ML20133E900

Forwards Evaluation of Lilco Transition Plan for Shoreham - Rev 5. Six Inadequacies Identified,Including Concerns Re Legal Basis for Plan Authority & Written Agreements Re Operations Concept

ML20133E900
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	10/08/1985
From:	Speck S Federal Emergency Management Agency
To:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20133E902	List: ML20133E900
References
NUDOCS 8510100056
Download: ML20133E900 (3)

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k,.  ; Federal Emergency Management Agency kf' Washington, D.C. 20472 OCT 8 1985 6

Mr. William J. Dircks c Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear ~Mr. Dircks:

On August 13, 1985, the Nuclear Regulatory Commission (NRC) requested the Federal Emergency Management Agency (FEMA) to conduct a full Regional Assistance Committee (RAC) review of Revision 5 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 5 was submitted to the NRC by LILC0 on August 2, 1985, in response to FEMA Region II's Consolidated RAC Review of Revision 4 dated October 12, 1984. FEMA's findings on Revision 4 were provided to the NRC on November 15, 1984.

A full RAC review of Revision 5 has been completed and the results are-contained in the. enclosed report entitled "LILC0 Transition Plan for Shoreham - Revision 5, Consolidated RAC Review" dated September 23, 1985.

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

FEMA finds that Revision 5 is a further improvement over Revision 4.

Eight inadequacies were identified in the RAC's review of Revision 4; six elements are rated inadequate in Revision 5. The deficiencies and recom-mendations for improvement are explained in the RAC report. The NUREG evaluation criteria for the 6 inadequate 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 major concerns.)

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(1) A.2.b.* Each plan shall contain (by reference to specific acts, codes or statutes) the legal basis for such authorities (i.e., the

1. n authorities mentioned in NUREG-0654 element A.2.a.).

(2) A.3.* Each plan shall include written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role within the Emergency Planning Zones. The agreements shall identify the emergency measures to be provided and the mutually acceptable criteria for their implementation, and specify the arrangements for exchange of information.

(3) C.4.* Each organization shall identify nuclear and other facilities, organizations, or individuals which can be relied upon in an emergency to provide assistance. Such assistance shall be identified and supported by appropriate letters of agreement.

(4) 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 plumes and with those of the Department of Health and Human Services / Food and

. Drug Administration (HhS/FDA) regarding radioactive contamination of htaan food and animal feeds.

(5) J .10. k .* The organization's plans to implement protective measures for the plume exposure pathway shall include: Identification of and means for dealing with potential impediments (e.g., seasonal impassa-bility of roads) to the use of evacuation routes, and contingency measures.

(6) J.12. Each organization shall describe the means for registering and monitoring of evacuees at relocation centers in host areas.

The personnel and equipment available should be capable of monitoring within about a 12-hour period all residents and transients in the plume exposure EPZ arriving at relocation centers.

7 Of the above, all were identified as inadequate in the RAC's review of Revision 4, except J.12, which was previously rated adequate.

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FEMA is now analyzing the results of this review of Revision 5 with respect to Mr. Edward Jordan's memorandum to Mr. Richard Krimm of FEMA e dated June 20, 1985. I hope to respond to that inquiry considering '

Chairman Palladino's response to Congressman Markey on the same subject and various legal proceedings related to Shoreham within several weeks.

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, cmsula LO.

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

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