ML20138P033
| ML20138P033 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/30/1985 |
| From: | Butler W Office of Nuclear Reactor Regulation |
| To: | Leonard J LONG ISLAND LIGHTING CO. |
| References | |
| NUDOCS 8511060329 | |
| Download: ML20138P033 (4) | |
Text
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OCT a o s Docket tio.: E0-322 Mr. John D. Leonard Vice President - Nuclear Operations Long Island Lighting Co.
Shoreham Nuclear Fower Station P.O. Box 618, horth Country Road Wading River, NY 11792
Dear Mr. Leonaro:
SUBJECT:
fella fit:Dit:GS ON LILC0 TRANSITION PLAN FOR SHOREHAh The Feceral Er.wrgenc3 Management Agency (FEFA) has reviewed your letter of August 2,1985(ShfiC-11SP), which transmitted your response to the FEMA findings developed as a result of the review by the Regional Assisterce Cornittee (RAC) of Revisfor 4 to the LILCO offsite Trar.sition Flan for Shorehara.
Enclosed is a copy of a memorandum datec Octtt,tr 8,1985, for William J. Dircks cf thc hPC frcm Sarruel W. Speck of FEMA which transmits the results of the I:AC review of Revision 5 to the plan.Ycu will also find enclosed a ccpy of a racecrardurr dated October 24, 1985 f rcia Richaro W. hrim of FEf tA to Edward L.
Jordan of the fiRC which contains a terrection to page 49 of the evaluaticr..
FEMA finds that six inadequete cla.ents still remain in Revision 5 and notes that five of thtst were identified as inadequate in the RAC review of Revision 4.
FEMA indicates that these is a legal authority concern associated with four of the inadequacies ard that in scrae of the inadequacies the 1(gal issues are the najor concerns.
halter R. Butler, Chicf Licensing Brarch fo. 2 Division of Licensing
Enclosures:
As stated cc: Sec rert page h
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OCT 1 0 1985 Docket He.: 50-n2 Mr. John D. Leonaro Vice President - Nuclear Operations long Islano Lighting Co.
Shoreham fiuclear Power Station P.O. 60x 618,110rth Country Road hading River, fiY 11792
Dear Mr. Ltcrcrd:
SUBJECT:
FEt1A FIhDINGS U, LILLO TRA!4SITION PLAN FOR SHCEEf1t*
The Fedcrr.1 Er.ergency Management Agency (FEt?) has reviewed your letter cf August 2, 1985(SNRC-Il9E), which transmitted your responst tc the FEMA findings developed as a result c:' the review by the Regional Assistar;ce Comittee (RAC) of Revisiu; 4 tc the LILCO of fsite Trerisiticr Plan for Shoreham.
Enclosed is a copy of a remorandum datec Octcber 6,1965, for William J. Dircks of the I.P.C f rom bar.:cel W. Speck of fella which trar.srits the results of the RAC review of Revision 5 te tbc pltri. You will also find enclosec a copy of a renorendun. catec October 24, 1985 fron Richard K. Krirrn of FEMA to Edward L.
Jordan of the NRC which contairs a correction to page 49 of the evaluativ.
FEl% fincs that six inadequate clerents still remain in Revision 5 ard nctcs that five cf these were identified as irater,uatt in the RAC review of Revision 4.
FEMA indicates that there it e legal authority concern assccietec with four of the ir.acer,uacies and thot in some of the inadecurcics the legal issues are the uajor cor:ccrre.
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v Walter R. Butler, Chief Licensing Branch flo. 2 Division of Licensirig Enclosures.
As stated cc:
See ccxt page i
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!!r. John D. Leonard, Jr.
Shoreham Huclecr Fower Station Long Island Lighting Company (list 3)
CC' Morton B. Margulies, Chairman Atomic Safety & Licersing l
Aoministrative Judge Board Panel i
Atomic Safety & Licensing Eotrd U.S. Nuclear Regulatnry Comission l
U.S. Nuclear Regulatory Comission Washington, D.C.
20555 t
Washington, D.C.
20555 l
Atomic Safety & Licensing Appeal Dr. Jerry R. Kline Board Panel Administrative Judge U.S. Nuclear Regulatory Commission j
Atomic Safety & Licensing Board Washington, D.C.
20555 U.S. Nuclear Regulatcry Comission Washington, D.C.
20555 Spence Perry, Esq.
Associate General Counsel Mr. Frederick J. Shon Federal Emergercy Mana5eraent Agency Acrinistrative Judge kcom C40, 500 C Street, SW j
Atcnic Safety & Licensing Boara kashingten D.C.
20472 U.S. Nuclear Regulatory Comission 1
Washingten. D.C.
20555 Gerald C. Crotty, Esq.
j Ben Wiles, Esq.
j Jenati'an D. Feinberg, Esq.
Counsel to the Governcr j
New York State Departnent ut Executive Chamber - State Capitot l
Fublic Service Albany, New York 12224 4
Three Empire State Plaza l
Albany, t;cw Yerk 12223 Herbert H. Brown, Esq.
l Lawrence Coe Lampher, Esq.
W. laylor Ecveley, III. Esq.
Karla J. Letsche, Esq.
Hunton & Williams Kirkp6 trick & Leckhart l
707 East Hein Street 1900 N Strett, H.ll. - 8th Floor r
Pcst Cffice Box 1535 Washington, D.C.
20036 Richmono, Virginia 23212 Richard M. Kessel j
Ms. Donna D. Duer Chairman & Executive Director Atomic Safety & Licensing Board Panel New York State Cons ner i
U.S. Nuclear Regulatory Comissicn Protection Board i
Wcshir.gton, D.C.
20555 Room 1725 t
250 Broadway i
Regional Administrator, Resicn I flew York, New York 10007 i
U.S. f.uclear Regulatory Comission 631 Pcrk Avenue James R. Dougherty, Esq.
King of Prussia, Pennsylvania 19406 3045 Porter Street, NW j
Washington, D.C.
20008
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Stephen B. Latham, Esq.
John F. Shea, III, Esq.
Stewart H. Glass, Esq.
i Twomey, Latham & Shea Regional Counsel 1
Attorneys at Law Federal Erergency Management Agency Post Office Box 398 26 Federal Plaza - Room 1349 33 West Second Streeet New York, f.ew York 10278 Riverhead,i:ew York 11901 4
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6 Shoreham (3) cc:
Robert Abrars, Esq.
Anthony F. Earley, Jr., Esq.
Attorney Genercl of the State General Counsel of New York Long Island Lighting Company ATTN: Peter Bienstock, Esq.
176 East Cid Ccunty Road Departrent of Law Hicksville, Ncw York 11601 State of New York Two llcrld Trade Center Mr. Lawrence Britt Roc.n 46-14 Shoreham Nuclear Power Staticn New York, New York 10047 Post Office Eex 616 Wading River, New York 11792 Mr. William Steiger Plant !!ar.ager hartin Bradley Ashare, Esq.
Shoreham Nuclear Pcwor Station Suffolk County Atterrey Post Office Co>. EEE P. Lee Dennison Building Wasine River, f:(w York 11792 Veteran's heacrial Highway Hauppauge, New York 11700 fGB Technical Associates 17:5 Har;ilton Avenue - Suite K Nornan L. Greene, Esq.
San Jose, California 95125 Cuggcnheimer & Untermyer 80 Pire Street Honorable Peter Cchelcr.
New York, liew York 1CC05 Suffolk County Executive County Executive / Legislative Building Mr. Robert Hoffran Veterar's finorial Highway Ms. Susan Rosenfeld Hauppauge, New York 117EL lis. Sharlene Sherwin Post Office Cox 1355 Kr. Jay Dunkleberger f.essapec,ua, New York 11758 New York State Ercrgy Office Agency Building 2 Er.:pire State Flaza Albany, heu York 12223 Ms. Nora Bredes Shorehar. Cppcr.tnts Coalition 195 East Main Street Smithtown, New York 117E7 Resident inspector Shoreham NPS U.S. Nuclear Ftgulatory Commission Post Office Box B Rocky Point, New York 11776 Fabian G. Palomtre, Esq.
Special Counsel to the Governor Executive Chartcr - State Capitol Albany, New Ycrk 122E4
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3 Federal Emergency Management Agency
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Washington, D.C. 20472 OCT 241915 MEMORANDEM EDR: Edward L. Jordan Director, Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Nuclear Regu 4,t Carnission FROM:
fp rd' Erdbm Assistant Associate Director Office of Natural and Technological Hazards Programs SUR7ECT:
Addendum to the FEMA Finding of Revision 5 of the Iong Island Lighting Capany (LIICO) Offsite Emergency Plan for the Shoreham Nuclear Power Station h is is to notify you of an administrative error recently discovered in the FDtA finding on Revision 5 of the LII4D Transition Plan for offsite emergency preparedness at the Shoreham Nuclear Power Station. 21s finding was sent to the Nuclear Regulatory Cminission on October 8,1985.
It was prepared by FEMA Region II and was the result of a full Regional Assistance Cortnittee review.
We error concerned the section dealing with NUREG-0654 element J 12, and appears on page 49 of 66 in Attachment I to the finding letter itself (i.e., in the Regional Assistance Corrvnittee consensus review of the Plan). De first paragraph of the J 12 review sent on October 8,1985 only applied to Revision 4 of the Plan; it was left in the current review by mistake. FEMA Region II has transmitted a corrected page 49, which is attached to this memorandum. S e erroneous paragraph has been deleted.
Please incorporate this corrected page in all Nuclear Regulatory Comnission mples of the FDiA finding package.
We regret any inconvenience that this oversight may have caused. If you have any questions, please don't hesitate to call ~me.
Attachment As Stated p
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TELEC0FIER TRANSMITTAL HE ADER stanquonastrterRAL ctxna nAra COMML/NICATIONS CENTER TEL200t!!R F.MBERS:
RAPICOM 3300 Automatic (202) 646-2504 (202) 646-2432 Nanual VERIFICATION NUMBER:(202) 64_6-2533/2530
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NITACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 49 of 66
- (Rev. 10/85)
NUREC-0654 Element Review Comment (s)
Rating J.11 Maps are now referenced which include all of the (Cont'd) 50-mile ingestion pathway EPZ (see Procedure OPIP 3.6.6, page Ib of 50, page 5.1.12d; and page 4 of 50, 5.7).
The plan now includes references to tables listing dairies, farms and food processing plants.
Maps of 50-mile EPZ are housed at the local EOC (see Plan, page 3.6-8a Procedure OPIP 3.6.6, Sections 5.1.1.2, 5.1.2.3, 5.1.3, 5.4, 5.4.1, 5.7, 5.8 and 7.0).
J.12
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The plan describes how the maximum number of evacuees would be monitored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (see Chapter 3, Section 3.9, B).
In Revision 5 of the plan, LILCO states that in order to monitor the maximum number of evacuees that might be expected to arrive at the Reception Center in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a minimum of 70 monitors will be necessary assuming it takes 1 1/2 minutes to monitor each evacuee.
LERO has additional i
monitors available to monitor vehicles and decon-taminated evacuees.
If these personnel are not Q
needed for vehicle or decontamination monitoring, l
they will be directed to assist in the initial monitoring of arriving evacuees.
E In Procedure, OPIP 3.9.2, Attachment 3, page 3 of 4, a flow diagram ladicates vehicle interiors will be monitored if the exterior is contaminated; however, no setton levels nor prescribed actions are indicated if the interior is contaminated. In addition, in the plan on page 4.2-1 and in procedures OPIP 4.2.3 and 3.9.2, there are statements which say that vehicle
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a0 ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 49 of 66 (Rev. 10/85)
WREC-0654 Element Review Coarnent(s)
Rating J.11 Maps are now referenced which include all of the (Cont'd) 50-mile ingestion pathway EPZ (see Procedure OPIP 3.6.6, page Ib of 50, page 5.1.12d; and page 4 of 50, 5.7).
The plan now includes references to tables
!! sting dairies, farms and food processing plants.
Maps of 50-mile EPZ are housed at the local EOC (see Plan, page 3.6-8a Procedure OPIP 3.6.6 Sections 5.1.1.2, 5.1.2.3, 5.1.3, 5.4, 5.4.1, 5.7, 5.8 and 7.0).
4 J.12 The plan describes how the maximum number of
'l evacuees would be monitored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (see Chapter 3, Section 3.9, B).
In Revision 5 of the plan, LILCO states that in order to monitor the maximum number of evacuees that might be expected to arrive at the Reception Center in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a minimum of 70 monitors will be necessary assuming it takes 1 1/2 minutes to monitor each evacuee.
LERO has additional monitors available to monitor vehicles and decon-taminated evacuees.
If these personnel are not needed for vehicle or decontamination monitoring, they will be directed to assist in the initial monitoring of arriving evacuees.
In Procedure, OPIP 3.9.2, Attachment 3, page 3 of 4, a flow diagram indicates vehicle lateriors will be monitored if the exterior is contaminated; however, i
no action levels nor prescribed actions are indlested If the interior is contaminated. In addition, in the
(
plan on page 4.2-1 and in procedures OP1P 4.2.3 and 3.9.2, there are statements which say that vehicle i
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o Federal Emergency Management Agency Washington, D.C. 20472
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DCT 8 1985 e
Mr. William J. Dircks 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 LILCO 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 "LILCO 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.)
= -
. Each plan shall contain (by reference to specific acts, A.2.b.*
(1) codes or statutes) the legal basis for such authorities (i.e., the authorities mentioned in NUREG-0654 element A.2.a.).
Each plan shall include written agreements referring to the
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A.3.*
(2) 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
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acceptable criteria for their implementation, and specify the arrangements for exchange of information.
Each organization shall identify nuclear and other facilities, C.4.*
(3) organizations, or individuals which can be relied upon in an emergency Such assistance shall be identified and to provide assistance.
supported by appropriate letters of agreement.
Each State and local organization shall establish a capability (4)
J.9.
for implementing protective measures based upon protective action This shall be consistent with the guides and other criteria. recommendations of the Environmental Protectio 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 human 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 i
plume exposure EPZ arriving at relocation centers.
Of the above, all were identified as inadequate in the RAC's review of i
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 I hope to respond to that inquiry considering dated June 20, 1985.
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 If you have any questions, preparedness issues concerning Shoreham.
please don't hesitate to call me.
Sincerely,
% ud) U Samuel W. Speck Associate Director State and Local Programs and Support Enclosures
O LILCO Transition Plan for Shoreham - Revision 5 Key to Consolidated RAC Review Dated September 23,1985
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The Regional Assistance Committee (RAC) review of the LILCO Transition Plan for Shoreham (Attachment I) is based upon planning criteria specified in NUREG-0654, FEMA-REP-1, Rev. 1; Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, November,1980. The plan has been evaluated against each planning element specified in NUREG-0654 applicable to State and/or Local jurisdictions. These evaluations are keyed to the following rating system:
ADEQUATE RATING A (Adequate)
A* (Adequate - concerns pertaining to LERO's legal authority identified during this review)
The element is adequately addressed in The element is adequately addressed in the plan.
Recommendations for the plan provided concerns pertaining improvement shorn in italic are not to LERO's legal authority are resolved.
mandatory, but their consideration The issues of legal authority affecting would further improve the LERO plan.
these elements are more fully described These recommendations include in Attachment 2.
revisions to the NUREG-0654 cross-reference, and other minor Recommendations for improvement improvements.
(not related to legal concerns) shown in italic are not mandatory, but their consideration would further improve the LERO plan. These recommenda-tions include revisions to the NUREG-0654 cross-reference, and other minor improvements.
o
)
I LILCO Transition Plan for Shoreham - Revision 5 Key to Consolidated RAC Review Dated September 23,1985 INADEQUATE RATING I (Inadequate),
l' (Inadequate - concerns pertaining to LERO's legal authority identified during this review)
The element is inadequately addressed The element is inadequately addressed in the plan for the reason (s) stated in in the plan for the reason (s) (not related bold type. The plan and/or procedures to legal concerns) stated in bold type.
must be revised before the element can The plan and/or procedures must be be considered adequate. Recommenda-revised before the element can be tions for improvement shown in italic considered adequate.
Recommenda-are not mandatory, but their consider-tions for improvement shown in italic ation would further improve the LFRO are not mandatory but their imple-plan.
mentation would further improve the LERO plan.
In addition, concerns pertaining to LERO's legal authority were identified by the RAC, and are more fully described in Attachment 2.
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review E
Dated September 23,1985 Page 1 of 66 NUREC-0654 Element Review Comment (s)
Rating A.
Assignment of Responsibility (Orge.nization Control)
A.1.a The lead role for response activities belongs to the A*
utility, LILCO.
The plan establishes the Local Emergency Response Organization (LERO) devel-oped by the utility and comprised of federal, utility and private organizations.
Suffolk County is not participating in offsite emergency planning for Shoreham (see Chapter 1, Section 1.1, page 1.1-1 of the plan which references Resolution 1196-83, adopted February 17,1983 by Suffolk County Legislature), and New York State has not implemented actions (see Chapter 1, Section 1.4, page 1.4-1. of the plan) relative to their authority.
Should New York State decide to respond in the event of a radiological emergency at Shoreham, the types of services that the State might provide are defined as follows (see page 1.4-2a):
o Command and Control e Communications e Evacuation e Social Services e Public Health e Fire and Rescue Should Suffolk County decide to respond in the event of a radiological emergency at Shoreham, the plan provides that the Director of Local Response will work in conjunction with the County Executive or his representative in responding to the emergency (See page 3.1-1). This would incitide the active participation; at the EOC of the County
- See footnote at the end of comments for element A.1.a which are continued to page 3.
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ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 2 of 66
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NUREC-0654 Element Review Comment (s)
Rating A.I.a Executive, Public Information personnel at both the (Cont'd)
EOC and the ENC; and the participation of other County officials to the extent the County Executive deems prudent (See page 1.4-2a).
LILCO expects t
that Suffolk County personnel will continue to perform their normal functions in accordance with referenced sections of The Suffolk County Charter for the following (see page 1.4-b):
e Snow removal e
e Fire Safety e Police Actions The RAC in its review of Revision 4 Indicated that according to the plan, provision for New York State to interface with the LERO decision process is accommodated by LERO's transmission of emer-J gency information via the State's Racilclogical Emergency Communications System (RECS). The plan should be revised to reflect the current situation. The RECS line to New York State has been deactivated (see letter from David Axelrod, Chairman, New York State Disaster Preparedness Commission to Charles Daverio, LILCO: dated July 10,1984), while the plan (see page 1.4-2, line 29) shows this line to be available.
Commercial telephone serves as a means of communication if the State decides to participate.
I In Revision 5 of the plan, LILCO made no modifi-cation to address the RAC's recommendation. How-ever, LILCO stated that:
"The RECS line from Shoreham to New York State may be activated at any time at the discretion of N.Y. State. Thus the statement on page 1.4-2,
- that,
'N. Y.
State has continuous access to emergency event information at Shoreham via the RECS,' is still true. If for any reason the LERO Director of Local Response needs to contact the N.Y. State EOC, he will use commercial phone lines."
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~1 ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 3 of 66 NUREC-0654 Element Review Comment (s)
Rating 9
A.1.a The RAC has evaluated LILCO's response but still (Cont'd) maintains that the plan needs to be revised to reflect the current situation regarding the RECS line.
The response roles of Federal agencies identified in i
Figure 2.2.1 are detailed for the following agencies in Section 2.2 of the plan (see pages 2.2-2a - 2.2-4f). The response roles of' the following agencies are addressed:
e U.S. Coast Guard e FEMA e NRC 4
e DOE 4
e USDA I
e DOC i
e DOD e HHS 4
e DOT-1 e EPA e NCS The plan specifically states that it is expected that i
NRC will assign a liaison to the EOC (see page 2.2-1, lines 44-46).
Figure 4.1.3 Indicates that two centrex/ commercial telephone lines and instruments i
are available at a desk in the operations area of f
EOC assigned to the NRC liaison.
- This element is adequately addressed in the plan.
How1ver, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, l
Legal Concerns for details).
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ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 4 of 66 NUREG-0654 Element Review Comment (s)
Rating A.1.b The operational role of LERO is defined in Sections A
1.4, 2.1 and 3 of the plan.
Definition of the concept of operations has been improved in Revision 4 of the plan. Response roles of the various Federal agencies which may be called upon to support the LERO response have been clarified.
Figure 2.2.1 has been revised to show response organization relati'onships. Agency roles are described more fully (i.e., EPA - page 2.2-4f, USDA - page 2.2-4c).
Pages 2.2-4 and 2.2-4a accurately describe FEMA's role as the primary point of contact and coordination between the NRC and other Federal agencies for nontechnical response activities.
LILCO anticipates that all local law enforcement agencies, fire departments, and snew removel agencies within the 10-mile EPZ will continue to carry out their normal response functions during a radiological emergency at SNPS (see pages 1.4-2b and 2.2-4g).
Revision 4 of the plan clearly states that LILCO has not obtained agreements with Local Law Enforcement Agencies, Fire Departments and Snow Removal Agencies (see Page 2.2-4g, line 47).
Revision 4 of the LILCO Transition Plan specifies the following provisions that would allow police and fire departments to perform thele normal functions in the event of radiological emergency at SNPS.
e LERO will offer training in dosimetry and radia-tion fundamentals and equipment (see Procedure OPIP 5.1.1, Section 5.1.3.4) to these agencies.
e LERO will provide adequate supplies of dosi-metry equipment to these agencies.
e if no training is provided prior to an actual e mergency, LERO will designate personnel trained in radiation protection and equipped with dosimetry to accompany county personnel
O ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 5 of 66 NUREG-0654 Element Review Comment (s)
Rating A.1.b carrying out their duties within residential (Cont'd) areas.
LERO does not intend to use Law Enforcement and Fire Departments where exposures in excess of the general public PAGs are possible.
A.1.c The organizational components of LERO are illus-A trated in Figure 2.2.1.
The position of Radiation Health Coordinator is filled by an outside consultant (see page 2.2-4g) from IMPELL Corporation, who provides LERO with health physics expertise.
Figure 2.2.1 nas been revised to depict Federal support response agencies, and corresponds with the description of roles described in Section 2.2 of the plan (see also comment for element A.1.a).
Commercial telephone serves as a means of com-munication if the State decides to participate.
The RAC in its review of Revision 4 stated that Figure 3.4.1 indicates that both New York State and Suffolk County have RECS communication lines.
The assumption that New York State and Suffolk County would pick up these dedicated lines and receive notification in the event of a radiological emergency is incorrect. The plan should be revised to reflect the current situation. The RECS line to New York has been deactivated (see letter from David Axelrod, Chairman, New York State Disaster Preparedness Commission to Charles Doverlo, LILCO: dated July 10, 1984), while the plan (see page 1.4-2, line 29) shows this line to be available.
In Revision 5 of the plan, LILCO made no modifica-tion to address RAC's recommendation. However, LILCO stated that: "The RECS line from Shoreham to New York State may be activated at any time at the discretion of N.Y. State. Thus, the statement
A'1TACHMENT 1 LILCO Transition Plan for Shoreham - Revision S l
Consolidated RAC Review Dated September 23,1985 Page 6 of 66
~
NUREC-0654 Element Review Comment (s)
Rating A.1.e on page 1.4-2, that, 'N.Y. State has continuous (Cont'd) access to emergency event information at Shoreham via the RECS' is still true. If for any reason the LERO Director of Local Response needs to contact the N.Y. State EOC, he will use commercial phone lines."
The RAC has evaluated LILCO's response but still maint'ains that the plan needs to be revised to re-flect the current situation regarding the RECS line.
l A.1.d Specific individuals who shall be in charge of the A*
emergency response are identified by title under 7
Chapter 2,
organization (pages 2.1 2.1-8).
j Again, LILCO personnel are the majority of LERO staff, along with DOE-RAP personnel from the Brookhaven Area Office (BHO).
The position of Radiation Health Coordinator is j
filled by a consultant provided by IMPELL Corporation. The NUREG-0654 cross-reference has been revised to refer to Appendix B, page APP-B-70 which is a LILCO purchase order to cover the costs associated with the consulting services of a Radiological Health Coordinator from IMPELL Corporation. According to this purchase order, one of either a primary or alternates is required to respond in the event of an accident at SNPS.
The NUREG-0654 cross-reference has also been revised to refer to Appendix B, page APP-B-71 I
which is a proposal from IMPELL Corporation to LILCO to provide personnel to fill the position of Nuclear Engineer which has been added to the LERO organization in Revision 4 of the LILCO Transition Plan.
One (1) primary and four (4) alternates are proposed to fill this position.
- This element is adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details).
ATTACIIMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 7 of 66 NUREC-0654 Rating Review Coment(s)
Element A.I.e T'.a lead Communicator (see page 2.1-7) has A
responsibility for ensuring that all communicator positions in the local EOC are manned on a continuous basis once this facility is activated.
Also, Chapter 3, Section 3.4, pages 3.4 3.4-5 stipulates that the Radiological Emergency Communications (RECS) line between the Plant and LERO, and LILCO's Notification Radio System are monitored 24-hours per day.
A.2.a The functions and responsibilities for major A*
elements and key individuals by title, of emergency response, are specified in the plan for the following:
Command and Control Alerting and Notification, Communications, Public Information, Accident Assessment, Public IIealth and Sanitation.
Social Services, Fire and Rescue, Traffic Control, Emergency Medical Services, Law Enforcement and Transportation. Section 2.1 (see page 2.1-la) of the plan, Figure 2.1.1 and the NU R EG-0654 cross-reference have been revised to specify that the Director of Local Response is responsible for protective response.
Section 2.1 has been revised to distinguish between primary and support responsibilities. Primary and support responsibilities are reflected in Figure 2.1.2, with single f unctions cited.
Procedure OPIP 2.1.1 has been revised to assign primary responsibi!!ty for the following functions to one position within LERO:
Public Information and Notification - Coordina-o tor of Public information.
- See footnote at the end of comments for element A.2.a which are continued on page 8.
j ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 I
Page 8 of 66 t
NUREC-0654 Element Review conunent(s)
Rating A.2.a In Revision 5 of the plan, the Emergency News (Cont'd)
Manager has been removed from Figure 3.8.1 and the Coord. of Public Information is the only position with primary responsibility for Public Information *
(Plan, Chap. 3, Sec. 3.8).
e Accident Assessment - Radiation Health Coor-dinator l
Medical and Public IIealth - Emergency Medical e
Service Coordinator l
e Traffic Control - Traffic Control Coordinator r
Figure 3.3.7 assigns primary responsibility for j
alerting the general public to the LERO Director of 1
Response.
The LERO Coordinator of Public l
Information is responsible for providing public Information.
Figure 3.3.7 has been revised to Indicate that FEMA has no primary responsibility for notifying the public during a radiological emergency.
j in Revision 5 of the plan, FEMA has been added to l
Figure 3.3.7 to Indicate their role in public information for Federal nontechnical emergency response activities (Plan, Chap. 3, Sec. 3.3).
I j
- This element is adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details).
i 4
A.2.b.4.1 refers to legal authority under 10 l'
i CFR 50.47 (c)(1) which provides as follows:
i
)
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 9 of 66 WUREC-0654 Element Review Comunent(s)
Rating A.2.b Failure to meet the standards set forth in (Cont'd) paragraph (b) of this subsection" may result in the Commission declining to issue an Operating License; however, the applicant will have an opportunity to demonstrate to the satisfaction of the Commission that deficiencies in the plans are not significant for the plant in question, that adequate interim compensating actions have been or will be taken promptly,*or that there are 1
other compelling reasons to permit plant operation.
This element has not been addressed in Revision 5.
In light of the recent ASLH concluding partial Initial deelslon on emergency planning dated August 26, 1985 and recent court deelslons (Cuomo v. LILCO, 84/4615, Slip-op. (N.Y. Sup. Ct., Feb. 20,1985) and Cittaens for an Orderly Energy Polley v. County of Suffolk, ev. 83-4966, Silp-op (E.D.N.Y., March 18, 1985)] relating to the legal authority relled upon by LILCO in the LILCO Transition Plan for Shoreham, element A.2.b remains inadequate.
The utility has developed LERO, comprised of utility, Federal, and private Individuals.
If New York State and Suffolk County implement an emergency plan, LERO would follow their lead (see Section 1.4, pages 1.4 1.4.21 also, Attachments 1.4.1 and 1.4.2).
- This element is Inadequately addressed in the plan. In addition, concerns pertaining to LERO's legal authority to implement the plan were Identitled by the RAC during this review (see
. Legal Concerns for details),
i
" Standards A-P specified in criteria defined in NUREG-0654: FEMA-REP-1 Rev.1. Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Prept. redness in Support of Nuclear Power Plants - For Interim Use and Comment, January 1980.
l
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 10 of 66 l
WUREC-0654 1
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Ratina 1
I A.3 Appendix B contains letters of agreement for the 1*
following support organizations identified in Section 2.2 of the plan.
l Signed Dated e DOE /Brookhaven i
National Laboratory Yes Yes e WALK radio Yes Yes e WBLI radio Yes Yes
}
e WCTO radio Yes Yes e WGSM radio Yes Yes e WLIM radio Yes Yes e WLIX radio Yes Yes e WLNG radio Yes Yes e WRCN radio Yes Yes e -WRHD radio Yes Yes e WOLI radio Yes Yes e WRIV radio Yes Yes e
U.S. Coast Guard Yes Yes e New York Telephone Yes Yes e Marketing Evaluations, Inc.
Yes Yes e American Red Cross Yes Yes e Island Helicopter Corp.
Yes Yes e institute of Nuclear Power Operators Yes Yes it has come to the attention of the RAC that two new radio stations on Eastern Long Island, WBAL (Southold) and WSBN (Southhamptom), have substan-tlat listening audiences in the area of the EPZ.
ULCO should make on attempt to obtain letters of agreement with these two radio stations.
The plan states that: "It is anticipated that all local law enforcement agencies, fire departments and snow removal agencies within the 10-mile EPZ will continue to carry out their normal response functions during an emergency."
4
'See footnote at the end of comments for element A.3 which are continued to page 16.
i
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 11 of 66 NUREC-0654 Element Review Comment (s)
Rating A.3 Revision 5 of the LILCO Transition Plan contains no (Cont'd) letters of agreement which assure that local law enforcement agencies, fire departments and snow removal agencies within the 10-mile EPZ will continue to carry out their normal response func-tions during a radiological emergency at SNPS.
However, page 1.4-2b of the plan references Public Laws detalling the responsibilities for snow re-moval, fire dafety, and police actions defined in the 6
Suffolk County Charter.
Letters of agreement and contracts with bus and ambulance suppliers are included in Appendix B for the following resources:
o Bus Companies
- 1,236 40-passenger school buses e Ambulance companies
- 63 ambulances
- 130 ambuletts Bus resources available are adequate to fulfill the potential requirement for 333 40-passenger buses (see Appendix A, page IV-746). The ambulance and ambulette resources available appear adequate to fulfill the potentla! requirements of the special facilities list in Procedure OPIP 3.6.5. According to LILCO, a copy of the confidential computerized Homebound Evacuation Listing would be made available for FEMA's review during an exercise.
RAC found that such listing will be sufficient to determine if the ambulance and ambulette resources are adequate. FEMA would like to review the listing prior to any exercise. However, a final determination of the overall adequacy of ambulance and ambulette resources must await comparison of the number of vehicles with the needs of persons listed in the computerized Homebound Evacuation Listing. A sample of resources would be evaluated during an exercise (see also analysis comments for element J.10.d).
ATTACHMENT 1 1
LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 12 of 66 4
NUREG-0654 Raeing Element Review Comment (s) l Although the revised LILCO Transition Plan does j
A.3 (Cont'd) not speelfy the number of bus drivers that have been tralned and licensed Figure 2.1.1 (page 3 of 4) i speelfles that 333 LERO bus drivers are assigned to l
the three (3) staging areas as follows:
I e Port Jefferson 108 j
l i
e Riverhead 100 j
e Patehoque 125 i
I Total 333 LILCO commits in their summary of the consoll-dated RAC review for Revision 3 of the plan (see l
page 3 of 13), that at least this number of bus drivers will be trained, lleensed and available to i
respond to a radiological emergency at SNPS.
I 1
l The supplementary letter of agreement from DOE l
(dated June 18, 1984), confirms that DOE has l
agreed to provide two, 2-man field monitoring 4
teams and additional teams, if needed. It is evident from this letter and the plan that a DOE repre-sentative will be dispatched to the local EOC to coordinate the relay of fleid monitoring data for use In off-site dose assessment which will be completed i
by the LERO Radiation Health Coordinator. The DOE letter of personnel commitment is adequate.
4 The letters of agreement including contracts, i
purchase orders, proposals, etc. are adequate for the following support organizations (persons or representatives of outside agencies):
(
i e Central Suffolk Hospital e Laboratories which provide environmental
)
sample analysis except Teledyne isotopes e Radiation Health Coordinator i
e Nuclear Engineer e Gasoline purchases f
e Bus Transfer Points
f ATTACHMENT 1 1
LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review i
Dated September 23,1985 Page 13 of 66 l
NUREC-0654 l
Element Review Comment (s)
Retina A.3 The letter of agreement with Teledyne isotopes has (Coat'd) espired and aseds to be updated (see Appendia B, i
page APP-B-74).
i 1
The Letters of Agreem~ent with the State of
{
Connecticut, EPA, and USDA are adequate (see Appendix B, pp. B-72, B-76, and B-77).
LILCO, in response to the RAC comments on Revision 4 of the plan, has specified that FAA support would be requested through FEMA under the I
auspices of the Federal Radiological Emergency l
Response Plan (FRERP) of which the Department of l
Transportation (i.e., FAA) is a part.
However, page 2.2-ta of the plan Indicates that a f
letter of understanding with FAA Is available. This i
letter could not be loested on page B-54 as ladiested in the index to Appendix B. Referenee to a letter of understanding with FAA should be j
deleted from the plan.
In addition, procedures i
should inelude an individual by title who is I
responsible for requesting this support through FEMA.
The letter of understanding with the American Red Cross states that the American Red Cross will set 1
up relocation centers at a predesignated facility or faellities to be listed in the LILCO Transition Plan.
Since the Relocation Center Coordinator, Nursing Support staff and Counseling Coordinator are Amerlean Red Cross personnel, no separate letters of agreement are needed with these individuals.
j LILCO has obtained letters of agreement (from the lessee and the Nassau County Executive) for the use of the Nassau Coliseum as a reception center, and for nionitoring and decontamination of evacuees.
The letter of agreement with Hyatt Management Corporation of New York, Inc. dated September 25, 1984 Is included in Appendix B of the LILCO
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 14 of 66 NUREC-0654 Etement Review Conunent(s)
Rating Transition Plan.
This agreement specifies that A.3 (Cont'd)
Nassau Veterans Memorial Coliseum, Uniondale, New York will be made available to LILCO for the monitoring snd decontamination of evacuees in the event of a radiological emergency at Shoreham.
This letter of agreement also provides that Nassau Veterans Memorial Coliseum will be available to LILCO for the purpose of conducting drills and exercises of the Local Emergency Response Organization (LERO).
With respect to traffic flow in the vicinity of Nassau County Veterans Memorial Coliseum, Figure 7.2 (App. A, p.111-39) addresses this issue. In the event of a radiological emergency at Shoreham, Nassau County Police will direct traffic on public roads surrounding the Coliseum and parking at the Coliseum (see Procedure OPIP 4.2.3, Sec. 2.5).
The flow of vehicles and evacuees within the coll-seum building are shown in Attachments 4 through 9 to Procedure OPIP 4.2.3. Attachments 4 through 6 illustrate the separation and decontamination of contamined personnel. If there has been a particu-late release and incoming vehicles are to be monitored, then vehicle monitoring and decontam-Instion personnel will set up in the area of the parking lot shown in Attachment 7, and detailed in
- of Procedure OPIP 4.2.3.
Vehicles entering the Coliseum parking areas will be mont-tored by twelve (12) two-man monitoring teams set up at the northeast and south entrances to the coliseum parking field (see Sees. 5.7.5 and 5.11.2 and Attachment 7 of Procedure OPIP 4.2.3). Buses and ambulances only will be allowed to enter the western entrance to the Coliseum parking field to discharge passengers entering the personnel mont-toring and decontamination facility (see Sec. 5.8.4, C22, p.13 of Procedure OPIP 4.2.3 and Attachment 7 to that procedure).
i I
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 15 of 66 NUREC-0654 Element Review Comment (s)
Racing A.3 However, there appears to be some confusion (Cont'd) between the discussion in OPIP 4.2.3 and Figure 4.2.2 with regard to the exiting of clean vehicles from the coliseum parking lot.
With regard to the issue of having to evacuate the Coliseum during periods of contracted use, the plan in Section 4.2 (page 4.2-1) specifies that if there is a Shoreham emergency while the Coliseum is in contracted use (i.e., hockey games, circus, etc.), the Coliseum and its parking lots will be cleared within one and one-half hours which is prior to the arrival of the first evacuees.
LERO procedures do not require the use of the arena floor or exhibition hall so that the possible unavailability of these spaces do not inhibit the implementation of the plan.
Procedure OPIP 4.2.3, Section 5.1.1 provide that at a Site Area or General Emergency, the management of local response will contact the Hyatt Manage-ment Corporation to (1) Inform them of the emer-gency status, (2) discuss with them the likelihood of an evacuation and establish when the Coliseum would be required, and (3) Inform them that LERO personnel will be arriving to perform preliminary set up of the facility.
Appendix B contains the letter of agreement between LILCO and the American Red Cross dated July 25,1984. This letter lists facilities with which ARC has agreements allowing them to use those facilities as relocation centers (congregate care centers) during an emergency.
However, at this time it is unclear whether these agreements apply to technological hasards. Also, FEMA is aware that some owners / operators of facilities espected to be available for use by the American Red Crosa contend that they do not have agreements that would apply in the event of an j
emergency at Shoreham. The letters of agreement between American Red Cross and facilities to be i
used as congregate care centers should reviewed.
4 l
1
\\
{'
ATTACH 88ENT 1 l
I 4
i LILCO Transition Plan for Shoreham - Revision 5 4
I Consolidated RAC Review l
Dated September 23,1985 e
i f
Page 16 of 66 i
j IRIREC-0654 Element Review Coaument(s)
Ratina
}
A.3 Personnel from the Nassau County Chapter of the l
j i
(Cont'd)
American Red Cross will report to the reception
)
eenter at Nassau County Veterans Memorial Coll-l soum (see Procedure OPIP 4.2.3, Sections 2.4 and 5.5.7). Red Cross staff will provide information and assistance to evacuees as required, and direct l
j evacuees to relocation centers operated by the Red
- i i
Cross. Since no monitoring or decontamination will be performed at those relocation centers, it is not necessary for LILCO to have letters of agreement
[
with each facility.
[
LILCO has agreed to provide any training to the l
Red Cross that they may require.
Red Cross
{
personnel will participate, as appropriate, in j
emergency planning drills and exercises.
A map of relocation centers (congregate care centers) could not be located in the plan. This map should be developed for use by Red Cross personnel as required by NUREG-0654, element J.10.a, since the relocation centers have been changed from I
those identified in Revision 4 of the plan. This map L
should be also appropriately located in the l
American Red Cross procedures and submitted to i
FEMA for review and comments.
I a
{
Since the list of services to support a ' Federal response is included in the plan only to expedite the L
Identification of where these services are available, f
l no letters of agreement with these businesses are 1
necessary.
4
'This element is inadequately addressed in the plan. In addition, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC during this review (see l, Legal Concerns for detalls).
I l
I
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 8
Consolidated RAC Rev ew Dated September 23,1985 Page 17 of 66 WIREG-0654 Etement Review Comment (s)
Rating The LERO Director of Local Response is responsible A
A.4 for ensuring the continuity of emergency resources for 24-hour operations over a protracted period.
1 The establishment and maintenance of LERO over a protracted period is described in Section 2.1, page 2.1-1, line 26-29; page 2.1.2, lines 36-39 and Procedure OPIP 2.1.1.
The NUREG-0654 cross-reference has been revised to include Procedure OPIP 2.1.1 as a citation for element A.4.
C.
Emergency Response Support and Resources C.I.a According to the plan, the LERO Director of Local A*
Response requests the Governor to ask the President to declare an emergency or disaster.
Revision 4 of the LILCO Transition Plan has been changed to specify that Federal assistance in a radiological emergency at SNPS would be coordinated by FEMA in accordance with the Federal Radiological Emergency Response Plan (FRERP).
The NUREG-0654 cross-reference has been revised to include Attachment 2.2.1 as a citation for element C.1.a.
'This element is adequately addressed in the plan.
Ilowever, concerns pertaining to LERO's legal authority to implement the plan were identitled by the RAC during this review (see Attachment 2, Legal Concerns for details).
C.I.b The DOE-RAP is speelfled to provide radiological A
rr.onitoring assistance and expected times for arrival are provided.
1.
AfrACHMENT 1 l
1 LILCO Transition Plan for Shoreham - Revision 5 j
Consolidated RAC Review i
Dated September 23,1985 i
Page 18 of 66 WUREC-0654 i
i Element Review Conunent(s)
Ratina g
C.I.b Speelfic resources and approximate resource time (s) l (Cont'd) for Federal agencies (including USCO, EPA, NRC i
and USDA) have been included in Revision 4 of the LILCO Transition Plan (see page 2.2-1 and s
l.2.2).
i C.1.e The LILCO Transition Plan identifies resources that A
are available to support the Federal response.
i The inclusion of services provided by Federal agencies under provisions of the Federal Radio-l logical Emergency Response Plan (FRERP) are sufficient to satisfy that resources have been
[
i identitled by the Federal agencies participating in i
FRERP. LILCO has obtained separate letters from EPA and USDA which identify resources needed.to j
support their effort.
i 6
t C.2.s LERO representatives are already at the SNPS site A
l and may be dispatched to the near-site Emergency j
Operations Facility (EOF).
l C.3 Page 3.5-2 of the plan Identifies a minimum of two A
(2) ORS teams from DOE-RAP for monitoring ser-vices and several other organizations for analyses.
I i
l C.4 Speelfle reasons for the inadequate rating of thin 1*
I element are detailed in analysis commenta for element A.3.
i L
- This element is inadequately addressed in the plan. In addition, concerns pertaining to LERO's legal authority to implement the plan were l
Identifled by the RAC during this review (see I, Legal Concerns for detalls).
I a
NITACHMENT1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 19 of 66 3
NtJILEC-0654 Element Review Comment (s)
Rating Emergency Classification System D.
D.3 The Emergency Classification System described in A
Chapter 3, Section 3.2, page 3.2-1 conforms with the system set forth in Appendix ! of NUREG-0654:
FEM A-REP-1, Rev.1.
D.4 The emergency action procedures to be taken are A
adequately described in Chapter 3, Concept of Operations and the Implementing Procedures OPIP 1.1.1 through 5.4.1.
E.
Notifiestion Methods and Procedures E.1 The notification and mobilization of emergency A
response organizations including the verification of messages is outlined in Section 3.3, page 3.3-1 and Procedures OPIP 3.3.2, 3.3.3 and 3.3.4. The LILCO Customer Services Office in the lilcksville Operations Center is the primary LERO notification point.
Figure 3.3.4 (4 pages) has been revised to identify persons / groups / organizations to be notified at general emergency.
E.2 The necessary procedures for alerting, notifying, A
and mobilizing emergency response personnel are found in Procedure OPIP 3.3.2.
Section 3.4, page 3.4-5 which describes the LlLCO paging system, and Figure 3.4.1 have been added to the NUREG-0654 cross-reference as citations for element E.2.
o ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision S Consolidated RAC Review Dated September 23,1985 Page 20 of 66 NUREC-0654 Element Review Comment (s)
Rating E.5 The plan establist;es a system for disseminating A*
appropriate information contained in initial and follow-up messages received from the licensee, including the appropriate notification to the broadcast media.
The notification system described throughout the plan is termed the Emergency Broadcast System (EBS). This system, which is a network of Long Island radio stations, with WALK as the entry station, is not the official Emergency Broadcast System (EBS) for Long Island.
The RAC in its review of Revision 4 acknowledged the fact that LILCO, in its summary of responses to the consolidated RAC review for Revision 3 of the plan has stated that "following statement was received from R.W. deddon, Chief, Emergency Communications Division, FCC on 6/22/84: ' Radio stations are authorized to activate the Emergency Broadcast System upon receipt of a request to activate from a reliable authority. Stations may also ae;lvate the EDS at their own discretion without receiving a request from outside sources.'
(Emphasis on original.) Therefore, the use of the term 'I'.DS' within the LERO framework is appro-priate." FEMA received clarification from FCC on
- October 17,1984.
Mr. R.W. Seddon in his letter to FEMA indicated that the FCC rules Subpart G, Section 73.935(a)
Emergency Broadcast System, specified that the EDS may be activated at the State and local level by AM, FM and TV broadcast stations, at management's discretion, in connection with day-to-day emergency situations posing a threat to the safety of Ilfe and property. In other words, it is up to each Individual station as to whether they will activate the EDS for a State or local emergency.
Their participation is entirely voluntary.
l L
o i
ATTACHMENT 1 q
LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review y
j' Dated September 23,1985 Page 21 of 66 NUREG-0654 j
Element Review comunent(s)
Ratina a
E.5 Mr. Seddon also informed FEMA that Section A*
(Cont'd) 73.1250 of the FCC rules allows AM radio stations I
to stay on the air with their full daytime facilities if, in the broadcasters mind, the situation threatens life or property and no other broadcast station is adequately providing this service. Section 73.1250 i
operation can be accomplished without a local j
official's response.
Accortting to FCC, draft local EBS plans for the Nassau and Suffolk Counties of New York have j
never been finalized. However, if the Long Island l
Lighting Company and several local radio stations i
have developed a plan of their own for disseminat-Ing information to the public via EBS, the FCC
}
would prefer to review the plan to insure that it conforms with the FCC EBS rules, and that it i
enhances the National Level EBS.
j
- This element is adequately addressed in the plan.
i i
However, concerns pertaining to LERO's legal l
authority to implement the plan were identified by l
the RAC during this review (see Attachment 2,
{
Legal Concerns for details).
I j
L6 The prompt notification system consists of 89 fixed A'
sirens, tone activated radios provided to special
{
facilities, (i.e., schools, hospitals, medical support hospitals, handicapped faellities, ambulance companies, nursing homes,and major employers, etc.), EB8, and a mobile public address system.
j Marketing Evaluations incorporated will verify that j
each siren has activated (see page APP-B-53). The j
plan adequately covers the need to demonstrate, under NUREU-0654 criteria, that there are means to notify the public.
{
'This element is adequately addressed in the plan.
j However, concerns pertaining to LERO's legal authority to implement the plan were identifled by l
the RAC during this review (see Attachment 2 l
Legal Concerns for details).
i
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 22 of 66 NUEEC-0654 Element Review Comment (s)
Rating.
The draft messages intended for the public found in A
E.7 Procedure OPIP 3.8.2 satisfy NUREG-0654 requirements.
Draft EBS messages are included in the plan for the following conditions:
e Unusual Event - No EBS message is to be alred during an Unusual Event.
e Alert (No radiation release) e Site Area Emergency (No radiation release)
Site Area Emergency (Radioactive release).
e e General Emergency (Sheltering) e General Emergency (Sheltering and Evacuation) e General Emergency (Evacuation)
Procedure OPIP 3.8.2 includes the following additional draf t messages:
e EBS Activation Advisory e Alert (Release of Radiation) e De-Escalation of Emergency e Termination of Emergency e Test Message for EBS e Spurious Activation Message of Prompt Notification Sirens Description of Emergency Planning Zones for e
Suffolk County (to be included in EBS messages).
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 23 of 66 NUREG-0654 Element Review Comment (s)
Rating E.7 In response to RAC commests on Revision 4 of the (Cont'd) plan, LILCO made the following changes in Revision 5:
e OPIP 3.8.1, Section 5.2.4.f calls for distribution of press releases to the utility, rumor control staff and any government P!O's.
o OPIP 3.8.2, Attachment 4, Messages E, F, G, H have been modified in terms of percentage of EPA PAG's.
e EBS messages have been revised to include a statement advising action by the food industry.
OPIP 3.8.2, Section 5.2.2.f calls for developing a supplementary EBS message to inform people in ingestion pathway of appropriate actions.
Sample message D states that milk producing animals will be placed in shelters and on stored feed.
o OPIP 3.8.2, Attachment 4. Messages E, F, G, H have been revised to allow for the broadcast of protection actions based on the plant conditions before a release of any significance occurs.
e OPIP 3.8.2, Attachment 4, an EBS message has been modified to indicate that protective actions may continue to be recommended after the emergency at Shoreham has been terminated.
F.
Emergency Communications F.1.a Provision for 24-hour activation of the LERO A
emergency response network is accomplished via the RECS line in the LILCO Customer Service
o l
ATTACHMENT 1 i
1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page '44 of 66 NUREC-0654 Element Review Conunent(s)
Rating Office in the Hicksville Operations Center (see F.1.a (Cont'd)
Section 2.1, page 2.1-7 and Section 3.4, pages 3.4-1 to 3.4-5). This RECS line is monitored on a 24-hour basis and the LERO officer at the Customer Service Office is responsible for activating the paging system which notifies key emergency response personnel that an actual incident has occurred.
The LILCO Notification Radio System se ves as the backup communication system to the RECS for communications between the Shoreham Control Room and the LILCO Customer Service Office.
F.1.b Section 3.4 E (page 3.4-4) provides for communi-A cations from LERO to Suffolk County, Nassau County, New York State, and Connecticut via commercial telephone and centrex.
Since no portion of the State of Rhode Island is within 50 miles of SNPS (see Figure 1.1.1), the issue
}
of provisions for communication with Rhode Island
{
is not a concern.
j The NUREG-0654 cross-reference has been revised to include Section 3.4, page 3.4-4 as a citation for element F.1.b.
1 F.1.c The plan provides for notification of the following A
federal emergency response organizations (See plan, Chapter 2, pages 2.2 2.2-4f):
e FEMA e NRC e DOE o USDA e DOC e DOD if45 e
l l
h
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 i
Consolidated RAC Review Dated September 23,1985
.i ?- 66 S,e NUREC-0654 Element Review Comment (s) vgn,
U.S. Coast Guard (USCG) e Federal Aviation Administrati
- n W Figure 3.3.4 (see page 3 of 4) has been revised to include NRC, FDA, DOE, USDA, DOC, EPA, and HHS (Public Health Service).
The notification of other federal emergency support organizations will be completed by FEMA (see page 2.2.4, lines 29-30 and 45-47; page 2.2-4a, lines 1-8).
The RAC in its review cf Revision 4 of the plan recommended that provision for notification of the Long Island Railroad should be addressed in the plan.
According to LILCO's response to RAC comments, the Long Island Railroad has refused the offer of a Tone Alert Radio. This offer is being repeated.
If the Long Island Railroad will refuse the second offer of a Tone Alert Radio, LILCO should have another mechanism to notify the rattroad company.
F.1.d Com'munication between the local EOC in A
Brentwood, New York and the licensee's EOF (or TSC) is maintained via the following means (see Figure 3.4.1):
e RECS line (except New York) e commercial telephone e radio e dedicated telephone (except New York)
The RECS line will allow 24-hour per day notification between the plant and LERO.
Communication with the radiological field monitoring teams is maintained via radio link, i
e
-.c-,
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 26 of 66 NUREC-0654 Element Review Comument(s)
Rating F.1.e The provisions for alerting and activating A
emergency response personnel in each response organization as described in Section 3.3, pages 3.3-1-4; Figures 3.3.2, 3.3.3 and 3.3.4 of the plan and Procedure OPIP 3.3.2 are adequate.
Figure 3.3.4 has been revised to speelfy that the notification list of persons / groups / organizations to be notified at site area emeNency and general emergency are the same (see comment for element E.1, above).
F.2 Communications with fixed and mobile medical A
support facilities are specified in the plan as follows:
Means e Ambulance dispatch commercial telephone stations and radio l
o Ambulance drivers radio link via j
dispatch station i
e Hospitals commercial telephone l
and radio links via ambulance dispatch i
stations and mobile ambulance units.
I l
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 27 of 66 NUREC-0654 Element Review Consent (s)
Rating F.3 Communication drills will be conducted by LILCO A*
(see Section 5.2, Part A, page 5.2-2a). Commun-leations wf!! be tested monthly; while communica-tions between the plant, the local EOC, and field monitoring teams will be tested annually. Also, see page 3.4-7.
The plan has been revised to include the required frequency of siren tests in accordance with NUREG-0654, Appendix 3, page 3-12, Section h(2).
- This element is adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for Details).
G Public Education and Information G.la-d Section 3.8, pages 3.8-1-3 of the plan provides for A
the dissemination of brochures to the public which include the information required by NUREG-0654.
The information to be provided will include:
e educational information on radiation l
e contact for additional information e protective measures e survey card on special needs of the handicapped.
Educational brochures will be mailed to all households and commercial establishments. LILCO i
plans to use their billing lists for the malling. In addition, inserts will be developed for the Suffolk telephone directory which will include the following:
e Map of 10-mile EPZ/ emergency planning zone e List of EBS stations e S!ren system description / purpose
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 28 of 66 NUREC-0654 4
Element Review Comment (s)
Rating e Protective actions the public may be advised to G.1.a-d (Cont'd) take (sheltering, evacuation) i e Relocation center locations e items to take along for an evacuation.
Local telephone directories will also contain the above items. In addition, these local directories will contain maps showing evacuation routes.
Brochures will be updated on an annual basis, and an annual orientation of news media will be reinforced during annual exercises.
With regard to EBS activation, see comment for element E.5.
G.2 The public information program and provisions for A
its dissemination as described in Section 3.8 of the i
plan are adequate.
4 i
G.3.a The emergency news center (ENC) is to be estab-A*
lished in the Quality Inn, Old Mill in Ronkonkoma, New York.
This facility will be set up as the central clearing house for the release of informa-tion received from the utility and LERO representa-tives (see Section 3.8, page 3.8-4).
The plan provides that " private and public agency /or organ-ization representatives (i.e., American Red Cross, Suffolk County, FEMA, NRC, State officials, etc.)
will be invited to participate as a panel in all news l
conferences."
l l
E
~
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ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 29 of 66 NUREC-0654 Element Review Comunent(s)
Rating G.3.a The NUREG-0654 cross-reference has been revised (Cont'd) to include page 3.8-1 as a citation for element G.3.a.
i
- This element is adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details).
G.4.a The LERO Coordinator of Publie Information (CPI)
A and LILCO's Emergency News Manager at the ENC is the designated spokesperson(s) for LERO.
G.4.b LERO Public Information Personnel at the ENC are A
charged with the responsibility "to provide accurate information (to the media) on a timely basis."
i G.4.c The ENC is designated as the central location for A
rumor control. The rumor control point is for the use of utility personnel at the LILCO Customer Relations District Offices and the LILCO Customer Call Boards, in answering questions asked by the public. The rumor control point will be staffed by representatives from LERO and the utility.
The RAC in its review of Revision 4 Indicated that the plan does not provide information about rumor control staffing, the number of rumor control telephone lines that will be available and staffed, and how current information will be provided to the rumor control staff. It is recommended that the rumor control staff be provided with press releases and radio emergency information bulletins to assure that they are apprised of the current emergency status.
i i
ATTACHMENT 1 i
LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 30 of 66 NUREC-0654 I
Element Review Comument(s)
Reting G.4.e LILCO responded to the RAC comments by stating l
(Cont'd) that rumor control is the responsibility of the SNPS o tsite organization as detailed in the onsite
]
procedure EPIP 4-4.
LERO supports this effort through the use of call boards and Customer Relations personnel.
1 The onsite procedure EPIP 4-4 should be submitted 1
to the RAC for review and comments or should be included in the offsite plan. The effectiveness of I
the rumor control system would be evaluated during i
an exercise of offsite radiological
G.5 LERO will coordinate an annual orientation program A
for the news media. This program will familiarize the media with the following:
i j
e Utility emergency plans e Radiation information i
e Points of contact for release of public information in the event of an emergency e The location and operation of the ENC.
]i H.
Emergency Facilities and Equipment H.3 The local EOC to be operated and staffed by LERO A
personnel is located at the LILCO Operations Facility in Brentwood, Long Island, New York.
H.4 The activation and staffing of the local EOC by A*
LERO personnel is specified in Section 3.3, page 3.3-1; Section 4.1 page 4.1-1 and Procedure OPIP l
4.1.1 of the plan.
The issues that resulted in the provisionally adequate rating for Revision 3 of the plan have been resolved.
4
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 31 of 66 NUREC-0654 Element Review Conunent(s)
Rating H.4 e The Radiation Health Coordinator and Nuclear (Cont'd)
Engineer have been added to the notification plans 'and procedures (see Figures 3.3.3 and 3.3.4; Procedure 3.3.2).
e Figure 3.3.4 (4 pages) has been revised to identify persons / groups / organizations to be notified at general emergency (see comments for elements E.1 and F.1.e).
e The plan has been clarified to state that upon his arrival at the local EOC, the Director of LERO will establish contact with the LILCO EOF and the New York State EOC (see Plan, Chapter 4; Section 4.1, A).
e The RAC in its review of Revision 4 states that the notification of the New York State EOC (page 4.1-1, line 44) should be reviewed. Since the RECS line is no longer operational, the State EOC will, in all likelihood, not be operational.
This notification should probably be to the State Warn!ng Point.
In Revision 5 of the plan, LILCO made no modifica-tion to address RAC's recommendation. However, LILCO stated that:
"Shoreham onsite personnel will notify New York State by either RECS or commercial phone lines.
LERO will provide information to New York State via the RECS if they are participat-ing in the emergency response."
The RAC has evaluated LILCO's response but still maintains that the plan needs to be revised to reflect the current situation regarding the RECS line.
t 4
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 32 of 66 NUREC-0654 Element Review Comment (s)
Rating Due to changes made in Revision 4 of the LILCO H.4 e
(Cont'd)
Transition Plan, the locations of several i
functioris performed have been changed to Brookhaven National Laboratory. In Revision 5 of the plan, procedures OPIP 2.1.1, attachments 2,3 and OPIP 3.3.3, attachment 2 have been reviewed and revised to assure consistency with the plan.
The'NUREG cross-reference has been revised to e
include Procedure OPIP 4.1.1 as a citation for element H.4 (s'ee cross-reference, page XV, H).
'This element is adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC,during this review (see Attachment 2, Legal Concerns for details).
H.7 The two (2) Offsite Radiological Survey (ORS)
A teams, each consisting of two (2) individuals per team from DOE-RAP are provided in the plan.
These teams will obtain their ORS kits at Brookhaven National Laboratory (BNL).
Equipment is shown for the two ORS teams on page 4.4-1.
The plan has been revised to clarify that the LILCO ORS kits to be stored and maintained at the local EOC in Brentwood are back-up equipment that will be used by DOE-RAP team members if required.
I l
l
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 33 of 66 NUREC-0654 Element Review Comunent(s)
Rating H.10 Section 5.3 of the plan provides that LILCO will A
inspect, inventory and operationally check emer-gency response equipment at least once each calendar quarter. Calibration of instruments will be done at intervals recommended by manufacturers.
The plan also makes provision for reserve equipment.
The availability and maintenance of backup field monitoring equipment at the local EOC in Brentwood has been clarified in the plan.
H.11 A detailed list of equipment to be used in the A
emergency response by LERO is located in the portions of the plan listed in the NUREG-0654 cross-reference.
In Revision 5 of the plan, the inconsistency regarding the ORS kits has been removed since OPIP 3.5.1 has been deleted. LILCO states that the ORS kits maintained at the EOC provide backup equipment in the event that Brookhaven National Lab, which is within the EPZ, became inaccessible.
Radio communications will be maintained between the field teams and the DOE-RAP team captain located at the DOE Brookhaven Area Office (see page 3.5-2a of the plan). A DOE-RAP team liaison will be deployed to the local EOC in Brentwood to complete the communications between field teams and the EOC.
)
H.12 Page 3.5-2 of the plan states that field data will be A
radioed back to the Environmental Survey Function i
and all samples will be returned to the local EOC, j
or as directed, for laboratory analysis by DOE-RAP j
or SNPS labs.
I i
i
=
ATFACHMENT 1 i
LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review 1
Dated September 23,1985 J
Page 34 of 66 j
NUREC-0654 Element Review Comument(s)
Rating l!
Accident Assessment i
l The LILCO Transition Plan has been revised to specify that LERO will depend solely upon DOE-i 4
RAP for radiological field monitoring and dose assessment functions. Although the review of DOE-RAP procedures is outside its responsibility, the RAC acknowledges that the DOE-RAP systems are adequate to accomplish the field monitoring and i
dose assessment functions described in the plan.
j l
1.7 The capability and resources for field monitoring A
within the plume exposure EPZ are to be provided through the DOE-RAP resources at the Brookhaven Area Office.
The capabilities, mobilization, l
response time, and equipment for these resources are provided in the FRMAP plan for the support of local emergency response plans.
l The LERO radiological procedures, OPIP 3.5.1, l
Downwind Surveying, has been deleted from the i
plan in Revision 5. The plan calls for DOE-RAP to l
use their own procedures. In addition, Procedure OP!P 3.5.2 details provisions for transporting environmental media to the laboratory for expe-dited analysis of radiolodine field samples after a i
field analysis.
Revision 5 of the plan also clarifles that the information provided in Attachment 2.2.1 is the equipment in the DOE-RAP team kits.
1 i
l I.8 The capabilities, equipment and expertise for A
accident and dose capabilities are found in l
Procedure OPIP 3.5.2.
Field team composition, communication, monitoring equipment and estimated deployment times are found in Section 3.5 and Procedure OPIP 3.5.2.
Page 3.5-2 of the plan gives field team composition.
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 35 of 66 NUREC-0654 Element Review Comunent(s)
Rating I.8 Pages 3.1-2 and 4.1-2 of the plan specify that the (Cont'd)
LERO Director of Local Response, with the Radiation Health Coordinator, is responsible for formulating the protective action decisions.
A Nuclear Engineer has been added to the LERO emergency response staff (see Figures 3.3.3,3.3.4, 3.5.2; page 3.5-2). This individual is responsible for evaluating the plant status to determine the potential for a radiological release in making protective action recommendations.
The RAC, in its review of Revision 4 of the plan, stated that guidance given in Section 5 of Procedure OPIP 3.6.1 and Attachment 5 thereto does not include all of the pertinent variables (e.g., wind speed).
Also see analysis comments for element H.4, where related issues are discussed.,
LILCO responded to RAC comment by stating that in OPIP 3.6.1, the Nuclear Engineer is directed to obtain information from the Radiological Emer-gency Data Form.
This form contains all the radiological information needed including windspeed.
However, the referenced section 5.0 and Attachment 5 of OPIP 3.6.1 do not require information concerning windspeed.
Prior to the radiological release occurring, protective actions are based upon an evaluation of plant systems and an estimate of when these systems are expected to degrade to the point of causing a radiological release.
Consequently windepeed is not used to determine the efflesey of evacuation in this case.
The RAC found LILCO's response to be adequate.
In response to RAC comments, OPIP 2.1.1 in Revi-sion 5 of the plan has been revised to indicate that personnel from the DOE-RAP Team will only report to the DOE Brookhaven area office at Brookhaven National Laboratory. In addition, OPIP 3.5.1 has been deleted.
ATTACHMENT 1 4
LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 36 of 66 t
NUREC-0654 Element Review Comment (s)
Rating
!.9 Section 2.2, Attachment 2.2.1 states that the DOE A
j Brookhaven Area Office een provide support to LILCO for airborne radiolodine sampling and analysis to concentrations as low as 5x10E-08.
The revised procedures now call for measurement of the particulate filter activity in all cases.
The procedure has also been revised to include an ex-planation and precaution for the mix and decay of radioisotopes released. The procedure has also been revised to include provisions to verify field men-surements with laboratory measurements for i
samples exhibiting activity when release assump-tions are not valid.
In response to RAC comments, Section M, OPIP vid fr x di ed r urn f e d sam le
{
Brookhaven National Laboratory for analysis (see also item I.7).
The RAC, in its review of Revisions 3 and 4, identi-fled concerns about Procedure OPIP 3.5.2, Attach-ments 5 and 6 that the heading of the tables should be changed to read, multiply results by 10E-6.
In response to RAC comments, LILCO stated that
{
when these values were transferred to the computer i
memory they were entered with the correct units.
The computer calculations involve certain assump-1 tions (as did the nomograms) with regard to the mix l
of radionuclides being released (most probable BWR sequence). The RAC concerns on the use of the nomogram for calculation of thyroid dose commit-
]
ment using the TCS air sampler were addressed in Revision 4.
In Revision 5 of the plan, LILCO also clarified the issue of independent dose assessment capability of LERO. In addition to DOE-RAP, LERO can perform Independent dose assessment using OPIP 3.5.2.
Provisions are included in Section 2.3 to obtain field l
monitoring data from either the DOE-RAP liaison in
?
y-n.,
n.
,r---
,n-
,w..
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 l
Consolidated RAC Review Dated September 23,1985 Page 37 of 66 l
l NUREC-0654 Elemene Review Comunent(s)
Raeina the local EOC or from SNPS field teams via the LS (Cont'd)
EOF.
i j
!.10 The procedures for estimating integrated dose from A
the projected and actual dose rates (plume exposure) were found in Procedure OPIP 3.5.2.
l Ingestion pathway dose estimations were found in Procedure OPIP 3.5.3.
Procedure OPIP 3.6.1 contains protective action recommendations.
The LERO plan adequately describes provisions for relating measured parameters to projected esti-I mated dose commitments and provides for relating l
ground deposition to need for additional protective actions.
i LILCO has specified in its response to the RAC comments on Revision 4 of the plan that the DOE-RAP team uses the IRDAM dose assessment model on a portable Osborne Computer. LERO uses the ACCDOS dose assessment model described in OPIP 3.5.2, on an HP-85b portable computer. This model is mathematically the same that was previously included in the manual calculation l
method of Revision 3.
The information previously needed to complete the missing nomograms has I
been developed and included in the computerized I
software. Both of these systems' may be used in the EOC which has a backup power supply.
The RAC found that the use of the IRDAM code by DOE-RAP and the availability of the ACCDOS code f
in the local EOC will provide sufficient backup i
calculational espability. With these two separate calculational systems available, there is no need for a backup hand calculational method.
Provisions have been made to obtain field data for input to the ACCDOS code in the local EOC (see also RAC comments for element 1.9).
The NUREG-0654 cross-reference has been revised to include Procedure OPIP 3.6.1 as a citation for element 1.10.
~..
_ ~ _.. - - _. _ _ - _. _ _ _ _ _ _ _ _ _. _ _ _. _ _ _ _ _ _ _.
ATTACHMENT 1 l
i LILCO Transition Plan for Shoreham - Revision 5 i
Consolidated RAC Review Dated September 23,1985 i
Page 38 of 66 NUREG-0654 i
Element Review Comument(s)
Rating I.11 Capabilities to locate and track the plume (fleid A
j monitoring) are to be provided through the DOE-i RAP resources at the Brookhaven Area Offlee. The capabilities, mobilization, response time, and equipment for these resources are provided in the FRMAP plan for the support of local emerg2ncy response plans (see Attachment 2.2.1 of the plan).
i l
J.
Protective Response.
J.2 The provisions for evacuation of SNPS non-essential A
j site personnel in Section 3.6 (page 3.6-8a) describe j
the route to be taken if a public evacuation is in progress (i.e., high traffic density). The plan has I
been revised to specify that, depending on radio-logical or meteorological conditions, SNPS non-j essential personnel would be instructed either to j
report home or to the Wildwood Substation.
j LILCO's summary of responses to the consolidated l
RAC review comments for Revision 3 (see page 7 of l
- 13) clarifies that the evacuation route for non-l essential site personnel is the same regardless of a public evacuation in progress or whether there is j
inclement weather.
The plan has also been revised to specify that evacuees from the SNPS. site would leave in the
)
same personal vehicles they used to travel to the i
j site.
i J.9 EPA's plume exposure and FDA's ingestion pathway I
PAGs are listed in Section 3.6.
l A Nuclear Engineer has been added to the LERO I
emergency response staff. The procedures to be used by this indiridual are set forth in Procedure OPIP 3.6.1 (see comments for elements I.8 and J.10.m).
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 39 of 66 l
NUREC-0654 Element Review Conument(s)
Rating J.9 The plan, Revision 5, page 3.6-2 correctly states the I
(Cont'd)
FDA Emergency PAG as 5 rem whole body and 15 rem to the thyrold. Page 3.6.3 of the plan, Revision 5, has been revised to include a fifth radionuclide (Cs-134) for which ingestion PAGs are also shown in Procedure OPIP 3.6.6.
However, the incorrect quotation of the 'FDA derived response level tables in OPIP 3.6.6 have not been corrected to incorporate all footnotes from the latest FDA guidance."
The NUREG-0654 cross-reference has been revised to include Table 3.6.1 as a citation for element J.9.
"One RAC member felt that this element should be rated adequate.
J.10.a The Evacuation Plan (Appendix A Section 1-Preface pages 1-1 to 1-2) is made up of two plans - a study performed by Suffolk County as part of an agree-ment with LILCO (9/21/81), and a study performed by KLD Associates under an agreement with LILCO to develop an evacuation plan (12/30/81), Lir " O has integrated the two studies into AppendP....
The maps showing evacuation routes, evacuation areas, and shelter areas are included in the plan.
However, a map of relocation centers (i.e., congre-gate care centers) could not be located in the plan.
l l
'This element is adequately addressed in the plan.
I However, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details).
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 i
Consolidated RAC Review Dated September 23,1985 i
i Page 40 of 66 NUREC-0654 i
Elseent Review Comment (s)
Rating l
The plan has been revised to specify that some A
J.10.b evacuation zones (i.e., Zones F and K) have been
~ into subsones for planning purposes.
i subdivided Zones would be evacuated in their entirety and therefore, a map depicting subarea boundaries within these zones is not necessary.
A map (see Figure 7.1) has been included in Revision i
4 of the plan which depicts the population by ERPA projected for 1985 for winter and summer.
i a
j J.10.e The means for notifying the transient and resident A*
j population consists of fixed strens (89 units) and EBS.
l; The NUREG-0654 cross-reference has been revised to include Procedure OPIP 3.3.4, Section 5.4 l
(notification of the deaf) as a citation for element
]
J.10.c.
i l
- This element is adequately addressed in the plan.
l However, concerns pertaining to LERO's legal authority to implement the plan were identified by I
the RAC during this review (see Attachment 2, Legal Concerns for details).
i 1
J.10.d The procedures and inventory of requirements for A
j protecting institutionalized mobility impaired persons are being completed.
l The means and procedures for completing the direc-l tory of non-institutionalized mobility impaired individuals is adequate. The listing of non-l Institutionalized mobility impaired individuals is being placed into LILCO computers to allow for 1
i
_ = _ _ _ -
s i
4 i
I ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 41 of 66 NUREC-0654 Element Review Conument(s)
Rating J.10.d updating and quick retrieval. The Special Facilities (Cont'd)
Evacuation Coordinator will have a printout of the f
Invalid / Disabled Evacuation Listing (see Procedure OPIP 3.6.5, page 2 of 20, Section 4.0; and Attach-g ment 1). The computer listing of invalid / disabled persons will be kept at the local EOC and can also be printed out directly by computer at the Brentwood facility, ther' by ensuring the availability e
of up-to-date information.
The listing to be compiled codes seven (7) categories of needs including hearing, ambulatory (i.e., curbside pickup
- including assistance) and non-ambulatory (i.e.,
ambulance and ambulette - includes wheelchair i
needs) to facilitate notification and the coordination of transportation equipment if relocation of these persons is necessary.
This directory of non-Institutionalized mobility impaired individuals would be examined by FEMA at an exercise of off-site emergency preparedness.
i J.10.e The provisions for use of KI for emergency workers A
are discussed. The plan (see page 3.6.5, lines 10-12) and procedures (see Procedure OPIP 3.6.2, Sections 5.1.le, and 5.2.1) have been revised to specify that each emergency worker who will enter the 10-mile EPZ will be issued one (1) K1 tablet prior to being deployed to the field from the staging area to which they reported. This revision adequately overcomes j
the concern that emergency workers would need to be recalled from the field resulting in time delay in i
{
administering KI to them.
j The bottles of K1 tablets have a thirty-six (36) month shelf life. Tablets should not be issued if they are beyond their indicated expiration date.
The bottles of potassium lodide are checked every
[
three months as part of Emergency Equipment
[
Inventory, OP!P 5.3.1 (see Procedure OPIP 3.6.2, L
Section 3.1 and Procedure OPIP 5.3.1 Section 5.4.2).
.i
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. ~ _.
1 ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 42 of 66 NUREC-0654 Element Review Cosument(s)
Rating i
Page 3.6-3, lines 22-24 of the plan state that the A*
J.10.f PAG for use of KI as a thyroid blocking agent is a projected dose commitment of 10 rem to an emergency worker's thyroid. No provision is made for the general population which is consistent with i
New York State policy (see letter from J.L. Smith to Harold R. Denton, N.R.C. S.N.R. C-539 Attach-ment 1, page 4-J-10c clarification). The 10 rem i
PAG is considerably lower than the FDA Final i
Recommendation of 25 rem or greater projected thyroid dose commitment.
It would appear that LILCO has taken the more conservative lower limit of NCRP Report No. 55 (10-30 rem) or the original FDA draft recommendation (10-20 rem). Current FDA guidane (6/29/82 Federal Register) for use of KI is at 25 rem projected thyroid dose commitment; not 10 rem as provided in Puedure OPIP 3.6.2 (see, page 2 of 2).
The plan has been revised to specify that all LERO emergency workers will be taught about KI and its possible side effects during their training program.
According to LILCO's summary of the consolidated RAC review of Revision 3 (see page 3 of 3), the i
training will specify that if an allergy to lodide is suspected, the emergency worker is instructed to consult his/her physician. The plan states that if emergency workers have allergic reactions to Iodide, they will be told not to take the KI tablet issued to them at the staging area. These admini-strative measures are adequate to overcome the concern that procedures for screening emergency workers who would be given K! are included in the plan.
i l
The RAC, in its review of Revision 4 of the plan, l
recommended that consideration should be given to not using personnel who are allergic to lodide, or controlling the distribution of K! to workers at the staging areas, and withdrawing these individuals from the field if the. PAG for thyroid exposure is reached.
ATTACHMENT 1 i
LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 43 of 66
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NUREC-0654 Element Review Conunent(s)
Rating J.10.f In response to the RAC comments, LILCO stated (Cont'd) that it is company policy to direct anyone suspecting they are allergic to K! to see their physician. If they are confirmed to be allergic to KI they are reassigned to positions outside of the EPZ. In addition, the nomogram in OPIP 3.6.2 has been removed and a reference made to iodine dose projections and field measurements.
Iodine release measurements and field data (or specific plant parameters / components) will be used as the bases for determining emergency worker use of KI.
- This element.is adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details).
J.10.g The plan reflects the resources necessary for school A
or general evacuation including the number of buses to be used.
Letters of agreement with the bus companies have been finalized and are contained in a separately-bound Appendix B.
l The Notification Call-Up List will now be a computer printout.
l l
The NUREG-0654 cross-reference has been revised to include Procedures OPIP 3.6.4 and OPIP 3.6.5 as citations for element J.10.g.
J.10.h The present concept of operations regarding A
relocation centers has been to separate the reception and congregate care functions as set forth in Revision 5 of the LILCO Transition Plan.
Reception, monitoring and decontamination are to l
l ATTACHMENT 1 l
LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review l
Dated September 23,1985 Page 44 of 66 NUREC-0654 Element Review Conunent(s)
Rating J.10.h be conducted by LERO personnel at the Nassau (Cont'd)
County Veterans Memorial Coliseum.
Evacuees requesting congregate care services will be directed to facilities operated for this purpose by the American Red Cross. (See Chapter 4, Sections 4.2 and 4.8, pages 4.2-1 and 4.8-1).
J.10.1 The projected traffic capacities of evacuation A
routes under emergency conditions are shown in Appendix A, Section !!!, Table IV, pages !!!-17-33a.
The necessary studies have been completed, and adequately satisfy NUREG-0654 requirements.
J.10.)
The plan and procedures call for contacting the A*
Coast Guard and FAA and requesting cooperation of these agencies for assistance (i.e., clearance of boats from Long Island Sound, restriction of aircraft activity, e tc.).
The LERO Traffic Control Coordinator is responsible for coordinating the road logistic aspects for an evacuation and coordinating the maintenance of traffic control points for an evacuation.
The locations of approximately 138 j
traffic control posts are specified in Appendix A,Section IV, Figure 8, pages IV-52-65).
f Provisions for access control, to limit access to evacuated areas, is contained in Appendix A,
Section IV, Evacuation Procedures (see Traffic Control, page IV-5).
?
- This element is adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2, Legal Concerns for details).
h L.
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 45 of 66 NUREC-0654 i
Element Review Comument(s)
Rating J.10.k The means for dealing with potential impediments 1*
to evacuation are addresseJ in Section 3.6, page 4
3.6-6 of 'the plan, Procedure OPIP 3.6.3 and Appendix A, page IV-5. Provisions for the removal of cars by tow trucks are adequate.
The plan discusses the occurrence of adverse weather during evacuation (see Appendix A, page !!-
l l
4).
LILCO's summary of the consolidated RAC review for Revision 3 of the plan (page 8 of 13) indicated that snow removal efforts need not be coordinated with the emergency response for three reasons:
e Except in emergency scenarios having very long i
lead times, the time required in a severe snow l
storm to clear all the extensive side streets and driveways would be too long to be of meaningful assistance.
j i
{I e LERO would' be recommending a protective action of sheltering in most cases regardless of l
j the availability of snow removal services.
i e if evacuation was recommended during a mode-j rate snow fall, heavy traffic would prevent j
effective snow plow operations.
i The RAC in its review of Revision 4 of the plan, i
indicated that pre-emergency planning for snow r
I removal on the evacuation routes should be further i
developed to include administrative procedure, l
SOPS, etc. These procedures are recommended to j
ensure that the snow removal strategy would I
coincide with any evacuation scheme that might be chosen.
In response to the RAC recommendation, LILCO has i
identified the roads having the highest levels of traffic flow during an evacuation in Attachment K 4
1
ATTACHMENT 1 4
LILCO Transition Plan for Shoreham - Revision 5 i
Consolidated RAC Review Dated September 23,1985 4
h Page 46 of 66 NUREC-0654 i
Element Review Conument(s)
Rating i
J.10.k to Procedure OPIP 3.6.3.
The procedure has been (Cont'd) revised to speelfy that local snow removal organizations (i.e.,
Brookhaven and Riverhead l
Townships, Suffolk County and New York State j
Departments of Public Works) will be notified of these road clearing priorities by the Evacuation Coordinator (or designee) in the event an evacuation I
recommendation is to be implemented during, or I
i immediately following a snowfall.
i LILCO's proposed resolution is an improvement over Revision 4, but still does not meet the requirement of this element. According to the plan (see page 1.4-2b and 2.2-4g), LILCO anticipates that snow removal ageneles within 18-mile EPZ will continue i
to carry out their normal response functions.
Therefore, there is no assurance that snow removal agencies will consider and follow LILCO's road clearing priorities.
There must be reliable pre-emergency planning for snow removal on the evacuation routes including administrative iwi,cdares, SOPS, etc. as noted in the RAC review for Revision 4 **
The NUREG cross reference has been revised to i
include Procedure OPIP 3.6.3 as a citation for element J.10.k.
(
- This element is inadequately addressed in the l
plan. In addition, concerns pertaining to LERO's l
legal authority to implement the plan were Identified by the RAC during this review (see l, Legal Concerns for details).
t "It should be noted that one (1) RAC member felt that this element should be rated adequate (A).
i
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolide.ted RAC Review Dated September 23,1985 Page 47 of 66
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NUREC-0654 Element Review Conunent(s)
Rating J.10.1 The presentation of time estimates for evacuation A
of various sectors in Appendix A, Table XV, page V-8 conforms with the preferred format for presenting the data and results for the following types of l
evacuation:
Conditions Normal Adverse i
Permanent population x
x Transient population x
x General population x
x Special population x
x The table as presented is adequate.
in Revision 5 of the plan, the time for confirmation of evacuation is out!!ned on page V-9 in Appendix A.
This reference is noted on Table XV, Summary of Results of Evacuation Times Analysis, in Appendix A.
J.10.m According to page 3.1-2 and page 4.1-2, the LERO A
Director of Local Response, in conjunction with the Radiation Health Coordinator, formulate the protective action decisions.
A Nuclear Engineer has been added to the LERO emergency response staff (see comment for element 1.8, above). The Nuclear Engineer is stationed at the local EOC to evaluate plant status as part of the development of protective action recommenda-tions.
Coordinated response with the evacuation coordinater has been integrated into the decision-making process (see page 3.6-4 of the plan).
The NUREG-0654 cross-reference has been revised to include Procedure OPIP 3.6.1 as a citation for i
l element J.10.m.
1 i
_ _ _ _ - - ~.
t ATTACHMENT 1 l
LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 48 of 66
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NilREC-0654 Element Review Coseent(s)
Rating J.11 Section 3.6, page 3.6-8a of the plan states that A
control of the ingestion exposure pathway EPZ will be directed by the LERO Health Services Coordina-tor. In accordance with the draft Federal Radio-logical Emergency Response Plan (FRERP), the federal government will assist LERO in developing and implementing protective actions with respect to e
impoundment, decontamination, processing, decay, product diversion, and preservation.
Under the aegis of FRERP, USDA, DOE and HHS will assist LERO in developing and implementing the ingestion pathway protective actions.
Prosedure OPIP 3.6.6 contains ingestion pathway procedures,
- PAGs, and agricultural resource information such as listings of dairy farms, processing plants, duck growers, hog farms, vegetable and fruit growers, potato processing plants in New York and processing plants, dairy farms in Connecticut.
1 Since no portion of the State of Rhode Island is within 50 miles of SNPS, the issue of provisions for Ingestion pathway planning with Rhode Island is not a concern (see Figure 1.1.1).
t The plan is now specific in imposing ingestion pathway protective procedures for food, milk, water and livestock feed control.
This includes USDA support under FRERP.
Within New York State, the primary means of food control would be voluntary, based on radio messages (see Plan, Chapter 3, Section 3.6, page 3.6-8 and page 3.6-Sa) and telephone calls to food producers, processors and distributors indicating that LILCO will c
comps:, ate for food that is not salvagable (see Procedure OPIP 3.6.6, Sdotion 5.4.2.3 and Attach-ment 18).
l l
Revision 5 of the plan correctly names FDA and USDA as the Federal agencies to request aid regarding food interdiction (Chapter 3, Sec. 3.6, p.
l 3.6-8, line 47).
i i
.=.
l c
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 49 of 66 IlUREC-0654 Element Review Comunent(s)
Rating J.11 Maps are now referenced which include all of the (Cont'd) 50-mile ingestion pathway EPZ (see Procedure OPIP 3.6.6, page Ib of 50, page 5.1.12d; and page 4 of 50, 5.7).
The plan now includes references to tables listing dairies, farms and food processing plants.
Maps of 50-mile EPZ are housed at the local EOC (see Plan, page 3.6-8a Procedure OPIP 3.6.6, Sections 5.1.1.2, 5.1.2.3, 5.1.3, 5.4, 5.4.1, 5.7, 5.8 j
and 7.0).
J.12 The plan (see page 4.2-4) and Procedures (see OPIP I
3.9.2, Section 5.3.1) have been revised to specify that evacuee monitoring and decontamination equipment will be stored at the three primary relocation centers at BOCES, Islip; St. Joseph's College, Patchogue; and SUNY, Farmingdale.
l The plan describes how the maximum number of f
evacuees would be monitored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (see Chapter 3, Section 3.9, B).
l In Revision 5 of the plan, LILCO states that in order to monitor the maximum number of evacuees that might be expected to arrive at the Reception j
Center in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a minimum of 70 monitors will be necessary assuming it takes 1 1/2 minutes to monitor each evacuee.
LERO has additional monitors available to monitor vehicles and decon-taminated evacuees.
If these personnel are not needed for vehicle or decontamination monitoring, they will be directed to assist in the initial monitoring of arriving evacuees.
In Procedure, OPIP 3.9.2, Attachment 3, page 3 of 4, a flow diagram indleates vehicle interiors will be monitored if the exterior is contaminated; however, no action levels nor prescribed actions are indicated if the interior is contaminated. In addition, in the plan on page 4.2-1 and in procedures OPIP 4.2.3 and 3.9.2, there are statements which say that vehicle i
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ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 50 of 66 NUREC-0654 Element Review Comment (s)
Rating J.12 monitoring will only be performed if a particulate (Cont'd) release is suspected or has occurred. This restrie-tion is not correct.
While a particulate release would result in a potentially more serious dose situation, surface contamination can be caused by I
noble gas daughters and or radiolodine. 'the plan should be revised to address both concerns.
Procedure OPIP 3.C.2 has been revised to avoid the possibility of a contaminated person entering the a
relocation center. " Clean" and " contaminated" tags have been added to Procedure OPIP 3.9.2 (see Attachments 5 and 6) to ensure that.potentially i
contaminated persons will be kept separate from monitored individuals who have been admitted to the relocation center for mass care. Individuals found to be clean following monitoring and decon-tamination will be issued a " clean" tac and be required to sign out before being directed to the mass care facilities operated by the American Red Cross at the Relocation Centers.
The American Red Cross is responsible for opening and operating the predesignated relocation centers l
(Chapter 2, Section 2.2, page 2.2-2), and they will supply the registration forms.
Is a copy of the Amerlean Red Cross ARC 3050 available for exam-I Ination by the RAC?
The RAC in its review of Revision 4 of the plan l
recommended that a sample evacuee registration form be provided in the plan. A!! fndividuals who have been monitored, whether
" clean" or
" contaminated" need to have the monitoring survey documented as a legal precaution.
The logs (Attachment 8) are incomplete in that they do not provide for time /date of survey, the identification of the monitor, and the survey results (i.e.,
maximum count rate) to be included on the evacues registration form (see Procedure OPIP 3.9.2, Section 5.1.2 and 5.4.1).
.-._=.- - - - -,, - _ - -,, -. _ - - -, - _ -. - - -. -.. - -
AT1'ACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 51 of 66 NUREC-0654 I
Element Review Conunent(s)
Ratina l
l J.12 There were no modifications made to Revision 5 of (Cont'd) the plan to address this concern. LILCO provided the following explanation:
"It is LERO's policy to provide a detailed monitoring report, Plan Attachment 3.9.! for any individual found to have contamination in e; cess of acceptable levels. The " clean" log out forms are only useful for keeping a record of who was monitored. Since all the monitoring is going to be accomplished in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> it is not necessary to know the time and date. In addition, to have the monitors fill out a I
detailed form for each clean evacuee is unnecessarily time consuming."
3 Although the LERO criteria for decontamination and " clean" log provisions may satisfy LELCO's internal proceduras, a more complete form would be useful in the event anyone questions the survey l
results.
- Also, procedures for completing registration forms for uncontaminated individuals and maintenance of evacuee monitoring records should be specified in the plan.
Procedure OPlP 3.9.2 has been revised regarding non-contaminated persons (Section 5.9), and the storage of monitoring records (Section 5.1.7).
All completed monitoring and decontamination forms will be collected at the relocation centers by the Decontamination Leader and delivered to the EOC for permanent stomnc.
The NURENF1 e ss-reference has been revised
' to include r,sa't-. r 4.2.1 as a citation for element a
J.12.
f f
5 i
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ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 52 of 66 NUREC-0654 Element Review Conunent(s)
Rating K.
Radiological Exposure Control K.3.a Page 3.9-2' of the plan states that all emergency A
response personnel will be issued self-reading pocket dosimeters and TLDs. The LERO Dosimetry Coordinator is responsible for maintaining exposure control records on a 24-hour per day basis.
Ths plan has been revised to clarify that the dosimeters will be zeroed at the staging areas, and that the chargers will not be taken into the field (Chapter 3, Section 3.9, page 3.9-2, lines 6-12).
In Revision 5 of the plan, Procedure OPIP 3.9.1, was modified to indicate dosimeters must be zeroed and then distributed.
However, Procedure OPIP 2.1.1, p.14 of 79, Record Keepers, paragraph C, still refers to the Record Keeper calibrating and distributing dostmeters. In addition, the plan now correctly states that emergency workers are directed to notify super-visors at 3.5R and to leave posts at 5R if a higher exposure is not authorized. Also, Procedure OPIP 3.6.3,4,5 and 3.9.1 was not received.
K.3.b Page 3.9-2 of the plan states that emergency A
workers inside affected areas are instructed to take dosimeter readings at 15-minute intervals.
Emergency Worker Daily Dose and Permanent Dose Record forms are contained in Section 3.9 and also in Procedure OPIP 3.9.1. Section 3.9.A page 3.9-3 of the plan states that emergency worker dose records will be maintained at the local EOC.
K.4 The LILCO Transition Plan (Revision 4) provides for A
emergency workers to be trained to inform their immediate supervisor if the reading on their low range dosimeter goes beyond the 200 mR that it will i
l
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 53 of 66 NUREC-0654 Element Review Comunent(s)
Rating K.4 register. Pages 3.9-2 and 3 of the plan state that A
(Cont'd) the Director of Local Response, as advised by the Radiation ' Health Coordinator, is responsible for authorizing exposures in excess of the EPA General Public PAGs.
In response to the RAC comments on Revision 4 of the plan, the exposure guideline for hands and forearms of 200 R for lifesaving activities has been removed from Revision 5 of the plan (see Chapter 3, Sec. 3.9, p. 3.9-3).
K.5.a Tables 3.9.1 and 3.9.2 specify action levels for A
determining the need for decontamination.
The plan has been revised to use CPM for all" probe shield open" readings (see Table 3.9.1).
Action levels for determining the need for decontaminating individuals and property were adequately specified.
Procedure OPIP 3.9.2 and Table 3.9.1 are now consistent.
Reference to Regulation Guide 1.86 has been removed, and Table 3.9.2 has been deleted from the i
plan. Re-entry decisions are appropriately based on l
l l
K.S.b Page 3.9-4, line 39 and page 4.3-2, line 5 of the plan A
l and Procedure OPIP 3.9.2 (Section 5.8.1-C) state j
that any emergency worker with thyroid contamina-tion resulting in readings in excess of.13 mR or 150 i
CPM, will be sent to a designated hospital for fur-ther medical treatment. The plan consistently uses 0.13 mR or 150 CPM as the thyroid contamination
[
level.
The statement that alpha radiation will be measured has been appropriately deleted from the procedures (see Procedure OPIP 3.9.2, Section 5.5, 5.5.2,a).
l 1
4 t
1 ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 i.
)
Page 54 of 66 NUREG-0654 i
Element Review Comment (s)
Rating i
K.5.b Procedure OPIP 3.9.2 has been rnised to include (Cont'd) procedures for dealing with contaminated solid and liquid waste. (Section 5.0, 5.1.7 - 5.1.9).
Reception Center Activation and Operation l
Procedure should include reference 2,Section I
5.2.1.3 of 091P 3.5.2 with regard to disposal of liquid contaminated waste.
The decontamination equipment list is contained in d
i Procedure OPIP 5.3.1 and in the plan (see Chapter I
4, Section 4.2, D, pages 4.2-3 and 4.2-4).
First-aid kits have been placed at the Emergency I
Worker Decontamination Facility (EOC) and at the primary Relocation Centers (Chapter 4, Section 4.3, i
l A, page 4.3-1, lines 18-22 and page 4.4-3, lines 18-l 20.
J l
L.
Medical and Public Health Support L.1 Provisions are adequately described for hospital and A
medical services with the capability for handling j
contaminated or exposed persons. Central Suffolk l
Hospital is designated as the primary support i
hospital for the treatment of contaminated LERO I
emergency workers (see page 2.2-2a). According to l
Section 3.7, contaminated injured members of the public can be treated by accredited hospitals on l
Long Island that can treat radiologically contami-i nated individuals. These hospitals (of which Central Suffolk is one) are listed in Procedure OPIP 4.2.2.
The agreement with Central Suffolk Hospital (see l
Appendix B, App-B-75A) tc " treat injured or injured l
and radiologically contaminated individuals from the Shoreham Station" and the list of regional I
medical service facilities capable of treating l
emergency workers and/or the general pub!!c are I
adequate to satisfy this planning element.
l
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 55 of 66 NUREC-0654 Element Review Comment (s)
Rating L.3 The agreement with Central Suffolk Hospital and A
the list of regional medical service facilities capable of treating radiologically contaminated individuals are adequate to satisfy this planning element.
A new list of hospitals capable of treating contaminated / injured individuals, with the number of beds available, has been incorporated in Procedure OPIP 4.2.2, Attachment 1, pages 1-7).
The plan has been revised to include in Section 3.7, reference to the list of hospitals capable of treating contaminated / Injured individuals contained in Procedure OPIP 4.2.2, Attachment 1.
L.4 Page 3.7-1 of the plan states that the LERO A
I Ambulance Coordinator will coordinate the services of trained emergency medical technicians, ambulances and rescue vehicles.
The list of ambulance companies with which LERO i
has agreement to supply resources are contained in Procedure OPIP 4.2.2 (see Attachment 2).
The NUREG-0654 cross-reference has been revised to include Procedure OPIP 4.2.2 as a citation for element L.4.
M.
Recovery and Reentry Planning and Postaccident Operations M.1 Section 3.10, pages 3.10-1 and 2 and Section 3.11, A
pages 3.11-1 and 2 of the plan and Procedure OPIP 3.10.1 discuss Re-entry and Recovery. Procedure OPIP 3.10.1 provides for participation of the I
I J
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 56 of 66 NUREC-0654 Etement Review Coannent(s)
Rating M.1 following agencies / organizations on the Recovery (Cont'd)
Action Committee if they are available:
e FEMA representative DOE representative e
EPA representative o
State representative e
County representative e
General plans for recovery and reentry have been developed which take into account the engineering evaluation of plant conditions as well as radiological conditions (see comments for elements I.8, J.10.m.
and 0.4.b). The plan has been revised to include a Nuclear Engineer who will review plant conditions (see Procedure OPIP 3.10.1, Section 5.0, 5.11, g).
This individual is assigned as a member of the Recovery Action Committee and is responsible for emergency status evaluation of the plant.
Reference to Reg. Guide 1.86 has been removed from the plan as it is not related to recovery from an emergency at SNPS.
The plan has been revised to delete evacuation as a prerequisite for recovery '(see Procedure OPIP 3.10.1, Section 4.1).
In Revision 5 of the plan, Procedure OPIP 3.10.1, Sections 5.4.4 and 5.4.5 have been revised to consider procedures of recovery when sheltering may have been recommended.
EPA is listed as the agency responsible for post-emergency phase activities (see plan, Chapter 3, Section 3.11, page 3.11-1, lines 34-39; also, Procedure OPIP 3.10.1, Section 5.3, 5.3.8).
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 57 of 66 NUREC-0654 Element Review Comment (s)
Rating The LERO Director of Local Response is responsible A
M.3 for instructing all Recovery Action Committee coordinators to notify members of the response organization when recovery operations have been initiated (see Procedure OPIP 3.10.1, Sections 5.3.4 and 5.3.6).
M.4 The referenced section of the plan provides for the A
completion of radiation field surveys to determine whether contamination levels in an evacuated area are within acceptable limits for reentry of the public into formerly contaminated areas.
The plan has been revised to include a procedure for calculation of total population dose, and is referenced in Chapter 3, Section 3.10, b, e, page 3.10-2. The RAC in its review of Revision 4 of the plan, however, recommended that the dose reduc-tion factors for sheltering should be reevaluated, since the bulk of the available data indicates that for most buildings the benefit of sheltering decreases after two hours due to intrusion of outside air.
LILCO has not modified Revision 5 of the plan to address this issue.
However, LILCO responded to the RAC comments with the following clarification:
"The thyroid dose reduction factors identified in OPIP 3.10.2, Attachment 3 are time dependent because of infiltration of air into the building. The whole body dose reduction factor is not time dependent because the exposure is an integrated function over the entire cross section of the plume, and of this cross section the portion that is within the building is a very small part.
Thus the wholebody dose reduction factor is not in effect a function of air infiltration.
(See EPA 520/1 l 001A, the Effectiveness of Sheltering as a
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 1
Page 58 of 66 NUREC-0654 Element Review Comment (s)
Ratina M.4 Protective Action Against Nuclear Accidents (Cont'd)
Involving Gaseous Releases, pg 19, April 1978)."
The RAC has evaluated LILCO's response and found it acceptable.
N.
Exercises and Drills N.1.a The referenced,section of the pisn describes the A*
purpose, scope, frequency and procedures for exercises. The plan states that an exercise shall simulate an emergency that results in offsite radiological releases which would require the overall emergency response capabilities of SNPS, and LERO.
Revision 5 of the plan has been revised to add Accident Assessment and Evaluation, and Emergency Response Facilities to the list of capabilities to be tested in exercises (Plan, Chapter 5, Sec. 5.2, page 5.2-7, lines 13 and 14).
FEMA has been deleted from line 15 on page 5.2-3 since FEMA does not test its response capability in every exercise.
- This element is adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were identif!ed by the RAC during this review (see Attachment 2, Legal Concerns for details).
N.1.b The plan contains no provision for the mobilization A*
of State and local personnel and resources in order to verify responses during exercises. However, the
~_ _ _. - _ _
ATTACHMENT 1 j
LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 59 of 66
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NUREC-0654 Element Review Comunent(s)
Rating N.1.b plan does establish the means for mobilizing LERO (Cont'd) personnel and resources that would be adequate to verify the' capability to respond to an accident scenario requiring response.
- This element is adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were identified by the RAC during this review (see Attachment 2.
Legal Concerns for details).
N.2.a The plan adequately addresses the testing of A
communication systems with the following:
e Federal emergency response organizations and states within the ingestion pathway - quarterly, e The nuclear facility (SNPS) - annually, e The State and local (LERO) EOCs - annually, and e Local (LERO) radiological monitoring team -
annually.
The plan provides for drills of communication with i
the State and local EOCs.
The NUREG-0654 cross-reference has been revised to include Procedure OPIP 3.4.1 as a citation for element N.2.a.
N.2.e Page 5.2-2a of the plan and Procedure OPIP 5.1.1, A
Section 5.2.2.lc adequately provide for a Medical Drill to be conducted annually in conjunction with the annual exercise.
-r
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ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 60 of 66 NUREC-0654 Element Review Comunent(s)
Rating N.2.d The referenced section of the plan provides for A
radiological monitoring drills.
The plan has been revised to state that the DOE-RAP Team will participate annually in a practice exercise and in the FEMA /NRC observed exercise.
This will be in addition to their separate drill and exercise program associated with Brookhaven National Laboratory (see Chapter 5, Section 5.2, b, page 5.2-3, lines 19-23).
N.2.e.(1)
Page 5.2-2a of the plan and Procedure OPIP 5.1.1, A
Section 5.2.2.1.d. adequately provide for health physics drills to be conducted semi-annually.
N.3.a-f The referenced section of the plan adequately A
provides for exercise scenarios to include the following:
e The basle objectives; e The date(s),
time
- period, place (s) and participating organizations; e The simulated events; e A time schedule for real and simulated initiating events; e A narrative summary describing the conduct of exercises or drills; e Arrangements for scenario material to be provided to official observers.
Revision 5 of the plan includes provisions for protective clothing (Chapter 5, Sec. 5.2, page 5.2-2,
!!ne 13).
Also, LILCO states that protective clothing is used by LERO emergency workers in the fleid.
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 61 of 66
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NUREC-0654 Etement Review Comment (s)
Rating N.4 Section 5.2, pages 5.2-1 and 5.2-4, lines 4-6,14 and A
15 of the plan establishes that the LILCO Emergency Planning Coordinator (EPC) is responsible for conducting exercises that will be critiqued by observers from Federal, State and local governments.
N.5 Procedure OPIP 5.1.1, Sections 5.2.6 and 5.2.7 A
adequately provide for LERO to evaluate observer and participant comments and implement corrective actions. The LILCO Emergency Planning Coordina-tor is responsible for incorporating plan changes indicated as a result of the drills and annual exercise critiques.
Revision 5 of the plan, Procedure OPIP 5.1.1 has been revised to indicate that the comments from Federal observers will be available at a post-exercise critique and in the post-exercise assess-ment which summarizes the evaluation of the Federal Observers.
O.
Radiological Emergency Response Training O.1 Section 5.1, pages 5.1-3 through 5.1-5 of the plan A
and the LERO Training Matrix (Figure 5.1.1) provide emergency response training for LERO personnel through a training program consisting of 21 modules. Radiological emergency response training i
is included.
Also, tapping the Federal sector, LILCO would avail itself of approximately 12 i
courses, some given by FEMA, some by NRC, and some by EPA. The Red Cross would also be util-ized, providing six training courses.
l Procedure OPIP 5.1.1, Section 5.1.5 provides that i
the records maintained by LILCO will show the l
names and emergency position of individuals trained, the instructor's name, and the dates on which they received training.
LA
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 62 of 66 NUREC-0654 Element Review Comunent(s)
Rating 0.1.b Procedure OPIP 5.1.1, Section 5.1.3 states that A
Emergency Response Training will be offered to all members of LERO support organizations, such as the U.S. Coast Guard and ambulance personnel.
The plan has been revised to specify that LILCO will offer training in dosimetry and radiation fundamentals to alllocallaw enforcement agencies, snow removal authorities, and fire and rescue departments within the 10-mile EPZ which are expected to carry out their normal functions during a radiological emergency at SNPS (see also comment for element A.1.b, above).
O.4 The referenced section of the plan establishes a A
training program for emergency response personnel which is keyed to specific emergency response training topics. The following subelements of this planning criteria have been reviewed as follows:
0.4.a Training will be provided to directors or coordinators who are LILCO employees.
Revision 5 of the plan now includes a description of Training Module 15.
0.4.b Training is provided for accident assessment A
personnel, both engineering and radiological health. The plan has been revised to specify that personnel designated to fill the positions of Radiation Health Coordinator and Nuclear Engineer are required to be technically quallfled in their fleids of responsibility and will receive training in LERO procedures. Both positions listed on the LERO Training Matrix (see Figure 5.2.1, also see Plan, Chapter 5, Section 5.1, page 5.1-7, lines 2-8).
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolldated RAC Review Dated September 23,1985 Page 63 of 66 NUREC-0654 Element Review Cosament(s)
Rating 0.4 O.4.c Radiological monitoring teams and A
(Cont'd) radiological analysis personnel.
O.4.d Police, security, and fire fighting personnel; A
see comment for element O.1.b, above.
O.4.f First aid and rescue personnel A
O.4.g Local support services personnel A
O.4.h Medical support personnel A
O.4.)
Personnel responsible for transmission of A
emergency information and instructions.
O.5 Chapter 5, Section 5.1 of the plan, Training, states A
that LILCO will provide for periodic retraining on at least an annual basis for personnel with emergency response responsibilities.
P.
Responsibility for the Planning Effort P.1 The referenced section of the plan and imple-A*
menting procedures provide for the training of LERO personnel who are responsible for the planning effort.
P.2 The LILCO Emergency Planning Coordinator (EPC)
A*
is responsible for the administration of the LILCO Transition Plan (all revisions).
P.3 The LILCO EPC is responsible for conducting an A*
annual review and update of the LILCO Transition Plan including procedures and letters of agreement.
)
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ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 64 of 66 NUREG-0654 Element Review Comment (s)
Rating The LILCO Emergency Planning Coordinator is A*
P.4 responsible for incorporating plan and procedure changes resulting from exercises and assigning the responsibility for implementing corrective actions.
With the exception of the American Red Cross and the relocation
- centers, various agreements necessary to implement the LILCO Transition Plan are included in the plan and will be updated annually or upon revision of the plan (see LILCO Summary of e
Responses to the Consolidated RAC Review for Revision 3, (page 3 of 3). The RAC, in its review of Revision 5 of the plan, Indicated that at least one letter of agreement (i.e., with Teledyne Isotopes) has expired and needs to be updated (see Appendix B, page APP-B-74).
LILCO made no modifications to Revision 5 of the plan.
However, LILCO responded to the RAC comments as follows:
i "SNPS maintains up-to-date contracts with the laboratories doing isotopic analysis. The contract shown in the letter of agreement is only a sample to indicate the type of service required by SNPS Technical Specifications."
FEMA needs copies of all up-to-date contracts and agreements.
'These elements are adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were identitled by the RAC during this review (see, Legal Concerns for detalls).
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 65 of 66 WUREC-0654 Element Review Conument(s)
Rating P.5 The LILCO EPC is responsible for distributing the A*
LILCO Transition Plan and approved changes to the organizations and appropriate individuals respon-sible for their implementation.
In Revision 5 of the plan, dates of all revisions have, been added to the List of Effective Pages of all documents. They are as follows:
Rev.0 5/26/83 Rev.1 7/28/83 Rev.2 11/7/83 Rev.3 12/22/83 Rev.4 8/29/84 Rev.5 8/02/85
- This element is adequately addressed in the plan.
However, concerns pertaining to LERO's legal authority to implement the plan were Identifled by the RAC during this review (see Attachment 2, Legal Concerns for details).
P.6 Section 1.4, pages 1.4-1 and 1.4-2, and Attachment A
1.4.2, contain the required list of supporting documents.
e P.7 Appendix C to the plan lists by title, the procedure A
required to implement the plan.
The Revision 5 plan has been revised to include a reference to Procedure OPIP 1.1.1, Offsite Pre-paredness Implementing Procedure Development (see Plan, Chapter 1, Sec.1.1, lines 11-13).
1 i
9
ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review Dated September 23,1985 Page 66 of 66 NUREC-0654 Element Review Comument(s)
Rating P.8 The plan contains a specific Table of Contents, and A
is cross-referenced to NUREG-0654 criteria.
The NUREG-0454 cross-reference has been revised l
as requested by the RAC review for Revision 3 of the plan.
I The NUREG-0654 cross-reference has been revised in Revision 5 of the plan to include element C.2.a.
f P.10 Section 5.4, page 5.4-2 of the plan states that the A
telephone number lists will be updated on a quarterly basis, and more frequently, if necessary.
Also, Procedure OPIP 5.4-1. Section 5.4.4 calls for telephone numbers in emergency procedures to be i
updated quarterly.
1 i
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l
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t
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ATTACHMENT 2 1
CONCERN 8 PERTAINING TO LERO'S LEGAL AUTHORITY IDENTIFIED DURING RAC RRVIEW OF LILCO TRANSITION PLAN FOR SHOREHAM REVISIONS 3,4, AND 5 February 10, 1984; October 12,1984; and September 23,1985 1
i Below are the legal concerns identifleJ during the RAC review of the LILCO Transition Plan for Shoreham - Revisions 3, 4, and 5.
For easy reference, each NUREG-0454 element affected by the legal concern (s) is restated, followed by the RAC comments.
A.1.a Each plan shall identify the State, local, Federal and private sector organizations (including utilities), that are Intended to be part of the overall resoonse organisation for Emergency Planning Zones (see Appendix 5).
1 i
With neither State nor local support or participation in the emergency planning process, the following legal authority concerns l
have been Identified:
l l
e command and control responsibilities I
e coordination with local and State authorities including law j
enforcement agencies, fire departments, and snow removal agencies t
i e coordination with contiguous State and local governments j
e LERO's ability to seek a declaration of a state of emergency and to request State and Federal assistance.
e arrangements for agreements with emergency response j
organizations and/or Individuals i
1 e responsibility for alerting and notification of the public.
A. I.d Each organization shall identify a speelfic individual by title who shall be in j
charge of the emergency response.
The plan assigns responsibility for " protecting the health and safety of residents and transients within the Emergency Planning Zones (EPZs) defined in this plan" (see page 2.1-1, lines 37-41), to the LERO Director of Local Response. At this time, the LERO Director of Local Response has the responsibility for " decision making and I
strategic controls," and responsibility to " decide upon the major 1
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lt _ _ _._-_ _ _ _ _ _ _ --
~ _ _ _ _ _ - - - - - _ - - _,.-
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ATTACHMENT 2 2
responses to be made" (see page 3.1-1, lines 15-17). The concern is whether or not LERO has the authority to implement decisions that are made.
Each organization shall specify the functions and responsibilities for major A.S.a elements and key individuals by title, of emergency response, including the i
following:
command and control, alerting and notification, communications, publie,information, accident assessment, public health, and sanitation, social services, fire and rescue, traffic control, emergency medical services, law 1
enforcement, transportation, protective response (including authority to request Federal assistance and to initiate other protective actions), and radiological exposure control. The description of these functions shall include a clear and concise summary such as a table of primary and support responsibilities using the agency as one axis, and the function as the other (see section B for licensee).
The lack of participation by New York State and Suffolk County governments in radiological emergency planning for Shoreham,
+
distinguishes the LILCO Transition Plan as a private plan rather than a government plan. NUREG-0654 requires that the responsibility for Fire, Rescue, and Law Enforcement should be specified in the plan.
The discussion on page 1.4-2b (Rev. 4) states that LILCO expects that Suffolk County personnel will continue to perform their normal functions (police action, fire safety, and snow removal) in accordance with referenced sections of the Suffolk County Charter. This is also stated on page 2.2-4g of the plan. The utility's expectation remains a concern for the following reasons:
The county and State have refused to take part in the pre-e emergency planning programs, and i
A radiological emergency is not a normal condition and no e
assumption can be made as to how an organization will respond without preparatory planning.
l See also comments for A.I.a.
A.2.b Each plan shall contain (by reference to specific acts, codes or statutes) the legal I
basis for such authorities.
l.4.1 in the Plan refers to legal authority under 10 CFR 50.47 (c)(1).
l The utility has developed LERO, comprised of utility, Federal and private individuals.
If New York State and Suffolk County implement an emergency plan, LERO would follow their lead (see Section 1.4, pages 1.4-1,1.4.23 also, attachments 1.4.1 and 1.4.2).
O O
ATTACHMENT 2 3
The authority of LERO to implement this plan under NRC codes and regulations and new York State Executive Law, as well as the issue of LERO's police power authority, has not been resolved.
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. These agreements may be provided in an appendix to the plan or the plan itself may contain descriptions of these l
matters and a signature page in the plan may serve to verify the agreements.
The signature page format is appropriate for organizations where response functions are cover'ed by laws, regulations or executive orders where separate written agreements are not necessary.
During the RAC review, the following legal concerns were identified:
LERO's authority to enter into agreements and/or contracts with e
emergency response organizations identified in the plan.
The plan acknowledges county responsibility for snow removal, e
fire safety and police actions (see the Suffolk County Charter, referenced Page 1.4-2b of the plan). Since the county and State have declined to participate in radiological emergency planning for Shoreham, their normal response during an emergency remains a concern.
e it is unclear whether the Nassau County Executive has the authority to issue a letter of agreement without the approval of the Nassau County Board of Supervisors.
l C.1 The Federal government maintains in-depth capability to assist licensees, States and local governments through the Federal Radiological Monitoring and Assessment Plan (formerly Radiological Assistance Plan (RAP) and Interagency Radiological Assistance Plan (IRAP).
Each State and licensee shall make provisions for incorporating the Federal response capability into its operation plan, including the following.
C.1.a Specific persons by title authorized to request federal assistance, see A.1.d, A.2.a.
The plan provides for the LERO Director of Local Response to " Request the Governor to ask the President to declare an Emergency or Disaster".
The legal basis for this procedure has not been identified in the plan.
l
ATTACHMENT 2 4
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.
For comments - see A.3.
L5 State,and local government organizations shall establish a system for disseminating to the public appropriate information contained in initial and follow-up messages received from the licensee including the appropriate notification to appropriate broadcast media, e.g., the Emeriency Broadcast System (EBS).
LERO has established a network of Long Island radio stations for disseminating emergency information to the public.
LERO's authority to disseminate emergency information to the public without the involvement of State and/or local government officials remains a concern.
j LS Each organization shall establish administrative and physical means, and the time 1
required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone (see Appendix 3). It shall be the licensee's responsibility to demonstrate that such means exist, regardless of who implements this requirement. It shall be the responsibility of the State and local governments to activate such a system.
l The official EBS systens authorized by the Federal Communication Commission (FCC) is used by government officials to disseminate emergency information to the public.
LERO's legal authority to activate the alert and notification system without State and/or local government participation remains a concern.
F.3 Each organization shall conduct periodic testing of the entire emergency communications system (see evaluation criteria H.10, N.2.a. and Appendix 3).
No statement that State and local governments will participate in communication drills with LERO could be located in the plan.
G.3.a Each principal organization shall designate the points of contact and physical locations for use by news media during an emergency.
The plan does not specify the level of involvement in the development and/or review of EBS and news releases.
For comments - see E.5.
l
e ATTACHMINT 2 5
Each organization shall provide for timely activation and staffing of the 1
H.4 facilities and centers described in the plan.
Without a State Site Speelfic Plan for the SNPS, there are no
. procedures speelfled for the activation and staffing of the State EOC in the event of a radiological emergency at the Shoreham site. Therefore, provision for the notification and mobilization of personnel to coordinate the State's interface with the LERO response remains a concern.
The organization's plans to implement protective measures for the plume J.10 exposure pathway shall includes Maps showing evacuation routes, evacuation areas, preselected a.
radiological sampling and monitoring points, relocation centers in host areas, and shelter areas; (identification of radiological sampling and monitoring points shall include the designators in Table J-1 or an
)
equivalent uniform system described in the plan);
The Evacuation Plan (Appendix A Section ! - Preface pages I-1 to 1-2) is made up of two plans - a study performed by Suffolk County as part of an agreement with LILCO (9/21/81), a study 4
performed by KLD Associates under an agreement with LILCO to develop an evacuation plan (12/30/81).
LILCO has Integrated the two studies into Appendix A.
Since Suffolk County is not participating in the offsite emergency planning processes, a concern remains as to whether the data developed by Suffolk County under contractural agreement on emergency response planning executed in 1981, are still applicable.
Means for notifying all segments of the transient and resident l
e.
population; As noted in analysis comments E.5 and E.6, LERO's legal authority to activate the alert and notification system and to disseminate emergency information to the public without the l
involvement of the State and/or local government remains a concern.
f.
State and local organizations' plans should include the method by 1
which decisions by the State Health Department for administering radioprotective drugs to the general population are made during an emergency and the predetermined conditions under which such drugs may be used by offsite emergency workers; l
ATTACHMENT 2 6
The authority of the Health Services Coordinator to authorize the use of K! for other LERO emergency workers who are not LILCO employees is of concern, since the State Health Department would not be involved in the decision-making regarding the use of KI by emergency workers.
J.
Control of access to evacuated areas and organization responsibilities for such control; Since the staff assigned to Traffic Control are LILCO employees, the ability to accomplish this effort under the authority of 10 CFR 50.47 remains a concern.
Assigning access control duties to LILCO employees includes:
e setting-up and controlling roadblocks e dealing with evacuation, etc., remains a concern k.
Ider.tification of and means for dealing with potential impediments (e.g., seasonal impassability of roads) to use of evacuation routes, and contingency measures; According to pages 1.4-2b and 2.2-4 of the plan, it is -
anticipated that snow removal will be provided by local organizations in their normal fashion during an emergency.
LERO's coordination with local agencies responsible for snow removal needs to be addaessed to ensure that snow removal is in accordance with the evacuation scheme in case of a radiological emergency.
In addition, LERO's authority to remove impediments to evacuation remains a concern.
N.I.a An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and organization 3.
The emergency preparedness exercise shall simulate an emergency that results in offsite radiological releases which would require response by offsite authorities. Exercises shall be conducted as set forth in NRC and FEMA rules.
Since New York State and Suffolk County are not participating in the planning process, the testing of Integrated capability of the offsite authority (s) remains a concern.
ATTACHMENT 2 7
N.1.b An exercise shall include mobilization of State and local personnel and resources adequate to verify the capability to respond to an accident scenario requiring response. The organization shall provide a critique of the annual esereise by Federal and State observers / evaluators. The scenario should be
,earried from year to year such that all major elements of the plans and gei;e.edness oITanizations are tested within a five-year period.
Each organisation should make provisions to start an exercise between 4:00 p.m. and midnight, and another between midnight and 6:00 a.m. once every six years.
Exercises should be conducted under various weather conditions.
Some
)
exercises should be unannounced.
ilnee New York State and Suffolk County are not participating in the planning process, mobilization of their personnel and resources during an exercise remains a concern.
P.1 Each organization shall provide for the training of individuals responsible for the planning effort.
P.2 Each organization shall identify by title the individual with the overall authority and responsibility for radiological emergency response planning.
F.3 Each organization shall designate an Emergency Planning Coordinator with responsibility for the development and updating of emergency plans and coordination of these plans with'other response organizations.
P.4 Each organization shall update its plan and agreements as needed, review and certify it to be current on an annual basis. The update shall take into account changes identified by drills and exercises.
P.5 The emergency response plans and approved changes to the plans shall be forwarded to all organizations and appropriate individuals with responsibility for implementation of the plans. Revised pages shall be dated and marked to show where changes have been made.
NUREG-0654 mandates an integrated approach to the development of offsite radiological emergency plans by States, localities, and licensees.
Since New York State and Suffolk County are not participating in the development, updating of and training for a radiologleal emergency plan for Shoreham, the lack of an Integrated approach to offsite radiological emergency preparedness remains a concern.
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