ML20153E009
| ML20153E009 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/12/1986 |
| From: | Speck S Federal Emergency Management Agency |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8602240340 | |
| Download: ML20153E009 (4) | |
Text
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- Qg%hp[ Federal Emergency Manage Ro' t Agency ~
e Washington, D.C. 20472 ek Denton E I2 E GCunninoham Murley Mr. Victor Stello, Jr.
Acting Executive Director for Operations U.S. Nuclear Regulatory Canmission Washington, D.C.
20555
Dear Mr. Stello:
On January 16, 1986, the Nuclear Regulatory Commission (NRC) requested the Federal Onargency Management Agency (FEMA) to conduct a review of Revision 6 of the Iong Island Lighting Conpany's (LILCO) Transition Plan for the Shoreham Nuclear Power Station (SNPS) and to provide the NRC with its findings. his request was made in accordance with the NRC/ FEMA Memorandum of Understanding (MOU) dated November 1980.
Due to the limited nature of the changes, the review was conducted by FENA Region II staff.
A review of Revision 6 has been completed and the results are contained in the enclosed report entitled "LIIf0 Transition Plan for Shoreham -
Revision 6, FENA Review", dated February 7, 1986. W e Plan was reviewed 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. With the exception of plan aspects relating to NUREI3 elenent 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 firds that Revision 6 is a further improvement over Revision 5.
Six inadequacies were identified in the RAC's review of Revision 5; five elenents are rated inadequate in Revision 6. We deficiencies are explained in the FEMA review. H e NUREG evaluation criteria for the 5 inadequate elenents are as follows.
(An asterisk indicates there is also a concern pertaining to legal authority which surfaced in the review.
In sone of the inadequacies, the legal issues are the major concerns.)
(1)
A.2.b.*
Each plan shall contain (by reference to specific acts, codes or statutes) the legal basis for such authorities (i.e., the authorities mentioned in NUREG-0654 element A.2.a.).
(2)
A.3.*
Each plan shall include written agreenents referring to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role within the Dnergency Planning Zones. De v)rJements shall identify the emergency measures to be provided and the mutually acceptable criteria for their implementation, and specify the arrangenents for exchange of information.
8602240340 860212
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. (3)
C.4.*
Each orgenization shall identify nuclear and other facilities, organizations, or individuals which _can be relied upon in an emergency to provide assistance. Such assistance shall be identified and supported by appropriate letters of agreement.
(4)
J.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.
(5)
J.12. Each organization shall describe the means for registering and monitoring of evacuees a't relocation centers in host areas.
The personnel and equipment available should be capable of monitoring within about a 12-hour period all residents and transients in the plume exposure EPZ arriving at relocation centers.
Of the above, all were identified as inadequate in the RAC's review of Revision 5.
I hope the enclosed finding is helpful in your analysis of emergency preparedness issues concernin) Shoreham.
If you have any questions, please don't hesitate to call me.
Sincerely, e
I Y
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(amuelW. Speck Associate Director State and Local Programs and Support Enclosures s
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~ REB.06 '06 16:49 fem REGIm gy g P.03 LhC0 Transition Plan for Shoreham - Revision 6 FEMA Review Dated February 7, 1986 h JREG-065e jlement Revisw Coment(s)
Rattna A.2.D This element remains inadequate, ho material in l'
Revision 6 address tnis element. All comer.ts in the RAC review of Revision 5 are still in effect.
A.3 This element remains inadequate. *All comments in 1*
tne RAC review of Revision 5 see still in effect.
In addition, this revision reovires the socition of a letter of agreement with the owners of the Brookhaven N1tiplex Cinema for use of their property (parking lot) as a~ transfer Doint. Tha revisso page B vii shows tnis letter to es on pere 5 66 however.
page 5 68 is the letter of ag easent witn the previous transfer point property owner.
C.a Tnts elenent remains inadequate. See the review 1*
comments under A.3.
J.9 This element is now rateo adequate. Revisions to A of procedure CPIP 3.6.5 reflect the current FDA response level tables including all footnotes which are necessary for proper use of the numeric data contained in the tables.
J 10.g This element remains adequate. Thedesignationei' A
of replacemert transfer point requires numereut changes to specify tnis new location. The slan changes are a11 involved with the legistice of the movements of buses for the transit depensent oosuistion who need assistance in evacuating tne (PZ.
Tne new legistics de not change the concept of any erecedures.
J 10.K This element remains inaseouste. he material in
- 1' Revision 6 eddress tnis element. All coments in 3
tne RAC review of Revisten 5 are attil in effect.
"This element is inadequately accret, sed in the plan.
4 In addition, corcerns pertaining to LER0's legal authority to imolement the plan were igantified by the RAC during the review of Revisten 8 and are st111 in effect.
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.I ' [ FEB.06 *06 16:50 FD% REGION II PEW YORK 1 P.84
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I,fLC0 Transition D1an for Shoreham - Revision s FEMA Asview Dated February 7, 1986 4
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WREG 0654 fle-eat _
tjvtew Coment(s)
Antina J.12 Tiis element remains inadequate. As discussed below j
Revision 6 accountely addresses two concerns raised Dy the RAC review of Revision 6.
A new Attachment 8 to procedure 49!P 3.9.2 fives a i
trigger levels for declaring items contaminated.
1 This resolves the RAC issue of not naving a trigger
]
level for the interior of vehicles.
Revision to the Plan on eage 4.2 1 and in precedures i
091P 3.9.2 ane 4.2.3 have deleted all reference to a otrticulate release as seing a trigger for various actions.
Tnese enanges resolve a AAC issue.
i D*ocecure OPIP 4.2.3 nas been completely rewritten.
The new procedure gives a new evacues traffic eattern and a new monitoring arrangement at the Nassou County Coliseum Reception Center. This new j
procedsre is adecuate.
This Plan revision raises a new issue due to a change in procedure OPIP 3.9.2.
In step 3.2 of I
the revisse procedure, tne statement is made that if a radioactive release has occurred, monitoring i
personnel will be dispatched to special facility reception centers when available. LERO is responstele for monitoring all evacuees arriving at reception centers.
It is not adequate to plan i
for this eenitoring with personnel and equipment i
when available. It is not possible to evaluate the ewber of personnel reeutred for monitoring at i
the special population reception centers since the plan shows in procedure OP!P 3.6.f pegas 21-37 "te be arranges" for most of the special J
j
,sepulation reception centers. Feue (4) reception i
centers are shown which are not the Nassau County
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Coliseum.
Monitoring personnel ans equipment must De availabis for these four ano en other locations curren(4) reception senters tly snown as "to be arranged".
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