ML20115E974

Responds to NRC 850208 Request for Views on Util Proposed Resolution of Eight Remaining Inadequacies in FEMA 841115 Finding on Rev 4 to Transition Plan.Results of Review of Rev Encl

ML20115E974
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/03/1985
From:	Krimm R Federal Emergency Management Agency
To:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8504190355
Download: ML20115E974 (10)

Text

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p4 Federal Emergency Management Agency I ,

Washington, D.C. 20472

, APR 3 1985 MEMORANDUM FOR: Edward L. Jordan Director, Division nf Emergency Preparedness and Engineering Response Office of Inspection and Enforcenent U.S. Nuclear Regulatory Commission FROM: a . r Assistant Associate Director Office of Natural and Technological Hazards Programs

SUBJECT:

(LILCO) Response to Federal Long Island Emergency LightingAgency Management Company (FEMA) Findings on Revision 4 of the Shoreham Transition Plan This is in response to your memorandum of February 8,1985, requesting FEMA's view on LILC0's proposed resolution to each of the eight remaining inadequacies identified in FEMA's November 15, 1984, finding on Revision 4 of the LILC0 Transition Plan for Shoreham. According to LILCO, these resolutions would be contained in the next revision of the Shoreham Transition Plan. We understand that no date has yet been set for the issuance of that revision. Also attached in the materials which you sent were letters pertaining to LILCO's use of the Nassau Veterans Memorial Coliseum. The use of the Coliseum is referenced by LILC0 as a proposed resolution of one of the plan inadequacies stated in FEMA's November 15, 1984, finding.

The' Regional Assistance Committee (RAC) of FEMA Region 11 conducted a review of LILC0's proposed resolutions. The results of that review are attached. The RAC review was limited to a technical evaluation of LILC0's proposed resolution of eight inadequacies from revision 4, and did not constitute a full plan review. The final determination of the adequacy of each element must await the RAC review of a plan submission by LILC0.

Please note that certain elements previously rated adequate, but with recommendations for improvement shown in bold type (See the consolidated RAC review - revision 4, attached to FEMA's November 15, 1984 finding) were not addressed in LILCO's response. Any future revision submitted for review should address these concerns as well.

Finally, any reference to testing plan elements in an exercise should not be taken to mean that FEMA plans to observe or otherwise participate in an exercise. It is simply a generic reference to a normal procedure that FEMA uses to verify that a particular plan element has been/can be accomplished.

I hope this analysis has been useful . If you have any. questions, please feel free to call me at 646-2871.

Attachment j As Stated 8504190355 850403 PDR F ADOCK 05000322 pyg

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LIIID TBMEITEGI PUN IWr!SEN 4 DM W12/84 yege 1 of 9 EAC Plan moview a

r.frm paranee RAC 8 valuation of L114D mas EAC QW-- ^ tion (Action) mesponse 0654 (Queennes in mold Type for Each Element from censo11de:.ed RAC moview -

Proposed asenlution of Eight In%eies Element daud 1=ammy 16,1985 (seC 1133) -

6_ c " to Lilco's Summary of aeaponess)

LII4D has iruticated in their summary of r.rrm has stated in its letter of transmittal In light of t;:e recent court decisions A.2.b (letter to WC fttaa LIIID dated January 16, [Cuomo v. LIIID,* 84/4615, Slip-op. (N.Y.

responess to the mem11deced RAC review for 1995 - 9sc - 1133) with the prnenaad S @. Ct., Feb. 20, 1985) and citisans for an novision 3 of the plan (see page 2 of 13), that resolution Orderly anergy policy v County of Suffolz, this is a legal authority issue to be addressed that furthertoresolution outstanding planning ic M eies ot " legal authority CV 8F4966, Slip-op. (E.D.M.Y., March 18,1985)]

elsomhere and there is no modification to tamme" must monit the results of litigation relating to the legal authority relied upon by movision 4 of the plan. Therefore, the legal LIIID in the LII4D Transition Plan for Shoreham, mehnritieWhases of the WWO plan are not yet before One Atomic Safety and Licensing Board, Element A.2(b) remains inadequate, defined and for this reaman, the element has lausuits pending before the U.S. District Qmrt been rated inedegante. for the Eastern District of New lilock, and the New libet Supreme Court, Suffolk Q)unty. Por the legal conmen still remains.

completer .rrm response, see their letter to WC.

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- LH43D TueBITE05 ptJet MPISEras 4 cm 14/12/04 3ege ' 2 of 9 ,

EAC Plan asetsu

) ANEG RAC OW---

^

_ -iion LIIAD nesponse ARC Svsluation of LII4D 0654 (Cmements in Sold Type for Eadi Element (Action) Response I , Element frase Consolidated RAC Review - Proposed Resolution of Eight Ir=4=ry='ies '

(bereeponds to Liloo's Steseary of - _- -) dated Janaury 16,1985 (sec 1133) l A.3 (1) A deterisination of the overall ming =y of (1) A copy of the confidential avv*arised (1) The a,q-1 ^ resolution appears to be appro-I these amulance and amulette resonirces mist ik=mannid Evacuation Listing will be available priate. A copy of.the couguterised na'=8a=id aueit tabulation of the transportation needs of for FWE's review ducirq the upcoming FWWWBC Bwacuation Listing will be sufficient to deter-+

l non-institutionalised mobility impaired (see

~

mine if the ambulance and amulette resources observed esercise.

sample Invalid / Disabled Evacuation Listing, are arlarriara. It would be appropriate to review '

sone Q, Prr= Awe CPIP 3.6.5, Attadiment 1). the listing prior to any esercise. Itousver, a

final determination of the overall adagnacy of 1 asbulance and amanlatte resources mast aunit j maperison of the nieuber of weicles with the ,

! needs of persons listed in the -g=*-ised g th==hrmwid gyacuation Listing. A emple of re-i sources would be evaluated during an esercies.

• i A03 (2) Se letter of understanding with FAA should (2) A letter of agreement with the FAA is being ('J) The proposed, resolution appears to te appro-be a letter of agreement from the agency to requested and will be included with the letters priate. A letter of agreement with the FDA is

LI"4D (see Appendix B, IF-54). of Agreement, Appendix B. If the letter annot being . _. ^ = " by LII4D. If the seject letter j be obtained, FAA support will be regnested could not be obtained directly by LIIAD, FAA

' through FBE under the auspices of the FIEW. support could also be regaseted thsemagh pWE under the auspices of the Federal Radiological Boergency Response Plan (FM), of tenican the

- Department of Transportation (i.e.: Fan) is a part.

A.3. (3) S ere are no letters of agreement included (3) LIIAD has arranged for the use of Naaman (3) Se prtgomed resolution appears to be appror-l' in the LIIAD Transition Plan with the (bunty veteran's Memorial Coliseuse as a priate. r,rtm has obtained letters of agreement facilities designated to serve as relocation reception center. LII4D has obtained a letter (ftcu the lessee and the Massau Comity '

j eenters. H is element has been rated of agreement from Hyatt Managemmest to allow Esecutive) for the use of the Massau Onliams as inadequate ber mana the plan mast contain Im o to monitor and decantaminate evacuees at a reception Center, and for sonitoring and de-

, letters of agreement with the facilities to be the facility. In addition, Massau Oointy has contamination of evacuses. As stated in FRE's used for the wonitoring and demntamination of written a letter to Hyatt Manayennt affidavit to the ASta dated Feb. 15,1985, fisal evacuees. Oorporation approving the use of the facility aggroval of the Nassau Colisena as a reception in case of a Shorehas emergency. S ese letters center would be contingent agon tuo c3nsidera-j are enc h ri in Attadment 2. tions:

j - details of the esperation of the reception J

and congregate care insections mast be in-corporated within the LIIAD Transition ,

1 Plan, and be revieued and approved by the

! nogional Assistance Committee, I

LIlmo TsueIBITIGE PUWI Br.VISICEI 4 DAEED 10/12/04 Page 3 of 9 N C Plan Review IEJguKi RAC NWtion LIIID Response RAC Syaluaticot of LIUD 0654 (hts in Bold Type for Each Elesment (Action) Regonne Element fress Cbnsolidated RAc anview - Prvynaart Resolution of Eight Irmdarywieg (bereeponds to Lilco's %== mary of ^- - .- - As ) dated Janaury 16, 1985 (S15C 1133)

A*3* - an exercise past be held in dich a demon-(o nt.) stration of the reception conter function can be evaluated.

In addition, the plan should address the access control and traffic flow (of both the vehicles and evacuees) around the Massau (bliseum.

The issue of having to evar=*= the (blisease during periods of contracted use (i.e.: hockey, circias, etc.) Wile there is an emergency at Shorehan should also be addressed by LTrm in U Plan. .

With regard to ocmgregate care centers, the Intter of sqreement with the Nassau (bunty Red Cross identifies the facilities listed in the Intter of Agreement between F.Trm and ABC dated July 25, 1964, as congregate care centers.

However, a map indicating the location of these shelter facilities should be included in the plan. Red Cross staff agreed to provide infor*-

nation and assistance to eve- as recpaired, and to direct evacuees to congregate care centers operated by the Red Croes. No monitoring or decontamination will be perfoceed at these facilities, so Intters of Agreement with enda facility are not necessary.

LILOO has agreed to provide any training to t!m Red Cross that they may recpaire. Red Cross personnel will participate, as appropriate, in emergency planning drills and esercises.

The legal concern still remains.

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m LH4D TMBEITIGI PUW MUISIGI 4 De 10/12/94 44 d I MC Plan Revient ENWG RAC % t W tion f.if m Reeponse RAC Evaluation of LII4D 0654 (n==nts in Dold Type for Eadt Element (Action) Re8Ponee Element from Q)nsolidated RAC Review - Prngmad Resolution of Eight IriadaT='ies W to Lilcx)'s 4-ry of 1_. - e5) dated Janaury 16,1985 (9mc 1133)

C.4 S e letters of agreement with facilities to be See element A.3(3). In addition, a letter of See RAC response for element A.3.

used as relocation centers are missing. This Agreement with the Nassau County Red Cross has

• element has been rated inadequate ber === the been obtained, is enclosed in Attadiant 2.

plan mast contain letters of agreement with the his letter identifies the Congregate Cater facilities to be used for the monitoring and Centers that will be activated in Nassau Oxmty decontamination of evaa=as. Also see analysis to shelter evacuees. Wille a naall number of cxmuments for element A.3. facilities listed are operated by New York State, the runnining facilities provide more than enough capacity for the number of evacuees expected to require shelter assistance.

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LII4D 1MIRITIGB Mall MIFISIGB 4 DMk310/12/34 puse 5 of 9 MC Plan Soview

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IENWIG RAC n=== sits /Her==andation LII4D Aesponse RAC Braluation of LII4D 0654 (Comments in Bold Type for Eadt Element. . (Action) ansponse Element fran Consolidated RAC Review - Proposed Resolution of Eight IcMa'ies Cbrresponds to Lilco's Simmunary of _- -) dated J r_ _-y 16,1985 (SelC 1133)

• I.7 (1) It should be noted that the 150 radio- (1) OPIP 3.5.1, Downwind Surveying, will be re- (1) The proposed solution appears to be logical procedures are still included in the moved from the pr==bres. &gort organise- appropriate. Housver, a final determination Plan. These procedures apparently remain fram tions providing this service will use their own mast aseit the plan review by the RAC of Revision ~3 wherein 150 was to provide field pennnawes. Revision 5.

teams if needed. In Revision 4, there is no plan to use Imo personnel since DOE-RAP will perform field monitoring functions; therefore, the 1510 radiological procedures should be deleted fram the plan.

I.7 (2) Page 7 in Prw =rbre OPIP 3.5.1 has not been (2) OPIP 3.5.2 will be revised to state that (2) The peng==ri solution apears to be darujed in Revision 4. The plan at page the survey team will, if instructed by the RAP appropriate. However, a final detecnination 3.5-2a, line 3-6, states that laboratory anal- Team Captain to expedite return of sa gles, asst await the plan revief by the RAC of ysis can be performed. The potential problen proceed directly to the DOE-RAP heackguarters Revision 5. +

alluded to in line 3 of page 3.5-2a (i.e., the prior to going to the Beergency Worker calculation of thyroid dose from the iodine Decontamination Facility.

samples taken in the field) has not been addressed by any danges in the operating pro-cedures set forth in Procedure OPIP 3.5.1, edtim should provide for expedite laboratory analysis.

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LII4D 1aRISITIGE PIJWI EWPISEGI 4 De 10/12/84 page 6 ef 9

. RAC Plan moview mmWG ahc N tion LIIr0 posponse RAC avaluation of flIm 0654 (% in nold Type for Eadi Element (Action) mesponse Element fresa Consolidated IIAC Aeview - Proposed Resolution of Eight Iri=d=9= ies W to Lilco's Saunary of - --- -) dated J m ary 16, 1985 (fBmC 1133)

I.9 (1) Although mm's asumary of the con- (1) Section 3.3 of OPIP 3.5.2 will be sodified (1) The proposed solution appears to be appro-solidated anC review casaments for novision 3 to prwide for expedited return of field priate. Housver, a final deterisination met ,

stated that awp dited laboratory analysis will samples to Brookhaven National Laboratory for await the plan Eeview. 1 he made, the Procedure (CPIP 3.5.2, Section analysis. See also itesa I.7(2).

3.3) does not include provisions for expediting this analysis. Purther, Prna= Awe OPIP 3.5.1 4

daes not cell for an expedited return of these samples to the laboratory. In fact, the die-crepancies about diere the location of the Envirorumental Survey Puriction, discussed in the

<===nt for element I.8, is also of concern

! here. The instructions in Prna= Aire OPIP 3.5.1

are to be returned to the Baergency Worker e

Decontamination Center at the local BOC diere they will be transferred to the Envirorumental Survey Ptsiction and taken into the BOC for

, further analysis. The plan should be revised i

to clarify that sample media will be taken to Brookhaven National Laboratory for analysis.

I.9 (2) Attachments 5 and 6 of Prm= Awe OPIP 3.5.2 (2) The RAC ameerns identified in the Rev. 3 (2) The penpna=d solution agpears to be appro-have been removed and incorporated into a com- review about OPIP 3.5.2 Attachments 5 and 6 priate. If in addition to Dus-aAP, IBD wishes puterized procedure. The RAC < = ==rits for were that the heading of the tables should be to perfoco independent dose assosoment, then Revision 3 of the plan with regard to the nomo- changed to read, maltiply results by 108-6. provision to obtain irgut data should be gras are still valid. The asstzuptions used in tenen these values were transferred to the incorporated into the plan. A final determi-the computerised approacn may not be realistic. computer ===nry they were iriputted with the nation on the .=d=9=y of this element mast correct units. The RAC concerns on the use of await the plan review.

the nomogram for calculation of thyroid dose using the TG air sampler were addressed in nev. 4.

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. LII4D TMIEITEtEI FIJN IBFIEEEE 4 DREE) 14/12/94 Bege 7 of 9 MC Plan Amriser

. . MEWG Rhc Ozmeentap- " ina LIIAD Response ERC Ruelustion of LII4D 0654 (Qamments in Bold Type for Rada Element (Action)- Response Element frue consolidated RAC Review - Proposed Resolution of Eight Ipanwy=eies Q)cresponds to Liloo's Stsenary of ~ _----) dated J--y 16,1985 (SRC 1133)

I.10. As noted above in the dimanmaion for element The DOB-RAP han uses the IRDhn daee assessment The proposed solution appears to be appropriate.

I.9,. inclusion of the required information in a edel on a portable nahnrne Qauputer. The If in additon toJ)DS-RAF, LII4D intends to have .

computerised procedure may not be adequate, development of this does paame===nt model was an independent dose acessment capability, then since the previous zwision of the plan did not sponsored by the IRC and p@lished in provision to obtain irput data should be contain the required nomograme, and in the NURBG-m-3012. IERD uses the N does incorporated into the plan (see also I.9.2).

current revision this information has been assesament model described in OPIP 3.5.2, on an incorporated into a coguter program. ISO HP-8Sb portable computer. This model is anticipates that DOS-RAP will oscry out dose mathematically the saste that was previously aseeeement ocuputations and, therefore, the included in the manual calculation method of IERO courterized methodology may not be Rev. 3. The information previously needed to necessary. FB R will evaluate the capability cog >lete the missing namograms has been to obtain accurate dose assesament calculations developed and included in the computerized chring an esercise of off-site radiological software. Both of these systems may be used in ,

emergency preparedness. The current version of the BOC whidt has a bedt-q power sqply. .

the plan d)es not contain a method for manual LII4D feels that the availability of two calculation of dose. A pennaanre for manual indepen&mt proven and reliable d)se assessment calculation was contained in Revision 3 of the systems precludes the neessity of having a Plan in the event of computer eslfunction. It manual backup.

appears that Revision 4 addresses a problem by removing the affected pages of the plan not necessarily by correcting the problem. If Im0 decides to retain their procedure described in the plan, cbcumeritation of the computer progras should be provided to FDR for review.

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LIllD 15fe5ITIGE PUWI IWWISE35 4 DMW 10/12/84 %8 N I julC Plan Review MJmBG RAC Canunentsfe _- _.4ation LII4D T-.,nesw RAC Evaluation of LIllD 0654 . (en nts in Bold Type for Ea6 Element (Action) Response Element fran Consolidated RAC Review - hW Resolution of Eight In%w-ies Cm+Js to Lilco's 5hammary of Responses) dated Janaury 16, 1985 (SIsc 1133)

J.9 The FDA amergency PAGs for ingestion are for The Plan will be revised to reference the The proposed molytion appears to be appropriate.

projected dues of 5 ran dele body and 15 rem correct FtR PAGs and Cs-134 has been added to However, a final d' etermination smet await the to the thyroid, not 25 ren thyroid as stated in the list of nuclides uated. The discussion plan renew.

the plan. Also the interpretation of how to use in the Plan will al ised to merectly the response level tables (i.e., instructions quote the Federal ster.

contained in the footnotes) has been incorrectly transcribed from the Pederal Register referenced in the plan. In wE tior., page 3.6-2 lines 46 and 47, should state "5" nuclides, and include Cs-134.

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LII4D TRAIISITIGE PUWI REVISIN 4 DREW 10/12/04 Page 9 Of 9 RAC Flan Review NUIWG RAC &=mants/ ;-- Jetion LII4D Response 0654 (%ts in Bold Type for Eadt Element RAC Svaluation of LIIII)

Element (Action) Response from Consolidated RAC Review - Ptnpnaad Resolution of Eight Irmadarrwies (bereeponds to Lilco's sissaarv of " _ .ssa) dated Janaury 16,1985 (IBBC 1133)

J.10.K These reasons do not alleviate the need to LIIED has identified the roads having the coordinate pre-emergency planning for snow LII4D's proposed resolution is an ig_ i highest levels of traffic flow and will add over Revision 4,' but still does not meet the removal on the evacuation routes. Indeed, them as an attadiment to the procedure. Se requirement of this element. . LII4I) intends to since LIMI) relies on local snow removal Brookhaven and Riverhead 1bunships, Suffolk identify the roads having the highest levels of organizations who may be acrmpanied by ImD (bunty and New lbrk State Department of Ielic traffic flow during an evacuation and will add personnel dio will provide dosimetry to ensure Works will be notified of these road priorities these as an attadusent to Procedure OPIP 3.6.3.

that untrained workers do not remive doses in in case of an evacuation during or immediately It is expected that the plan will also be excess of PAGs for the general public (see following a snowfall. revised to specify that local snow removal

<mmant for element A.1.b), the need to organizations (i.e., Brookhaven and Riverhead coordinate pre-emergency planning for snow Tbunships, Suffolk County and New Drk State removal along evacuation routes is greater in Departments of Public Works) will be notified of this particular case. This is especially true these road clearing priorities by the Ibad

' in view of the fact that since resources may be Iogistics Coordinator (or designee) in the event limited, there is a need to ensure that these an evacuation recommendation is to be imple-resources would be used in an effective manner mented during, or immediately following a diere sheltering may not be remamanded. Pbr example, it would be advisable to ensure that snowfall.

efforts are concentrated on keeping evacuation arteries rather than side streets, driveways, However, according to the plan (see page 1.4-2b 4

etc. clear. The plan is not clear as to how and 2.2-4g), LIIin anticipates that snow removal

ImD could coordinate snow removal by normal agencies within 10-mile EPE will continue to

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response functions in the event, however carry out their normal response timetions.

Therefore, there is no assurance that snow unlikely, they would be needed during an removal agencies will consider and follow tJrm's emergency (see pages 2.2-4g and h of the plan). road clearing priorities. There must be reliable Therefore, pre-emergency planning foe snow pre-emergency planning for snow removal on the removal on the evaucation routes should be evacuation routes including ackninistrative further developed to include ackninistrative Procedure, SOPS, etc. These procedures are procedures, SOPS, etc. as noted in the RAC reviet rer = =anded to ensure that the snow removal for Revision 4.*

strategy would coincide with any evacuation adiene that might be diosen. S e legal concerns still remain.

• It should be noted that one (1) RAC member i felt that this element should be rated adequate.

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