure 5.1.1, evaluate f ederal observer comments.
Sec. 5.2.4
- Procedure 5.1.1, Sec. 5.2.5
- Procedure 5.1.1, Sec. 5.4.1 0.1.b Sec. 5.1, p.
Adequate; however, courses f or training of 5.1-1-7, nonprofessionals in transportation energen-Table 5.1.1 cies and accident assessment activities are
- Procedures 5.1.1-shown as being still "under development."
5.1.)
0.4.a Sec. 5.1, p.
Ad equate.
5.1-3-7, Fig. 5.1.1-7
- Procedures 5.1.1-5.1.5
- 0.4.b Sec. 5.1, p.
Inadequate; monitoring teams do not have' a 5.1-3-7, specific module to attend.
Fig. 5.1.1 0.4.c Se c. 5.1, p.
Ad equate.
5.1-3-7, Fig. 5.1.1 0.4.d Sec. 5.1, p.
Ad equate.
5.1-3-7, Fig. 5.1.1
je NUREG Cross-Reference Ref erence Evaluation and Conuments P.8 (Cont 'd)
Reference Lists in the plans.
They were identified during the. review process and should be incorporated in the appropriate Cross-Raf erence Lis t.
P.10 Se c. 5.4, p. 5.4-2 Mequate.
- Procedure 5.4.1
- Not included on NUREG Cross-Raference List which is provided in plans.
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Atter.d Shorehan Fact Findine Panel Meeting - Penday, July 11. 1923, Islio, NY Mo n.36 j. July 11 6:45 let GOV, residence to National AL 170 (US Air) (snack)
Lv. National 7:40 AM Ar. L.I. MacArthur 8:34 AM Upon irrival, leave via van to Shoreham education facility 9:00 AM Meet at Energy Environment Education Center (coffee & rolls) 9:15 AM Shoreham orientation program 9:45 AM Tour of Shoreham Nuclear Power Station Noon Depart Shoreham 12:30 PM Tour Emergency Operations Facility 1:00 PM Tour Emergency News Center Old Mill Inn (near L.I. MacArthur Airport) i:30.PM Conference Room 214 - Lunch 2:00 PM Shoreham Panel Meeting 5:30 PM Adjournment
_ Transportation provided to airport AL'#44 (US Air)
Lv. L. I. MacArthur 7:05 PM Ar. National-8:02 PM GOV - airport to residence h
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