ML20132G274
| ML20132G274 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/17/1985 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Markey E HOUSE OF REP., ENERGY & COMMERCE |
| Shared Package | |
| ML20132G251 | List: |
| References | |
| NUDOCS 8510010512 | |
| Download: ML20132G274 (3) | |
Text
s p*Ma g
b
?'
UNITED STATES j,
j NUCLEAR REGULATORY COMMISSION iW g
w AsmNGTON, O C. 20555
,%.s.e/
OFFICE OF THE September 17, 1985 CHAIRMAN The Honorsble Edward J. Markey, Chairman Subcocmittee on Energy Conservation and Power Committee on Energy and Comnerce United States House of Representatives Washington, D.C.
20515
Dear Mr. Chairman:
In response to your request of August 5,1985 for an explanation of the basis "for the Concission's change of position" regarding the conduct of an emergency exercise at Shoreham, a majority of the Comission believes that the basic position of the NRC has not changed during the course of the licensing review for Shoreham.
In accordance with the NRC/ FEMA ft00, the f;oC requested the assistance of FEMA in reviewing offsite emergency plans and preparedness as part of the NRC's overall evaluation of the adequacy of emergency planning for Shoreham.
In memoranda dated June 1 and Jure 17, 1983, the NRC specifically requested FEMA to provide separate findings on whether the LILC0 offsite plan is adequate, whether it is capable of being implemented and whether LILCO has the ability to implement the plan.
It was understood that the finding regarding LILC0's ability to implement the plan would require the conduct of an exercise.
The Decenber 19, 1984 memorandum to FEMA noted the status of FEMA's review of the offsite plan as well as LILCO's proposal for an exercise.
The NPC requested FEMA to take the lead in consideration of the proposed exercise.
In view of LILCO's standing request for an exercise, tre NRC on June 20, 1985 requested FEMA to schedule as full an exercise of the Shoreham emergency plan as is feasible and lawful at the present time.
As indicated in a June 4, 1985 memorandum from the Secretary of the Commission, an exercise of the LILC0 plan could, as a minimum, identify the impact of the limitations of LILC0's plan when executed under the state and county restrictions. That memorandum also directed the staff to ask FEMA to respond to five issues if FE"A indicated an exercise is not currently possible. Notwithstanding the absence of the state and county participation, an exercise could demonstrate LILC0's ability to respond to a postulated accident scenario at Shoreham, activate the Shoreham emergency response organization, formulate protective action recomendations based on plant conditions and projected doses, and test the neans to alert and ' notify the public of these protective measures.
These response actions do not necessarily require the involvement of state and county support organizations. By testing the plan now, the Commission and FEMA can identify and assure the correction of any 8510010512 850916 PDR CDFMS NRCC CORRESPONCENCE PDR
~
The Hon. Edward J. Markey 2
4 4
I
' deficiencies in LILC0 areas of role responsibility. Therefore, if, in I
the future, the authority question is resolved, a subsequent test of the plan could focus largely on areas requiring coordinated response by LILC0 and external agencies. The Comission believes such a two-stage test should result in a more expeditious process for assuring that the emergency plan in toto adequately protects the public. This is particularly reTevant as recent' court decisions have. held that i
deficiencies in emergency planning identified in the exe'rcjsa may be litigated in the Comission's adjudicatory process.
With regard to the status of FEMA's review of LILC0's offsite crergency plan, on August 2, 1985, LILCO submitted to the NRC Revision 5 of the plan which responded to the remaining plan inadequacies previously identified by FEv.A except for the inadequacy regarding the authority a
1 issue. On August 13, 1925, the NRC staff requested FEMA's assistance in l
reviewing Revision 5 of the Shoreham plan.
l
. Regarding your request for infomation ~concerning the cost for such an exercise, we and FEMA have estimated the costs attributable to observation and evaluation of full participation emergency preparedness-i exercises. For the NRC, such costs average on the order of $20,000 per exercise. FEMA has infomed us that their costs for observing the l
offsite portion of an exercise vary from approximately $90,000 to j
$180,000 per exercise. These approximate figures include costs for preparation, travel, actual exercise observaticn, and post-exercise assessment activities for NRC and FEMA staff and contractor personnel.
They do not include costs attributable to other Federal observers who l
may support FEMA's observation efforts as part of the Regional l
Assistance Comittee (RAC).
i The Comission also notes that its Licensing Board recently issued a partial decision that held that the lack of state and county participation in executing the emergency plan precluded the issuance of an operating license for Shoreham. The ramifications of that decision are still under review.
In the matter of holding a drill in the current circumstances, I i
disagree with the Comission majority. After thinking about this a great deal, I concluded that only a potentially workable plan should be i
exercised. Given the Board's decision that LILC0 does not have the legal authority to perfom many of the required emergency response i
functions set out in the proposed plan, I question the usefulness I
t
_.-. _. ~. _ -, -
The Hon. Edward J. tiarkey 3
of a drill at this time. Further, the results of a drill of an inadequate plan might create new hearing issues that would need to be addressed, which new issues might not arise if one were to exercise only an adequate plan.
Commissioner Asselstine agrees with my comments.
Sincerely,
-7,
} ')
l,.*[ ( g g ( g.,
(J' Lx Nunzio J: Palladino Chairman cc:
Rep. Ca'rlos f4oorhead
-.