ML20132G326
| ML20132G326 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/17/1985 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Downey T HOUSE OF REP. |
| Shared Package | |
| ML20132G251 | List: |
| References | |
| NUDOCS 8510010525 | |
| Download: ML20132G326 (3) | |
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UNITED STATES e
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NUCLEAR REGULATORY COMMISSION j
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l W ASHINGTON, D.C. 20555
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September 17, 1985 C A RMAN i
i The Honorable Thomas.J. Downey United States House of Representatives i
l Washington, D.C.
20515 Desr Congressman Downey:
In response to your request of August 5,1985 for an explanation of the hasis "for the Comission's change of position" regarding the conduct of
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in emergency exercise at Shoreham, a majority of the Comission believes 1
that the basic position of the NRC has not changed during the course of
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the licensing review for Shoreham.
In accordance with the NRC/ FEMA MOU, 1
the NRC requested the assistance of FEMA in reviewing offsite emergency j
plans and preparedness is part of the NRC's overall evaluation of the i
adequacy of emergency planning for Shoreham.
In memorands dated June 1 and June 17, 1983, the NRC specifically requested FEMA to provide j
seperste findings on whether the LILCO offsite pisp is adequate, whether 1
i it is capable of being implemented and whether LILCO has the sbility to j
implement the plan.
It was understood that the finding regarding LILCO's ability to implement the plan would require the conduct of an d
exercise.
The December 19, 1984 memorindum to FEMA noted the status of FEMA's review of the offsite plan is well is LILCO's propossi for an exercise.
The NRC requested FEMA to take the lead in consideration of the proposed exercise.
In view of LILCO's standing request for an exercise, the NRC i
on June 20, 1985~ requested FEMA to schedule as full an exercise of the Shorehim emergency plan as is feasible and lawful at the present time, j
As indicated in a June 4,1985 memorandum from the Secretary of the Commission, in exercise of the LILC0 plan could, as a minimum, identify 3
the impact of the limitations of LILCO's plan when executed under the j
state and county restrictions. That memorandum also directed the stsff i
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 particip9 tion, an exercise could demonstrate LILCO's ability to respond to a postulated accident scenario at Shoreham, activste the l
Shoreham emergency response organization, fomulate protective action recommendations based on plant conditions and projected doses, and test i
i the meins to slert and notify the public of these protective measures.
These response actions do not necessarily require the involvement of l
state and county support organizations. By testing the plan now, the Commission and FEMA can identify and assure the correction of any l
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l 8510010525 850916 PDR C(799 NRCC l
CORRESPOPSENCE PDR
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The Pon. Thomas J. Downey 2
deficiencies in LILCO areas of role responsibility. Therefore, if, in the future, the authority question is resolved, a subsequent test of the plan could focus largely on areas requiring coordinated. response by LILCO 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 relevant as recent court decisicos have held that deficiencies in emergency planning identified in the exercise may be litigated in the Comission's adjudicatory process.
With reg 1rd to the status of FEMA's review of LILCO's offsite emergency 4
plan, on August 2, 1985, LILCO submitted to the NRC Revisien 5 of the plan which responded ta the remaining plan inadequacies previously identified by FEMA except for the inadequacy regarding the authority issue. On August 13, 1985, the NRC staff requested FEPA's assistance in reviewing Revision 5 of the Shoreham plan.
Pegarding your request for information concerning the cost for such an exercise, we and FEf'A have estimated the costs attributable to observation and evaluation of full participation cmergency preparedness exercises.
For the NRC, sucn costs average on the order of $20,000 per exercise. FEPA has infomed us that their costs for observing the offsite portion of an exercise vary from approximately 190,000 to
$180,000 per exercise. These approximate figures include costs for preparation, travel, actual exercise observation, and post-exercise assessment activities for NRC and FEftA staff and contractor personnel.
They do rot include ccsts attributable to other Federal observers who nay support FEMA's observation efforts as part of the Regional Assistance Comittee (RAC).
The Comission also rotes 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 circunstances, I disagree with the Comission majority. After thinking about this a great deal, I concluded that cnly a potentially workable plan should be exercised. Given the Board's decision that LILCO does not have the legal authority to perfom many of the required emergency response functions set cut in the proposed plan, I question the usefulness
The Hon. Thomas.'. Cowney 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.
Cennissioner Asselstine agrees with my coments.
Sincerely,
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Nunzio J. Palladino Chairman