ML20154E629

Forwards FEMA & Rept on Review of Rev 9 of Licensee Offsite Emergency Plan.Recommends Exercise Proceed as Planned

ML20154E629
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	09/09/1988
From:	Brown S Office of Nuclear Reactor Regulation
To:	Leonard J LONG ISLAND LIGHTING CO.
References
NUDOCS 8809190080
Download: ML20154E629 (117)

Text

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? - September 9, 1988

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Docket No. 50-322 DISTRIBUTION:

pectet. n Te /

Long Island Lighting Company NRC & Local PDRs ATTH: Mr. John D. Leonard, Jr. PDI-2 R/F Vice President - Nuclear M0'Brien i P.O. Box 618 SVarga/BBoger Shoreham Nuclear Power Station WButler Wading River, New York 11792 SBrown 0GC Gentlemen: .

Enclosed are a Federal Emergency Management Agency letter dated May 31, 1988 and report on the review of revision 9 of Long Island Lighting Company's 1 offsite emergency plan for the Shoreham Nuclear Power Station. l Sincerely,  !

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j /s/

1 Stewart Brown, Project Manager ,

! Project Directorate I-2 Division of Reactor Projects I/II .

!j Office of Nuclear Reactor Regulation '

i

Enclosure:

As stated 4

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8809190080 88 9 l

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1. pa ntaug'o, UNITED STATES

!4 ,,, g NUCLEAR REGULATORY COMMISSION

.- ;a WASHINGTON, D. C. 20555 September 9, 1988

%,+....j Docket No. 50-322 Long Island Lighting Company ATTN: Mr. John D. Leonard, Jr.

Vice President - Nuclear P.O. Box 618 Shoreham Nuclear Power Station Wading River, New York 11732 Gentlemen:

Enclosed are a Federal Emergency Management Agency letter dated May 31. 1988 and report on the review of revision 9 of Long Island Lighting Company's offsite emergency plan for the Shoreham Nuclear Power Station.

Sincerely, e h Stewart Brown. Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated i

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O Mr. John D. Leonard, Jr. Shoreham Nuclear Power Station Long Island Lighting Company (list 1) cc:

Stephen B. Latham, Esq. Gerald C. Crotty, Esq.

John F. Shea, III, Esq. Ben Wiles Esq.

Twomey, Latham & Shea Counsel to the Governor Attorneys at Law Executive Chamber Post Office Box 398 State Capitol 33 West Second Street Albany, New York 12224 Riverhead, New York 11901 Herbert H. Brown, Esq.

Alan S. Rosenthal, Esq., Chairman Lawrence Coe Lanpher, Esq.

Atomic Safety & Licensing Appeal Board Karla J. Letsche Esq.

U.S. Nucir.ar Regulatory Comission Kirkpatrick & Lockhart Washington, D.C. 20555 South Lobby - 9th Floor 1800 M Street, N.W.

Washington, D.C. 20036-5891 W. Taylor Reveley III Esq.

Hunton & Williams Dr. Monroe Schneider Post Office Box 1535 North Shore Comittee 707 East Main Street Post Office Box 231 Richmond, Virginia 23?l2 Wading River, New York 11792 Howard A. Wilber Fabian G. Palomino, Esq.

Atomic Safety & Licensing Appeal Board Special Counsel to the Governor U.S. Nuclear Regulatory Comission Executive Chamher - State Capitol Washington 0.C. 20555 Albany, New York 12224 Atomic Safety & Licensing Board Panel Anthony F. Earley, Jr., Esq.

U.S. Nuclear Regulatory Comission Gereral Counsel Washington, D.C. 20555 Long Island Lighting Company 175 East Old County Road Atomic Safety & Licensing Appeal Board Hicksville, New York 11801 Panel U.S. Nuclear Regulatory Comission Mr. Lawrence Britt Washington, D.C. 20555 Shoreham Nuclear Pcwer Station Post Office Box 618 Gary J. Edles, Esq. Wading River, New York 11792 Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Comission Martin Bradley Ashare, Esq.

Washington, D.C. 20555 Suffolk County Attorney H. Lee Dennison Building Richard M. Kessel Veteran's Memorial Highway Chairman & Executive Director Hauppauge, New York 11788 New York State Consumer Protection Board '

Room 1725 Resident Inspector 250 Broadway Shoreham NPS I New York, New York 10007 U.S. Nuclear Regulatory Commission Post Office Box B l Jonathan D. Feinberg, Esq. Rocky Point, New York 11778 New York State Department of Public Service Regional Administrator, Region I Three Empire State Plaza U.S. Nuclear Regulatory Comission Albany, New York 12223 475 Allendale Road King of Prussia, Pennsylvania 19406

*s o-Long Island Lighting Company Shoreham (1)

CC' Robert Abrams, Esq. Town Attorney 3

Attorney General of the State Town of Brookhaven of New York 3232, Route 112 ATTN: John Corwin, Esq. Medford, NY 11763 New York State Department of Law Consumer Protection Bureau 120 Broadway 1 3rd Floor j New York, New York 10271 Mr. William Steiger i Plant Manager

] Shoreham Nuclear Power Station '

Post Office Box 628 Wading River, New York 11792  ;

MHB Technical Associates 1723 Hamilton Avenue - Suite K San Jose, California 95125 Honorable Peter Cohalan Suffolk County Executive County Executive /t.egislative Ruilding

Veteran's Memorial Highway i Hauppauge, New York 11788 ,

fis. Donna Ross New York State Energy Office  ;

Agency Building 2 Empire State Plaza i Albany, New York 1?2?3 i

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Ms. Nora Bredes

, Shoreham Opponents Coalition l 195 East Main Street '

Smithtown, New York 11787 (

Chris Nolin i

New York State Assembly .

Energy Committee  !

! 6?6 1.egislative Office Building i l Albany, New York 12248 l t

l Peter S. Everett, Esq. i

Hunton & Villiams  :

2000 Pennsylvania Avenue, NW  ;

Washington, D.C. 20036 l i

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Enclosure 2 0 44 P Federal Emergency Management Agency Region II 26 Federal Plaza New York, New York 10278

!av 6. 1988 MEMORANDUM FOR: Grant peterson Associate Director.

State and Local Procrams and Support a

FROM: J ac:: .%tbie f NM V Res. inn.14 to roet er/

SUDJECT: R AC Review Comments for the '!LCO Loest.

Offsite Radiological Emerzenev Response Plan for Shoreham. Revinton 9 Per your request of Feoruary 16, 19BA attache"2 ti t.n e review ef

ne re:erenceit n Lan wnten has been concui:ted by th* Revien II Regional $$ sis.tance Committee (RAC). As referencea en caen pate of the uoeument. this review has noen conductou An accoraance with the interim-use and comment document joint!" ceveloped bv FEMA and NRC entitled: Critaria for Preparation and Evniuntion o f Raciologieni Emergencv Response plans and preparedness in support of Yuelear Power Plant.*, tCriteria for Utility or: Nite 71anninu and Pr=parsoness): NUREG-0654/ FEMA-REP-1, Rev. ;. Supp. 1. In raviewing inis plan. FEMA and the RAC have assumed that ;n an etual raciological emergency. State and local officials that uve ceclinec to participate in emergency planning for the snorenam plant will:

(1) Exercise their best efforts to protect ne health tnd saf ety of the public:

f.) Cooperate with the utility and follow the utility offsite plan; and (31 Have the resources sufficient to implement hose l portions of the utility offsite plan where State and local response is necessarv.

Although Revision 9 constitutes a ma.ior revision. affecting more i

than 1000 ? ages of LILCO's plan. the Lucil Eme*ruancv Response Organi:ation's (LER0'sl concept er uparations remains essentinile 1

unchanyed from previous verstons of the '> ( an f.hn t nave baun )

reviewed. Thernfore, this review builds upon RAC comments developed for previous revisions IRevs. 1. 3. 5. 6. 7.' and 8) of j

the plan and this updated revlow reflects current operations, resources and status of the 7tilitv'1 oft'sito omergency planning effort.

review:

The following' steps were taken in completing this 8

G. Peter!. son

{ '

. lay (i . I t!d 8 Page :: of 3 (il etAc comments for Revisions 5. o. ina *

-rc '. o ru re der.otleu in deparate cocumenta, anu ..rmen = on aevision 3, were conaatidated ints arte document '

a t ru ./11/d8 and was districutod to the RAC memnera.

(2) A preliminary review antec .:/t7,'n at ':#viaton -

9 was connue teet oy FEMA Regton II nois contrte.cra to t. b e 'l E P '

program. "his preliminury r e v i '= w is . i t s t r '. n u t e n t c r.he rtAC . .GMA Henaq1tarters and '. . :. a .n 'aren .#. ; p at .

1/l seston .. net with LILC0 represen tn' 's es m Aprit 6, 11168 ona received tne uti!!ty'4 ;J e's .u - ei t se'. 44 :o resolve items rated Inn 1 equate i in

• se 't'*.M preliminary review ':nsmen t s .

141 Dora1 Lee review comments en Savia on *

't ina musn mee r e c;* 1 v e d from AAU memoer L C e tt e t o '4 tinu .P.* 'r.v...  ; N i *4 L into an updated rov 1ow document !. t s

...i.+.

51 i it.\t; meetinic, chaired br FEMA Regten :: en - a*tu in cur otitees to finalize the attnened comments in i.evar. ion 9 f or the plan. A record o t' cnis meering s..tx . r o n s. c r i b e d .

In the course o f developing the a t tnened ' opca r.e-[ mn : ew , rue fo) lowing nomonel.16ture has nevn sdapted from gro"ions r e v t ew's :

A (Adequate) The element is acequatetv u or* w nt in tno '

plan. Recommencations tor imprevament ><nown in if.it t i c t, are not manca t o r:* , bu. c. heir .

consideration would further impe>va tne utility's offsite emergency respons.* pinn. '

I (Inndequate) The element is inacequately nonrossed in the pinn for the reasontiI stateu . :t bold type.

The pian and/or procedures must ce rev1 wen before the element can ne consider 0d unequato.

For enne of uncerstanding, *no r9nson(s) an element has henn rated ;nadequara :s. unere posstole, stated first.

• As a means of summari:ing r.his rather lengthy rettew and for *am in underhtandlug tuo re,vi a r.l ons u s ed . nn Element i4ating Summary and List or Acronyms :$re prnvtoca :st .ne enn ,f yp oocumetit.

Seventeen (17) .+1emeri t s a re cu rr an t. l y ra r ou .nauequat e tIl and, in accordaneu with your request', Region II recommands a negativa tinding that the plati d o e at not pre **ently provide reasonable

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G. Peterson

>!ay 6. r.? s s

( Page 3 or 3 e

assurance that ndequate pro t ec t .ve .ian: u re . an ne .aken in tne event of a racioiotical emergency a t. S ito r e n.ua .

Planning for the exercise can go t o rwa ri: :oc wo rensons.

First, tne utility has provided negt.an i' .< i. i rn x.C with roposeo plan enanges to adcress e n ti s e in o:.s wi.icl e that wooid be incorporated, prior to the excretse. a n t a .- m i n t o n ;u of the plan. 'i.loven (1!) of these inadaqunenes .n .iu . r ' riat.ttively minor changes, anc the utility's proposec chnn..v. isr* re.sponsive to the MAC/FO!A concerns. Second, for tua .six i' . n a u e n tta t e elements rectua ring more suostantive reviston, fia .  :: : o f' t. n e s e (i.w., '

provisions for communications wtth New Vars state, ai. ament F.;.b; the puolic information provram t se r **.t or.o t s . t.ransients and t.ne agricultural community, eJements ,.; .-~. ..-. Snri ;.'1; .

and written agreements for "first-entl" eimmi o-nts vitn companies supplying supplementary numen tor :

• a n o -..ra v <-

vvacuat2cn of schools, element .J . L O . ; ) wi.. '

...,t .e .*s e r"; s ed .

Wi t a re a ri rr2 to the remaining :nesuequacy i.na t .nu s e ur -va oot-d at i the exercise (i.e., planning for the monti . r iia i r.o decentamination of school chilcr in evacun : ..<a .i t .,r . t e a s es .

element J.12). FF.)lA is providin:. technicai :in t a t.in .. .c ne utility to expedite the resolut ion o f tn t - .ssue :nr ;t3 '

inclusion in Revision 10.

With respect to LILCO's submission of Rev.u on 0, .nfa wt.1 '

. review the plan changes, coercinste t. i t h t a c .MC . ano

, incorporate them in the evaluation of the oxercise. Should any additional changes be forthcoming, =very erfort vi h ne mace to ,

incorporate them in the exercise as well. I Based on all of the above. I recommend *. hat tne exercise proceec

)

as planned. If you have any questions. please centact Mr. Ihor  ;

W. Husar, Chairman, Regional Asaistanco lcamittee, at FTS 649-

'l 8203.

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Review Comments B: sed On NUREG-0654/ FEM-REP-1, Rev.1 l Supp.1 1 Local Offsite Radiological Emergency Response Plan for Shoreham I Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 1 of 90 WUREC-0654 Element Review Comreent(s) Rating i A. Assignment of Responsibility (Organization Control)

A.1.a The lead role for response activities belongs to the A utility, Long Island Lighting Company (LILCO). The  :

plan establishes the Local Emergency Response Organization (LERO) developed by the utility and comprised of federal, utility and private organiza-tions.

Suffolk County is not participating in off-site emergency planning for Shoreham (see Chapter 1 Section 1.4, page 1.4-1 of the plan which references Resolution 1196-33, adapted February 17,1983 by Suffolk County Legislature), and New York State has not developed a state plan to compensate for the lack of participation by local government.

Should New York State decide to respond in the  !

event of a radlological emergency at Shoreham, the types of services that the State might provide are defined as follows (see page 1.4-2a):

• Command and Control

• Communications

• Evacuation ,

• Social Services ,

• Public Health '

• Fire and Rescue l Should Suffolk County decide to respond in the event of a radiological emergency at Shoreham, the j plan provides that the Director of Local Response i will work in conjunction with the County Executive or his representative 'In responding to the*

emergency (see page 3.1-1). This would include the

• I active participation at the EOC of the County j Executive, Commissioner of the Department of j Fire, Rescue and Emergency Services, the Commis-l stoner of the Department of Health Services and the Commissioner of Police: Public Information personnel at both the EOC and the ENC: and the r

Review Comments Based On NUREG-0654/ FEM-REP-1, Rev.1 Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 2 of 90 NUREC-0654 Element Review Comment (s) Rating A.1.a participation of other County officials to the extent (Cont'd) the County Executive deems p udent (see page 1.4-2a). LILCO expects 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 1.4-2b):

• Snow removal e Fire Safety

. Police Actions The plan provides that Federal Agencies will be called upon to respond to a radiological emergency at Shoreham in accordance with the roles of Federal '

agencies described in the Federal Radiological Emergency Response Plan (FRERP). The roles of three principal Federal agencies, the Nuclear Regulatory Commission (NRC), the Federal Emergency Management Agency (FEMA) and the Department of Energy (DOE) are defined.

The response roles of Federal agencies identified in Figure 2.2.1 are detailed for the following agencies in Section 2.2 of the plan (see pages 2.2-2a -- 2.2-5). ,

The response roles of the following federal agencies are addressed:

• U.S. Coast Guard (by Letter of Agreement)

• FEMA

• NRC l e DOE

• USDA e DOC

!

• DOD .

• HHS

• e DOT e EPA

\

e NCS i

• Veterans Administration Medical Center (by j Federal Mandate) 1 . , ,

. Review Comments Based On NUREG-0654/ FEM-REP-1, Rev.1, Supp.1 Local Offsite Radlological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 3 of 90 NUREG-0654 Element Review Comment (s) Ratina A.I.b The operational role of LERO and the concept of A emergency response operations are defined in Sections 1.4,2.1 and 3 or the plan.

Response roles of the various Federal agencies which may be called upon to support the LERO response are clearly defined. Figure 2.2.1 shows >

response organization relationships.

Pages 2.2-4 and 2.2-4a accurately describe FEMA's

~

role as the primary point of contact and coordina-tion between the NRC and other Federal agencies for nontechnical response activities.

LILCO anticipates that all local law enforcement agencies, fire departments, and snow removal i 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-c, and 2.2-7). The plan does depend upon law enforce- i ment agencies, fire departments and snow removal  !

agencies performing their normal function in areas j restricted as a result of an emergency at Shoreham.

The plan speelfles the following provisions that ,

i would allow police and fire lepartments to perform their normal functions in the event of radlological <

emergency at SNPS.

)

• LERO will offer training In doslmetry and radiation fundamentals and equipment (see Procedure OPIP 5.1.1, Section 5.1.3.4) to

these agencies.

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• LERO will provide adequate supplies of dost ,

l metry equipment to these agencies. .

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i' e if no training is provided prior to. an actual emergency, LERO will designate personnel

, trained in radiation protection and equipped 1 with dosimetry to accompany personnel

carrying out their duties within restricted i areas.

1

o Review Comments Based On

• NUREG-0654/ FEM-REP-1, Revo 1, l

Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham  ;

Final Regional Assistance Committee (RAC) Review of Revision 9  !

Dated April 28,1988 Page 4 of 90 NUREC-0654 Element Review Corament(s) Ratins -

i A.1.b LERO does not Intend to use law enforcement  !

(Cont'd) agenices, fire departments, and snow removal  !

' agencies where exposures in excess of the general  !

public PAGs are possible.

i 1 .

i A.1.e The organizational components of LERO are Illus- A  ;

trated in Figure 2.2.1.  !

The positions of Emergency Preparedness Advisor,

! Radiation Health Coordinator, and Nuclear Engineer  ;

l are filled by personnel from several outside con-sulting companies (see page 2.2-10) which provide LERO with specialized expertise.  ;

Figure 2.2.1 depicts Federal support response  !

agencies, and corresponds with the description of f roles described in Section 2.2 of the plan (see also  !

comment for element A.1.a).  ;

)

Figure 3.4.1 summarizes the communications l 4

systems used to notify LERO response organiza- l tions. The Rad:ological Emergency Communica-

}

tions System (CECS) dedicated telephone line is the 1 primary means of 24-hour notification between the

{ plant and LERO. The RECS telephone also provides l a means for courtecy notification of New York  ;

l! State and Suffolk County.

Figure 3.4.1 Indicates that both New York State and  !

Suffolk County have RECS communleation lines. l j The footnote on page 3.4-1 acknowledges that New  !

York State has apparently moved the offlees where l the RECS telephones are located and stipulates that i LERO will install the RECS telephones at the'

! proper locations when permitted to do so by the.

j State.  ;

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4

o e Review Commen%s Based On

,' NUREG-0654/ FEM-REP-1, Rev.1.

Supp.1 Local Offsite Radiolotrical Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 5 of 90 NUREC-0654 Element Review Coment(s) Rating A.1.e In response to earlier RAC concerns with the means (Cont'd) of notifying the State via RECS, LILCO has stated that: "The RECS line from Shoreham to New York State may be activated it any time at the dis-cretion of N.Y. State." If, during an emergency, the State decided to participate, their efforts could be coordinated with LERO via the RECS line and com-mercial telephone if the RECS line could be readily .

reconnected.

A.1.d Specific individuals who shall be in charge of the A  ;

emergency response are identifled by title under Chapter 2 organization (pages 2.1 2.1-7).

Again, LILCO personnel are the majority of LERO staff, along with DOE-RAP personnel from the Brookhaven Area Offine (BHO).

The positions of Nuclear Engineer and Radiation Health Coordinator are filled by consultants pro-  ;

vided by IMPELL Corp) ration. The NUREG-0654 cross-reference refers to Appendix B. page App-B-70, which is a letter extending the expiration date of a LILC 0 purchase order to cover the costs associated with the consulting services of a Radio- .

logical Health Coordinator from IMPELL Corpora-  !

tion. Four (4)!MPELL employees are listed as being available to fill each of these positions. There are also agreements in Appendix B with Aldlkoff Associates, Inc., The Behr Consulting Group, Inc.,

and Richard J. Watts, Inc. for personnel for the j positions of Nuclear Engineer, Radiation Health i Coordinator, and Emergtncy Preparedness Advisor (see comment element F.1.b).

I q_ .,- ,_-_-..----_.._._-,._.m___-.,__ , . , - , _ , . _ _ . _ . __._

Review Comments 80 sed On NUREG-0654/ FEM-REP-1, Rev.1 Supp.1 Loco Offsite Radlolorleal Emergency Response Plan for Shoreham '

MS Regional Assistanes Committee (RAC) Review of hovision 9 Dated April 28,1988 Page 6 of 90 WREG-0654 Element Review Coneent(s ) Rating A.1.e The !(ad LERO Communicator (see page 2.1-7) has A responsibility for ensuring that all communicator positions in the local EOC are staffed on a con-tinuous basis once this facility is activated. Also, Chapter 3. Svetion 3.4, pages 3.4 3.4-5 stipu-lates that the Radiolegical Emergency Communica-tions (RECS) line between the Plant ard LERO, and LILCO's Natification Rad lo System are monitored 24-hours per day.

The LILCO Notification Radio System, a unit of which is located in the Shoreham Control Room, serves as backup to the RECS. This radio system is monitored 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day at the Electric Systems Operations Center in Hicksville.

\.2.a The functions and responsibilities for major A elements and key Individuals by title, of emergency response, are speelfled in the plan f a. the fol-lowing

Command and Control, Alerting and Notifi-cation, Ccmmunications, Public Information, Accident Assessment, Public Health and Sanits.tlon, ,

l Social Service </ Congregate Care, Fire and Rescue, ,

Traffic Control Emergency Medical Services, Law

{ Enforcement. Transportation (general population, health ralated. schools), Protective Respense (plume, ingestion), Radiological Exposure Control 1 and, Reception and Relocation Centers. Section 2.1 (see page 2.1-la) of the plan, Figure 2.1.1 speelfles  ;

that the Direetcr of Local Response has primary responsibility for command and control, alerting and I notification, communications, public information, protective response and reception ant relocation ,

centers. The legend attached to the Figure 2.1.2.

organizational matrix denotes that it is assumed by

• LILCO that the government official with the neces-sary legal authority will provide the authority /

permission to LERO to implemitnt- command and control, alerting and notification, activation of sirens and issuance of EBS messages, protective i

i

. Review Comments Based On NUREG-06?4/ FEM-REP-1, Rev.1 Supp.1 Local Offsite Radlological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 7 of 90 WUREc 0654 Elet..ost Review correent(s) Ratinj A.2.a Response (for botti plume and Ingestion) and activa-(Cont'd) tion of reception and relocation centers, it is also assumed in the plan that legal authority / permission for Traffic Control will be provided to the LERO Evacuation Coordinator by the appropriate govern-mint of fletal.

i Primary and support responsibilities are reflected in Figure 2.1.2, with single functions cited.

Procedure OPl? 2.1.1 assigns primary responsibility for major functions to the following single positions within LERO:

i

• Command and control of LERO response activities - Director of Local Response.

e Coordination of the implementation of LERO response ac tit,.ts - Manager of Local l Response. . ,

e Public Information and Notification -

Coordinator of Public Information.

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• Accidir.t Asses 3 ment -

Radiation Healtn Coordinator

• Medical and Public Health - Emergency l l Medical /Public Servlee Coordinator l

. Coordination of evacuation actions -  ;

Evacuation Coordinator.

)

• Traffic Control '

Traffle Control.

Coordinator *

• Evaluation of road Impediment effects and determining alternate evacuation rerouting - )

~ ~ ~ '

"Yaffle Engineer ~.'

1

• Review Comments Based On NUREG 0654/ FEM-REP-1, Rev.1.

Supp.1 Local Offsite Radiolorleal Emergency Response Plan for Shoreham  :

Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 .

Page 8 of 90 NUREC-0654 >

Element Review Corunent(s) Rating I

A.2.a e Establishment of Staging Areas (at (Cont'd) Patehougue, Port Jefferson and Riverhead facilities), coordination of dosimetry

distribution and briefing of emergency workers - Staging Area Coordinators (3).

l -

Coordination of reception, logtstleal support '.

cotivities, LERO family tracking and reloca-on centers - Support Services Coordinator.

1 Figure 3.3.7 assigns primary responsibility for

alerting the general public to the LERO Director of l Local Response. The LERO Coordinator of Public 4 Information is responsible for issuing EBS broad- '

easts. Figvae 3.3.7 indleates that FEMA has pri- ~

j mary responsibility for notifying the public of the Federal response during an emergency. However, i r the lead Federal agency for th(s function L '

dependent on the Cognizant Federal Agency.

Two (2) key positions were r.dded to the LERO 6

organization in Revision 8. A traffic engineer was l added to the staff at the EOC to evaluate any, possible Impediments to evacuation and to make recommendations on necessary changes to evacua- i tion routes in response to potential Impediments. (

Another position, a LERO Spokesperson, and addi-

}'

tional staff have been added and ass!gned to the ENC to assure better coordination of information.

A.2.b State and local governments are currently declining A j to participate in the development of an offsite i emergency response plan for Shoreham. Therefore, the ut!!!ty has developed a Local Emerg:ncy' .

Response Organization (LERO) comprised of utility,'

4 Federal and private organizations that will respond

, to an emergency. According to the plan (Se " bn

! 1.4, page 1.4-la) New York Executive. Law Art.cle-l 2-B recognizes that state and local authorities may l

l 1

o

, Review Coramen9s Based On NUREG-0654/ FEM-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 9 of 90 WUREG-0654 Element Review Consnent(s) Rating j A.2.b make use of private resources including "emergency (Cont'd) ser,' ices organizations." Also according to the plan, LERO is an "emergency services organization" as defined in New York Exec. Law 20.2.e and, as volunteers, all LERO personnel would operate under 4 the authority of the State and local gcVernments.

Emergency response functions including protective action deelslons, notification of the public and  :

directing traffic would be done by LERO in l coordination with State and local authoritles.

I j Attachment 1.4.1 of the plan refers to legal authority under 10 CTR 50.47 (c)(1) which, amended 1 (52 FR42085), provides as follows: ,

Failure to meet the standards set forth in para-graph (b) of this section* may result in the Commission declining to issue an Operating Licenses however, the applicant will have an 1

opportunity to demonstrate to the satisfaction >

of the Commission that deficiencies in the plans " l i ue not significant for the plant in question, that '

adequate interim compensating actions have ,

I been or will be taken promptly, or that there are

) other compelling reasons to permit plant opera- l

{ tion. Where an applicant for an operating j

license asserts that its inability to demonstrate compliance with the requirements of paragraph j l (b) of this section results wholly or substantially l J from the decialon of state and/or local govern-j meats not to participate further in emerTency planning, an operating license may be lasued if the applicant demonstrates to the o m missiw.'s utisfaction that: ,

j (1) the applicant's inability to comply with' the requirements of paragraph (b) is

i wholly or substantially the result of the non-participation of state and/or local - -

governments.

1 i

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.' Review Comments eased On NUREG-OS$4/ FEM-REP-1, Rev.1.

Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 t

Page 10 of 90 WVREC-0654 Element Review Comment (s) ht_inJ [

A.2.b (11) the applicant has made a sustained, good (Cont'd) faith effort to secure and retain the participation of the pertinent state ,

and/or lockl governmental authorities,  !

Including the furnishing of copies of its emergency plan.

(ill) the applicant's emergency plan provides  :

reasonable assurance that public health l l and safety is not endangered by

{ operation of the facility concerned.

l  !

Revision of the plan responds to these revised NRC

] regulations that expressly recognize that State and

] local governments will respond and exercise their best efforts to protect the health and safety of the public in an actual emergency. In accordance'with the planning basis speelfled in NUREG-0654/ FEMA- f REP-1, Rev.1, Supp.1., the plan is precicated on i the assumption that State and local officials that j have declined to participate in emergency planning l will: '

l . t 1 a. Exercise their best efforts to protect the

• health and saf6y cf the pubtle l l

b. Cooperate with the utility and follow the l

utility offsite plant and ,

c. Have the resources suffielent to )

Implement those portions of the utility l 4

offsite plan where State and local response l l is necessary. l LILCO does not assume that non-participating State *

and local organizations will be as familiar with the '

1 plan as if they had participated W the planning j process and exercised with the u'.111ty. Therefore, 1

LERO will~ provide !!alsons to (1) coardinate j information and resources with State and local

governments and (2) provide advloe and assistance 1

l

. Review Comments Based On ,

NUREG-0654/ FEM-REP-1. Rev.1,

Supp.1 -

Local Offsite Radiologiet! Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 11 of 90

! 14UREC-0654 i Element Review Comunent(s) Rating j A.2.b to responding State and local governments in (Cont'd) Implementing their roles and functions as assigned ,

i under the utility's offsite response plan.

Revision 9 of the plan adequately addresses the [

i l legal basis for (1) authorities that have been  ;

assumed by the utility to plan for LERO's response l'

role and (2) functions and responsibilities that are , ,

i reserv6d by State and local government. {

j

• Standards A-P speelfled in eriteria defined in NUREG-0654/ FEMA-REP-1 Rev. 1 Supp. 1.

Criteria for Utility Offsite Planning and f i Preparedness, Draft Report for Interim Use and i

Comment, November 1987. l l (

A.3 Appendix B contains letters of agreement in effect A ,

for the following support organizations identified in j Section 2.2 of the plan. l

• DOE /Brookhaven Area Office  !

• WLIM radio

• WLNG AM radio - *

• WRCN FM radio l

• WRHD-AM radio  ;

e WGLI radio l

• WRIV radio l

• U.S. Coast Guard  !

• W P L."-F M radio (Common Point Control Station) l

• WICC-AM radio l

• WEL1- AM radio l

• American Red Cross .

(

• Institute of Nuclear Power Operators *

• State of Connecticut (Office of Civil Preparedness)  !

f The three EBS stations that have been added  !

broadcast from Connecticut. Two stations thAt l have substantial listening audiences in the area of I the EPZ (WBAL and WsBH) have not been added as previously suggested by the RAC.

J

Review Comments Based On

! NUREG-0654/ FEM-dEP-1, Rev.1.

Supp.1 Loen! Offsite Radiolorleal Emergency Response Plan for Shoreha.--

Final Regional Assistance Committee (RAC) Review of Revisien 9 Dated April 28,1988 Page 12 of 90 I NUREC-0654 Etesent Review Consent (s) Rating l A.3 The plan states: "All local law enforcement l (Cont'd) agencies, fire departments and J .to w removal l

agencies within the 10-mile EPZ will continue to carry out their normal response functions during an

) e mergency." This is in accordance witx the i assumptions !.D of NU R EG-0654 / TEM A-REP-1, i Rev.1,Supp.1.  !

I The supplementary lettar of agreement from DOE  ;

I (dated June 18, 1984), confirms that DOE has l agreed to provide two, 2-man fleid monitoring teams and additional teams, if needed. it is evident ll from this letter and the plan that a DOE repre-i sentative will be dispatched to the local EOC to '

j coordinate the relay of field monitoring data for use In off-site dose assessment which will be completed

! by the LERO Radiation Health Coordinator. The  !

DOE letter of personnel commitment is adequate.

. L The Letters of Agreement with the State of Connecticut, EPA, and USDA are adequate (see Appendix B, pp. B-72, B-76, and B-77). l 4 .

j There is a letter of understanding with the Federal , l j Aviation Administration (FAA)(12/11/87) that gives [

j the procedure for LlLCO to follow in directly l

) notifying the Duty Offleer at the Regional l 1 Operations Center in Jamalca, N.Y. In the event of l

> an emergency. This letter satistles a previous RAC (

objection.

i l There is a letter of understanding with the Long Island Railroad (LIRR) (10/17/87) that confirms ,

procedures for notifying LIRR and that gives the. l 4

24-hour LIRR telephone numoer to be called. Thl * ,

1 letter satisfies a previous RAC objection based on l an issue identified at the February 13, 1986 4

exercise.

I ,

i 1 l

i

• Review Comments Based On NUREG-0654/ FEM-REP-1, Rev. I, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 13 of 90 NUREC-0654 Element Review Coment(s) Rating A.3 It is noted that OPIP 3.6.3, p. 2 mentions (Cont'd) contacting the U.S. Coast Guard when helicopters are to be used in notifying boaters (parapaph 5.1.1.c). There is no mention of helicopters In the new Cout Guard letter of agreement (01/15/88) contained in the plan. However, Procedurs 3.3.4 Section 5.5.1 Indicates that LERO will provide helicopters (there is an adequate letter of speement with Island Helleopter Corp.) for notification to boaters so that the Coast Guard is not being relled upon for helicopters.

LILCO has withdrawn letters of speement (from the lessee and the Nassau County Executive) for the use of the Nassau Collseum as a reception center, and for monitoring ard decontamination of evacuees.

In Revision 9, the Nusau Collseum and Nassau Community College are to be used as school reloca-tion centers. In !!eu of letters of speement, authorization to use these facilities will be obtained as described in Procedure OP!P 4.2.1, Section 5.1.

The Director of Local Response is to inform the

• Nassau County Executive of the status of the

emergency, that schools may be evacuating to the Coliseum and Community College, and that the Executive's authorization is necessary to use these facilities. The procedure assumes that authoriza- ,

tion will be panted. When a school evacuation is recommended or in progress, the Director of Local Response advises the Nassau County Executive of the expected number of arrivals and requests that County Police assist in traffic control and that the, required buildings be cleared (Section 5.1.4.b-c). .

l

l l 1 l l l

I I

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Review CommenBs Based On j NUREG-0654/ FEM-REP-1, Rev.1, l Supp.1  !

I i

Local Offsite Radlological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 14 of 90 NUREC-0654 Review Comment (s) Rating Element A.3 Amerinn Red Cross - The letter dated August 21 (Cont'd) 1986 states that "... there is no apeement between Long Island Lighting Company and this (Nassau County) Chapter relating to the chapter's responsibility to provide emergency assistance during a radiological emergency." The cited letter refers to a 1984 letter (see App. B-10) that describes the role of the American Red Cross (ARC). It also notes that some of the conpegate care facilities listed in the 1964 letter are no longer available, but does not identify them. It does not refer to an agreement executed by the Nassau Chapter on January 17, 1986 in which it agrees to provide mass care services at eight enumerated LILCO facilities. It is not clear whether the intent of the August 21, 1986 letter is to abrogate the January 17, 1986 speement to provide mass care services at the specified LILCO facilities. A subsequent letter dated November 2,1987 states that the Nassau County Chapter want references to it deleted from the LILCO plan, but also states that because of its humanitarian mission it will provide mass care services to the extent of its abilities and will cooperate with public and private

• organizations. Regardless > 'he disposition of this correspondence, it must be ird rr-d that the ARC would cooperate with LILCO/LERO in an actual ,

emergency (sea also comments for element J.10.h of this review).

The Nuclear RegulMory Commission in Long Island  :

Lighting Co. (Shereham Nuclear Power Station Unit 1), CLI-87-5, 25 NRC 884, 888 (1987), recognized i that the ARC charter from Congress and its i

national policy require that the ARC provide aid in; "any radiologiest or natural disaster," whether ora not there are le.ters of speement with the ARC in connection with a particular emergency plan.

. I

. l Review Comments Based On NUREG-0654/ FEM REP-1, Rev.1, i Supp.1 l Lceal Offsite Radlological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28, 1988 Page 15 of 90 NUREG-0654 tiement Review Coenent(s) Ratina A .4 The LERO Director of Local Response is responsible A for ensuring the continuity of emergency resources for 24-hour operations over a protracted period.

The establishment and maintenance of LERO over a protracted period ir, described in Section 2.1, page 2.1-1 and Procedure OPIP 2.1.1.

C. Emergency Response Suppert and Resources Co l.a The LERO Director of Meal Response is responsible A for and assumed to '. ave the authority to request federal assistance hee page 2.1-la). i The plan stipulates that Federal agencies will initiate their support of an emergency response based on either direct request from LERO or through FEMA in accordance with the Federal Radiological Emergency Response Plan (FRERP).  :

i Under the provisions of FRERP, FEMA is i responsible for coordinating the offsite, non-technical response DOE is responsible for coordinating the offsite radiological monitoring, ,

assessment, evaluation and reporting of results to ,

Federal agencies during the initial phases of an

! ecaergency EPA is responsible for coordinating the

, Intermediate and long-term offsite radiation monitoring activities: NRC is responsible for mor.itoring the licensee and providing on-site technical assistance to ensure that appropriate protective action recommendations are being made. l l

I C.1.b The DOE-RAP (BHO) is speelfled to provide rat'o I ,

A logical monitoring assistance and expected times l for arrival are provided. 1 Specific resources and approximate :to Anse time (s) for Federal agencies (including USCG, EPA, NRC and USDA) have been included in the Plan (see pages 2.2-1 through 2.2-5 and Attachment 2.2.2).

-.-+g--. - - - - - - - - - - - , _ - - - - - - - - - , ,

Review Ccmments Based On NUREG-0654/ FEM REP-1, Rev.1.

Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28, 1988 Page 16 of 90 NUREG-0654 Elemene Review Comment (s) Rating C.I.c The plan identifies resources that are available to A support the Federai response (e.g., Attachment 3.11.1).

The inclusion of services provided by Federal ,

agencies under provisions of the Federal Radio-logical Emergency Response Plan (FRERP) are sufficient to satisfy that resources have been identified by the Federal agencies partic!;ating in FRERP. LILCO has obtained separate letters from EPA and USDA which identify resources needed to support their effort.

The 10th service designated to USDA under FRERP ,

(page 2.2-4d) should be removed because the U.S. '

Department of interior presently has lead responsibility for the National Radio Fire Cache.' ,

C.2.a LERO representatives are already at the SNPS site A and may be dispatched to the near-site Emergency Operations Facility (EOF). Additionally, a LERO  ;

Nuclear Engineer is usigned to the EOF. This person serves u a liaison between SNPS personnel

• and the LERO Radiation Health Coordinator at the EOC (Procedure OP!P 2.1.1, Attach. 2, p. 8b of 73).

I C.2.b The  !!censee is prepared to dispatch a A J representative to the LERO EOC in accordance

• with their procedures (Section 3.5, p. 3.5-1). ,

r C.2.c The LERO is prepared to dispatch a liaison to the, A State EOC in Alban3 and Emergency Preparedness.

Advisors to the Suffolk and Nassau County Execu

• tives (Section 2.1, p. 2.1-la). The Director of Local Response at the LERO EOC will contact the LlLCO

~

Office of Corporate Affairs and errange for a-LILCO representative in Albany to report to the l State EOC and act as a Liaison. A backup Director j or Manager of Local Response will be sent to the '

l

. l Review Comments Based On NUREO-0654/ FEM-REP-1, Rev.1 Supp.1 Local Offsite Radiolorleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 17 of 90 NtTRIC-0654 Element Review Comment (s) Rating C.2.c State EOC to replace this LILCO representative as A (Cont'd) soon as possible (OPIP 3.1.1. Attachment 1, p. 5).

The Emergency Preparedness Advisors report to the LERO EOC and upon orders of the Director of Local j Response report to the Suffolk and Nassau County Executives to advise and assist county officials in implementing those portions of the offsite plan where a county response is identified (OPIP 2.1.1, .

Attachment 2, p. la).

C.3 Section 3.5, pages 3.5-2a-3, of the plan identifies A radlological laboratory and analysis services that 1

can be used in an emergency. Two types of labora- t tories are DOE-RAP (BHO) laboratories and SNPS  :

i laboratories (Clean Harbors Analytical Services and Teledyne Isotopes). The letters of Agreement with the SNPS laboratories (see App. B-73 and B-74) give their general capabilities and expected availability.

Clean Harbors Analytical Services and Teledyste isotopes are located in Massachusetta and New Jersey, respectively. We could not locate where the l plan addresses who will transport field samples to ,

these SNPS laboratories for analysis. The plan j should address who wt!! transport samples to these out-of-state laboratories.

Page 3.5-2 of the plan identifies a minimum of two

, (2) ORS teams from DOE-RAP (BHO) for monitoring  ;

services (see Section 2.2, pages 2.2-3-4, of the plan). Included under DOE-RAP (BHO) services is j the Nuclear Emettency Search Team (NEST), whose response includes a special radiation detection.

system and airbourne radiation survelilance *,

syste ms. '

i , '

' * ~ * = < e . e ,

l t

- - __ _ , _ _ _ . _ _ - . _ , _ , ._ , _m- ____ _ _ ___._____,_____,__.,_____-,.,__,__,.c- _ , - .

.' Review Commen%s Based On NUREG-0654/ FEM-REP-1, Rev.1.

Supp.1 Local Offsite Radiolegleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 18 of 90

NUREC-0654 Element Review Comment (s) Rating C4 'Ihe leases in Appendix B for the Riverhead Transfer i Point and the Coram Transfer Point have not been executed. '!he lease for the Miller Place transfer point expired 02/29/88. No lease was found for the

Warehouse - Doctors' Path Transfer Point.

The Plan states that the LERO position of Traffic Engineer will be filled by personnel from KLD Assoelates, Inc. (Section 2.2, page 2.2-10).

Appendix B does not contain evidence of a contract with KLD Associates, Inc.

Letters of agreement and contracts with bus and ambulance suppliers are included in Appendix B for the following resources: ,

• Bus Companies -

- 1.584 40-passenger school buses

- 8 7-passenger vans

• Ambulance companies

- 63 ambulances

- 130 ambulettes 1393 40-passenger buses and the 8 vans have been contracted for on an "as available" basis. In 1987, contracts were signed with five bus companies to provide 191 buses. These contracts are not on an "as available" basis. The contracts witn the bus l companies were for unmanned, vehicles (l.e.,

vehicles without drivers). The contracts with '

. ambulance companies are for manned vehicles on an "u required" basis (see comments to element J.10.g for inconsistencies in number of buses available).

O

.' Review Comments Based On NUREG-0654/ FEM-REP-1, Rev.1, Supp.1 >

1 Local Offsite Radiological Emergency Response Plan for Shoreham

Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 19 of 90 l

} l NUREC-0654 Element Review Comunent(s ) Ratina [

{

i C.4 The ewcuation plan fAppendix A, page U-20a) i (Cont') states that LERO has arranged with various bus companies to obtain *first-call" rights to enough additional buses so that all school children could be evacuated in one wave. However, Procedure 3.6.5, l Attachment 3a and the letters of agreement shows '

i that many of the contracts with the bus companies I

1 are for buses "as available" rather than on a "first l call" basi.: for buses to be used for a one wave

}

evacuatton of schools.

Bus resources available are adequate to fulfill the f 1

potential requirement for 333 40-passenger buses '

j (see Appendix A, page IV-74e-f). l i

i The ambulance and ambulette resources available j appear adequate to fulfill the potential require- l

ments of the special facilities list in Procedure l OP!P 3.6.5. According to LILCO, a copy of the confidential computerized Homebound Evacuation Listing would be made available for FEMA's review i during an exercise. RAC found that such listing will j be sufficient to determine if the ambulance and j ambulette resources are adequate. FEMA would ,

l l

like to review the listing prior to any exeretse. l However, a final determination of the overall .

adequacy of ambulance and ambuiette 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 exeretse l (see also analysis comments for element J.10.d). l l l

) Although the revised plan does not speelfy the, i number of bus drivers that have been trained anda*

i lleensed, Figure 2.1.1. (page 4 of 5) speelfles that i 373 LERO bus drivers are assigned to the three (3) staging areas as follows:

i l

• Port Jefferson 108 l

• Riverhead 100 l

• Patchougie 165 Total 373

l l

.' Review Comments 80 sed On NUREG-06S4/ FEM-REP-1, Rev.1, l Supp.1 i Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 20 of 90 WRIC-0654 Element , Review Comment (s) Rating C.4 Appendix B contains executed agreements (leases)

(Cont'd) for the following transfer points:

• Middle Island Transfer Point (expired 03/31/88)

• Shirley Transfer Point (expired 03/31/88)

• Expressway Plaza Transfer Point (expired 03/31/88)

• Brookhaven National Laboratory Transfer Point

Leases are not required for the three transfer points on LILCO property (Eastport Substation, Brook-haven Substation, and Norwood Avenue).

Letters of agreement including contracts, purchase orders, proposals, etc. were found for the following organizations and individuals being relied upon in an

emergency to provide assistance

• Central Suffolk Hospital e Brunswick General Hospital

• Laboratories which provide environmental sample analysis

• Radiation Health Coordinator (minimum of 7)

• Nuclear Engineer (minimum of 6) ,

i e Emergency Preparedness Advisors (minimum of 2)

• Gasoline purchases

• New York Telephone

• Marketing Evaluations, Inc.

• Island Helleopter Corp.

The new purchase agreement (Fall 1987) with Teledyne Isotopes for environmental sample analysis  ;

expressly provides for one-day output (i.e., 24-hour.

turnaround of results) and gives the detection limits', c for . such shorter counting times. This new agreement satisfler a previous RAC objection. I

, I i

f m

f 1

.' Review Comments Based On NUREG-0654/ FEM-REP-1, Rev.1.

Supp.1 Local Offsite Radlologleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated Apr!! 28,1988 Page 21 of 90 WL1 TIC-0654 Element Review Coment(s) Rating C.5 The State Liaison and Emergency Preparedness A Advisors are to provide advice and assistance to State and local officials in implementing their portions of the offsite plan where State or local response is identified (Section 2.1, p. 2.1-las OPIP 2.1.1, Attachment 2, p.1.at OPIP 3.1.1. Attachment l

1 p. 5). Also, a Traffic Control Point Coordinator will report to the Suffolk County Police Head- ,

quarters to usist witP the dispatch of police I personnel to EPZ traffic control points. While at po!!ce heu* ' ters, the Traffic Control Point I Coordinator i maintain contact with the Traffic Control Coordinator at the LERO EOC. He will advise police of changes in emergency status and protective action recommendations. He will also y notify the LERO EOC of any road impediments reported by the police in the EPZ vicinity (Section

2.1, p. 2.1-lat OP!P 3.6.3, Attachment 15, pp.1 and l 2).

4 D. Emergency Classifleation System D.3 The Emergency Classification System described in A i

l Chapter 3 Section 3.2, page 3.2-1 conforms with l the system set forth in Appendix ! of NUREG-0654/

FEM A-REP-1, Rev.1. '

2

) D.4 The emergency action procedures to be taken are  !

described in Chapter 3, Concept of Operetions, and

] '

the implementir.g Procedures OP!P 1.1.1 through 5.4.1.

I Procedures for advising the Suffolk County!

! Executive and the Nassau County Executive on '

emergency actions to be taken are found in i Attachments 1 and 10 of OP!P 3.1.1. Attachment 10 describes adequately how the Director of Local Response advises the Suffolk County Executive of

., the status of the emergency and obtains permission for protective action recommendations (PARS).

-. -_ y.- . - . _ - . _-- _ , . -

_. . -y - , . - - - - - . - - -

. Review Comments Based On NUREG-0654/ FEM-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated Aprl! 28,1988 .

Page 22 of 90 NUREC-0654 Element Review Coment(s) Rating

, D.4 Attachment 1 of Procedure OP!P 3.1.1 !s the (Con t'd) Director of Local Response's emergency response [

action checklist. The first step on the checklist for each ECL includes obtaining emergency information from the Radiological Emergency Data Form and contacting the Suffolk County Executive in accordance with Attachment 10.

Section 3.1 of the Plan states that the Director of Local Response will formulate protective action i recommendations in conjunction with the Radiation Health Coord!netor. However, Attachment 1 of l OPiP 3.1.1 calls for the Director of Local Response confarring with the Radiation Health Coordinator as the fourth step on the checklist for Site Area /

General Emergency. There is no indication that the steps on the checklist are not to be performed sequentially (e.g., Procedure OP!P 3.9.1. Attach-ment 1 states that the actions on the Staging Area Dosimetry Record Keeper Procedure need not be l

performed in sequence but OPIP 3.1.1. Attachment i does not contain such a statement). In step 1, the Director of Local Response contacts the Suffolk County Executive and if appropriate obtains '

approval of PARS (see OP!P 3.1.1, Attachment 10, *

page 2). At this time, he or she has, emergency information from the Radiological Emergency Data Form. In Step 4, the Director of Local Response confers with the Radiation Health Coordinator for an assessment of the radiological emergency and to determine appropriate PARS (see OPIP 3.1.1.

Attachment 1, page 8). This procedure raises the possibility that the Director of Local Response might acommend and advise protectiva actions to, l

the Suffolk County Executive on the basis of.

l Information on the Radiological Emergency Data'

Form and without consultatica with the Radiation Health Coordinator as called for in the plan.

4

Review Comments Bas:d On NUREG-0654/ FEM-REP-1, Rev.1.

Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 23 of 90 NUREC-0654 ,

Review Coneent(s) Rating

• Element ,

D.4 After conferring with the Suffolk County Executive (Cont'd) at the Alert, Attachment 1 of Procedure OPIP 3.1.1 l

directs tre Director of Local Response to contact the Nassau County Executive to describe the Nassau County resources that will be needed if an evacuation is recommended. In the event that the Governor of New York has declared a State of Emergency, the Suffolk County Executive should be replaced by the Governor, as appropriate, as tha government official to advise. Telephone numbers for the Governor of New York and the Nassau County F.secutive could not be located.

l E. Notification Methods and Procedures E.1 The notification and mobilization of emergency A lj response organizations including the verification of

! messages is outlined in Section 3.3, pages 3.3-1 thru i

5 and Procedures OPIP 3.3.1, 3.3.2, 3.3.3, 3.3.4, and 3.3.5.

Upon initial receipt of an Alert or higher level i emergency classification, the Director of Local ,

Response will contact New York State and Suffolk County of ficials.

The LILCO Supervising Service Operator in the Electric Service Station. Hicksville is the primary  !

I LERO notification point. Upon activettion of the <

Local EOC, responsibility for receivirt notification will shif t to the Lead Communicator in the EOC's l communication center. ,

Figures 3.3.2-4 identify the persons / groups /'.  ;

organitations to be notified for each emergency classification. Figure 3.3.5 Illustrates LERO's '

notification scheme. Ve.ification of LERO personnel notification occurs over the Automated )

l' Verification System.

l r

f

• Review Comments B: sed On NUREG-0654/ FEM-REP-1, Rev.1.

Supp.1 Local Offsite Radiological Emergenev Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated Aprl) 28,1988 Page 24 of 90 NVILEC-0654 Review Coeurent(s) Rating Element E.2 The necessary procedures for alerting, notifying. A ,

and mobilizing emergency response personnel are ,

found in Procedure OP!P 3.3.2.

OPIPs 3.3.2 and 3.3.5 which provide Instructions for receipt and verification of notification messages and provide directions for Supervising Service Operators (see comment fcr element E.1),

respectively, have been added to the NURr'G-0654 4 cross reference u eltations for element E.2.  ;

l E.3 Content of the initial emergency messages to be A sent from the plant are shown on the "New York State Radiological Emergency Data Form." (some-times referred to herein as the "RECS data form")

Figure 3.3.1, Parts I and !!. The considerations  :

required by NUREG-0654/ FEMA-REP-1, Rev. 1 Supp.1, are included on these message forms.

l Although we recognize that the RECS data form l

contained in the plan (Figure 3.3.1) and Procedure

- OPl? 3.3.1 fAttachment 1) has been developed by l

' New York State for use in receiv(ng emergency '

l l information from other nuclear utilities in the state, it is suggested that reference to the state )

I should be made elsewhere in thLs form rather than  ;

I (n the title header as it is currently shown. This  ;

suggestion la made to avoid confusion in the case of I. Shoreham. j

! i I

l E.4a-n Provisions have been made for followup messages  ! i i from LILCO to offsite response orTanizations which, contain all the planning taformation required by.

4 NUREG-0454/FE M A-REP-1, Rev. 1, Suppl. 1,*

4 except the following1

• lleense e~ emergency response actions underway"(element L4.k):

l l

' Review Comments Based On NUREG-0654/ FEM-REP-1, Rev.1.

Supp.1 Local Offsite Radlolorleal Emergency Response Plan for Shoreham F;nal Regional Assistance Committee (RAC) Review of Revision 9 Dated Aprl! 28,1988 Page 25 of 90 WUREC-0654 Element Review Coment(s) Rating l E.4 a-n * "request for any needed onsite support by (Cont'd) offsite organizationa"(element E.4.m).

These considerations need to be added to the RECS data form shown in Figure 3.3.1 of the plan and Atta:hment 1 of OPIP 3.3.1.

i E.5 The plan establishes a system for disseminating I appropriate information contained in initial and >

follow-up messages received from the !!censee, including the appropriate notification to the broadcast media. >

i The notification system described throughout the plan is termed the Emergency Broadcast System (EBS). This system, which is a network of Long I

!sland and Connecticut radio stations, with Connecticut's WPLR-FM, ident! fled as the Common j Point Control Station, is not the official Emergency l Broadcast System (EBS) for Long Island.

LILCO has secured Letters of Ag7eement with I several radio stations on Long Island and Con-

• necticut which will broadcast eme.4ency informa-tion to the public. WPLR FM has been identifled in the plan as the Common Point Control Station and l

Procedure OP!P 3.8.2 (Sec. 5.1.1) speelfles that the

! Shoreham Local Emergency Broadcast System (EBS) ,

can only be activated by communication with Radio l j Station WPLR in Hamden, Connecticut based on l initiation from the LERO Director of Local l Response (or his authorized representative) or the Coordinator of Public Information. In this review.

we have assumed that thl's !s a backup means for* ,

issuing emergency instructions to the public.  ;

t J,

. . . i Review Comments B: sed On NUREG-0654/ FEM-REP 1, Rev.1.

Supp.1 i

Local Offsite Radlological Emergency Response Plan for Shorehem final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 26 of 90 WL1ttc-0654 Element Review Comment (s) Ratint E.5 However, the Letter of Agreement from WPLR (Cont'd) formallaing an agreement does not explicitly state that WPLR-FM will act as the Common Point

] Control Station. This agreement must be reached to insure coordination of all radio stations desig-nated as transalaston sources of emerTency broad-  :

east messages. ,

These radio stations have a Letter of Agreement i 4

which includes them in the EBS network

'

• WLNG-AM (Sag Harbor, N.Y.)

• WGLI (Babylon, N.Y.)

• WRCN-FM (Riverhead, N.Y.)

• WRHD-AM (Riverhead, N.Y.)

]

• WLIM (Patchougue, N.Y.) .

l

• WICC-AM (Bridgeport, Ct.)  !

• WELI-AM (New Haven, Ct.)

j

• WPLR-FM (Hamden, Ct.)

The plan indicates (see Sec. 3.8, and Procedure OP!P 3.1.2 that State or County officials may ,

decide to use the New York State EmcNency

Broadcast System (with WCBS designated as the t Common Point Control Station) as the EBS system.

t if this occurs, the plan and OPIP 3.8.2 (Sec. 5.1.4) specifies that all the radio stations on the Shoreham  !

local emergency broadcast system (which are all t

included on the WCBS network) will automatically a switch their source signal to WCBS from WPLR j when the WCBS two tone signal is activated. In addition, the plan stipulates that WPLR will direct L j their listeners to tune to WCBS for emergency J

information. In this review it is assumed that WCBS would activate EBS as authorized by state er county ; i offletals and that this would be the primary means -

for activating EBS. (Also see comments for element i

! E.8 in this review.)

I - .

Review Camments Based On NUREG-0654/ FEM-REP 1. Rev.1.

Supp.1 Local Offsite Radiolorleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988^

Page 27 of 90 MURIC-0654 Element Review Cospent(s) Rating E.8 The prompt notification system consists of 89 f!xed A strens, tone activated radlos provided to special facilltles (i.e., schools, hospitals, medical support i hospitals, handicapped facilities, ambulance companies, nursing homes, and major employers, e t c.). EBS, and a mobile public address system.

Marketing Evaluations Incorporated will verify that i

each stren has activated (see App-B-53). ,

Prescripted EBS messages in OP!P 3.8.3 include wording which urges those residents in the planning i areas recommended for evacuation to be "good neighbors" during an evacuation.

i E.7 The draf t messages intended for the public found in A Procedure OPIP 3.8.2 satisfy NUREG-0654/TEMA-l REP 1, Rev.1, Supp. I requirements.

I 4

Draft EBS messages are included in the plan for the i following conditions:

!

• EBS Activation Advisory  !

i e Alert (No release of radiation)

• i

• Alert (Release of radiation)

• Site Area Emergency (No general pub!!c l

protective actions) '

• Site Area Err ergency (Sheltering)

• General Emergency (Sheltering)

• General Emergency (Sheltering and ,

evacuation)

• General Emergency (Evacuation)

• De-escalation of Emergency i

• Termination of Emergency Message , l f

• Test Message for EBS

• l

• Spurious Activation of Prorapt Notification ,

System Message  ;

l

i .. . l

• Review Comments Based On NUREO-0954/ FEM-REP-1, Kev.1. '

, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 28 of 90 l WREC-0654 Element teview Coseent(s) Rating .

i E.7 Although transmlaston of EBS messages are not ,

)' (Cont'd) required, by the plan, during the Unusual Event ECL, OP!P 3.8.2 makes no reference to the Unusual Event. It is suggested that OP!P 3.8.2 be revlsed to  :

i include a statement to that effect.

l j Ingestion pathway EBS menages will be developed at the direction of the Director of Local Response I in conjunction with the Radiation Health i i Coordinator.

l 1 E.8 The Plan states that during an emergency, the A ,

Director of Local Response will work in conjunction l with the Suffolk County Executive. The Plan also j references the involvement of the Federal and State

{ responses. ,

Speelfle Interactions with the Federal. State and '

Suffolk County are outlined in the following Procedures:

i l

• OP!P 3.1.1. Attachment 1: "Director of  ;

j Local Response - Emergency Response ,

1 Action Checklist" l i i

• OP!P 3.1.1, Attachment 10: "Suffolk County  !

l Interface Procedure".

f I '

• OPIP 3.8.2: Emergency Broadcast System 1 Activation. l.

i i

)

j F. Emergency Communleations . j 1 s F.1.a Provision for 24-hour activation of the LERO' A

] emergency response is accomplished via the ,

! Radiological Emerger.cy Commmications System  :

(RECS) line from the SNPS Coneol Room to the j LILCO Supervising Service Operator in the LlLCO I

, - . .,_,n

, n. , .-.--,-.-...._._,---__,,_.-4 - _ - . - _ . - _ _ . - . , _ . , , - - - ~ _ _ - ,

, Review Commen8s Based On NUREG-0654/ FEM-REP-1, Rev.1, Supp.1 Local Offsite Radiolorleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 29 of 90 NUREC-0654 Element Review Conssent( ) Ratins F.1.a Electric Service Operations Section, Hicksville (see (Cont'd) Section 3.3, pages 3.3-1 to 3.3 2 and Figure 3.3.5 and Section 3.4, pages 3.4-1 to 3.4-5). RECS is a dedicated telephone system. This RECS line is monitored on a 24-hour basis and SNPS personnel are responsible for activating the paging system whleh notifies key emergency response personnel that an actual incident has occurred. .

The LILCO Notification Radio System ser<es as the backup communication system to the RECS for communications between the Shoreham Control Room and the LILCO Electric Service Operations Center. Figure 3.3.5 showing the LERO initial notification scheme does not show the LILCO Notification Radio System as a backup for RECS, as described in the text (see comments element A.1.c).

F.1.b Section 3.4 E (page 3.4-4) provides for commun!-  !

cations from LERO to Suffolk County, Nassau County, New York State, and Connecticut via commercial telephone. For Suffolk County and New York State commarelal telephone is considered as ,

backup to RECS. It is noted (page 3.4-1) that beesuse of changes in offices at the New York State Warning Point and Health Department, these agencies do not have RECS telephones. LERO intends to install telephones there when permitted by New York State. Without RECS there is only one communleations link with New York State. Neither the text nor Figure 3.4.1 Identify any backup to commerelal telephone for communications with Nassau County. %1s la not in compliance with ,

federal guidance (NUREO-0454, FEM.A-REP-1, Rev. .

1 Supp.1, page 13), whleh statas that a backup * ,

system is necessary for communleations with '

unparticipating states and local governments.

i i

• Review Ccmments Based On NUREG-0654/ FEM-REP-1. Rev.1,  ;

Supp.1 Local Offsite Radiolorleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1983 Page 30 of 90 WIUEC-0654 Element Review Comment (s) Rating i F.1.b Figures 3.3.3 and 3.3.4 and Procedure OPIP 3.1.1 (Cont'd) Identify the Director of Local Response as being ,

a responsible for notifleation of the States of New York and Connecticut and Suffolk and Nassau ,

Counties. Telephone numbers for New York.

Conneetleut, and Naassu County could not be ,

l located (see comments element A.1.e).

i F.1.c The plan provides for notification of the following A

federal emergency response organizatiotx (see plan.

Chapter 2 pages 2.2 2.2-4e. 2.2-5 Figvre 2.2.1):

1

• FEMA t

• NRC '

e DOE

)

• USDA (by FEMA) l

• DOC (by FEMA) j

• DOD (by TEMA)

• HMS (by TEMA)

• DOT (by TEM A) j

• EPA (by TEMA) i

• U.S. Coast Guard (USCG) l

• FAA ,

• NC3 (by FEMA)

LERO notifies FEMA, USCO. FAA, and DOE (Brookhaven Area Office). The local EOC has  !

commercial telephone links with these federal agencies. In addition, there is a radio link '

(undefined "2f"in Tigure 3.4.1) with the USCG and a I dedicated telephone line to the Brookhaven Area Office. Figures 3.3.3 and 3.3.4 provide that the Director of Imal Response is responsible for.

notifying most federal agencies but that the*

l Evacuation Coordinator is respottsible for notifying, l the FAA and the USCO. It is assumed that NRC

] will be notified in!tlally by SNPS and that NRC )

j personnel will be dispatched to the EOF /TSC as part of NhC's technical response role.

a i'

I l .

.' Review Commen9s Based On NUREG 0654/ TEM REP 1, Rev.1 Supp.1 Local Offsite Rad!olories! Emsrteney Response Plan for Shoreham ,

Final Regional Assistance Committee (RAC) Review of Revision 9 Dated Aprl! 28, 1988 Page 31 of 90 ,

WilREC-0654 Element Review Coreent(s) Rating F.1.e A letter confirmlag that in the event of an (Cont'd) emergency LILCO will contact directly the FAA Regional Duty Offleer at a speelfled telephone .

number has been added to Appendix B (App-B 54).

F.1.d The plan has been modified to include notification A of the Long Island Railroad (LIRR). Procedure OP!P  ;

3.3.2 Page 4 of Attachment 4, instructs the Evacua- l tion Coordinator to contact the LIRR at Site Area  ;

Emergency, or higher emergency classification, and ,

to request closure of parts of the mainline if  ;

evacuations are called for in certain sectors. l Flgure 3.3.4 page 4 speelfles that the Long Island  !

Railroad w!!! be notifled at the Site Area ,

Emergency and/or General Emergency ECLs. The [

LIRR has been added to the notification diagram i shown in Figure 3.3.5. [

Communications between the local EOC in l Brentwood, New York and the licensee's EOF (or  !

TSC) are maintained via the following means (see  !

Figure 3.4.1): i 1

• RECS line [

• commercial telephone l e radio t e dedicated telephone f I

Communications between the local EOC and the I three staging areas are maintained via the following I means:

e commercial telephone ,

l e radio , ,

e dedicated telephone '

l l

l l

4 . *

.' Review Comments Based On NUREG 0654/ FEM-REP-1, Rev.1, Supp.1 Local Offsite Radiolerleal Emergency Response Plan for Shoreham Pinal Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 32 of 90 NURIC-0654 l Element Review Comment (s) Raeing F.1.d Figure 4.1.3 of the Plan shows that the work places i (Cont'd) of 4 of the 5 Evacuation Support Communicators at j the EOC are equipped with each of these three communications links. $1milarly, page 2 of

Attachments 1-3 to Procedure OP!P 4.5.1 show the

Staging Coordinators' offices to be equipped with

! these three communications links. ,

,i  !

Radioloilcal monitoring will be performed by i j person.tel coordinated out of the Brookhaven Area Offlee (BHO) (Attachment 2.2.1, page 2). BHO is i

notifled by commercial telephone by the Supervising 1 Service Operator (see Figure 3.3.5 o' *.te Plan and i Procedure Ol'IP 3.3.5, page 5) not by L(!co '

Customer Services as stated in Attachment 2.2.1, page 2 of 27. This has not been changed since Revision 3 and (a now (neomistent with new revi-I sfons. Figure 4.1.3 of the Plan shows the work area  ;

1 of the BHO liaison at the Local EOC to be equipped 3 j with commercial and dedicated telephones. Page '

4.14 states that there is a radio link from the Local

~

EOC to the BHO field teams with equipment pro-

vided by DOE. It should be clarified that this Is an

! (ndirect !!nk with both the local EOC and the field teams linked to BHO. 7 l F.1.e The provisions for alerting and activating emst- A [

{ gency response personnel for each ECL in each t j response organization are desertbed in Section 3 3- l 1 1-41 Tigures 3.3.2, 3.3.3, 3.3.4, and 3.3.6 Section l l 3.4, page 3.4 5 of the plan and Procedure OP!P i 3.3.2.  !

i . i

) Key personnel are activated or alerted by SNPS l personnel via pager, with the pager 1r.dicating a* l l code that tells the pagee what setton to take.

Other personnel are alerted or activated by means  ;

of a cascading call out system. Procedure OP!P '

j 3.3.2 contains a "Supplementary Notification Call  !

I  ;

1 I

__ . _ . - , __ _ _ _ . , _ _ _.- _ ._ _, . _ _ , . _ . . - ._m --- - _ _ , , _ _ , - - , _ . - . . _ _ - _ _ _ _ . _ - .

. heview Comments Bascd On NUREG-0654/ FEM-REP-1, Rev.1 Supp.1 Local Offsite Rsdloletleal Einergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 .

Page 33 of 90 WILCC-0654 Element Review Ceamenr.(s) htm F.1.e Check 1ht" In Attachment 4. for use by LERO (Cont'd) persor.nel with responsibil!ty for alerting or activating other organizations and individuals who partichate in the response.

LlLCO has c ontracted with four firms (ree App B-4 22 24 and F.70) to provide Emergency Preparedness i Advisors, Radiation Health Coordinators, and

! Nuclear 'irgineers. However, Figures 3.3.3 and 3.3.4 designate Radiation Health Coord!nators and l

4 Emerfency Preparedness Advisors as LILCO employees, rather than as employees of "other organizations."

a F.2 Communications with fixed and mobile medical A

! support fact!!tles are speelfled in the plan as

follows

t Me'e ns i

j

• Ambulance dispatch commercial telephone j stations and radio I

i

• Ambulance drivers radio link via

• dispatch station

]

l

• Hospitals commerelal telephone

and radio links vie

ambulance dispatch a stations and mobile ambulance units.

Figures 3.3.5 and 3.4.1 of the Plan do not show o!!

the communication !!nks for fixed and mobile i medical support facilities. Figure 3.3.5 does not show the radio links to hospitals from ambulance',

depatch stations and mobile ambulance units.

Figure 3.4.1 does not show radio links between hospitals and ambulance dbpotch stations.

Review Comments Bued On NUREG-0654/ FEM-REP-1, Rev.1.

Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 -

Page 34 of 90 NUREG-0654 Element Review Comment (s) Rating F.3 The Plan calls for testing of communications A systems at intervals from weekly to annually (see Section 3.4, pages 3.4-7-8 and Procedure OPl?

3.4.1). These schedules meet federal guidance (see eva! 'tlon criteria H.10, and N.2.a of NUREG-

' 5 4. M A-REP-1, Rev.1, Supp.1).

4 plan has been revised to include the required frequency of stren tests in accordance with NU REG-0654/ FEM A-REP-1, Rev. 1, Appendix 3, page 3-12, Section h(1).

G Public Education and Informatio_n G.la-e LILCO has provided to FEMA for review the I following Shoreham Nuclear Power Station public emergency information materials which are sent as a package to EPZ residents.

• Primary public emergency information docu-ment

• Vest pocket summary of emergency iststruc-tions

• Refrigerator magnet with Zone and EES

• stations ,

Also provided for teview were semples of materials whlah are distributed to 'lon-resloantial facilities:

• Primary public emergency information docu-ment

• Vest pocket summary of emergency instruc-tions

• Wall poster  ;

• EBS sticker All af thesa materials are in draft form.

i

) .

m_ --m. _-_.-m_--, _ - . _ . _ _ , , . _% , _ , _ _ _ _ , , , _ _ , _ , _ _ . _ _ _ . _ ~ . , . , _ _ , _ ,_ . - - - _ . _ _ _ _ , . . ~ . . _ , . _ _ _ _ - _ _

• Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiolorleat Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 35 of 90 NUREG-0654 Element Review Convrent(s) Rati3 G.la-e Section 3.8, pages 3.8-1-3 of the plan provides for (Cont'd) the dissemination of brochures to the public which include the information required by NUREG-0654/

FE!:A-REP-1, Rev.1, Supp.1. The information to be orovided will include:

• educational information on radiation a contact for additional information a protective measures e survey card on special needs of the hand!-

capped.

The Plan ha been revised to include an additional item required by NUREG-0654/ FEMA-REP-1, Rev.

1,Supp.1:

• "special steps to be taken tn describe the role of the offsite response organization vs.

the State and local organizations during the emergency.

The Plan (Section 3.8, pages 3.8-2 and -3) states that educational brochures will be malled to all households and commercial establishments. LILCO plans to use their billing lists for the malling. In

• addition, inserts will be developed for the Suffolk telephone directory which will include the followings l

• Map of 10-mile EPZ/ emergency planning '

zone l

• List of EBS stations e Siren system description / purpose j

• Protective actions the public may be advised ,

to take (sheltering, evacuation)  ; l e Relocr.tlon center locations *

• Items to take along for an evacuation.

I 4

' Review Comments Br. sed On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.I Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988

? age 36 of 90 NUREC-0654 Element Review Consnent(s) Rating G.la-e Local telephone directories w!!! also contain the (Cent'd) 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. Annual exercues are no longer a requirement; biennial exercises are now required. While it is acceptable to conduct annual exercises, if that is not the Licensee's intent then the Plan should be revised accordingly.

The review of the primary public information document, Public Emergency Procedures for Zone A. reveals that it does contain the information needed by incividuals in order for them to protect themselves in the event of a radiological emergency. Unfortunately, problems such as '

disorganization, unnecessary redundancy, the high level of readability, the interruption of emergency action sections by sections of non-emergency information, the inappropriate choice of colors for  !

col' rblind individuals, and confusing maps and graphics seriously hamper the emergency utility of

• the document and make its effectiveness questionable.

The complete review of Public Emergency Pro-ceduret for Zone A is attached as Exhibit 1.

There u no indication the public smergency information material will contain adequate redts-logical preparedness instructions for the agri-cultural community. Federal guidance (FEMA-REP ,

11, pages 7-8) states that public infarmation effortas directed at farmers and food processors within the' i 10-mile EPZ should provide for the dlssemination of instructions at least annually covering the following subjects:

o effects of radiation and radioactive material deposits on the food chain:

Review Comments Based On

• NU REG-0654/ Feat A-REP-1, Rev.1, Supp.4 Local Offsite Radiological Emerger f Response Plan for Shoreham_

Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 h se 37 of 90 NUREC-0654 Element Review Comment (s) Rating G.la-e e explanation of FDA's preventive and (Cont'd) emergency actfon levels:

e identification of preventive protective actions to be taken for water, livestock, crops, fruits and 'iegetables:

e identificattor. of emergency actions to be taken for protecting water, livestock, crops, fruits, and vegetables:

e methods and sources of notifying farmers, ,

food processcrs and distributors of protective actions in time of ememency; and

• where to seek further (nformation, such as NOAA Weather Radio, EDS, or others.

(See comments element J.11)

There is a discrepancy between the plan and the public information brochure as to the number of nursery schools w(thin the plume exposure EPZ.

This discrepancy should be resolved (see comments element 1.10.g).

G.2 Tne plan, Section 3.8, provides for malling written I public education material to re;ldents within the .

plume exposure EPZ. It also provides for making such asterial available for distribution at schools.

Notices will be posted at concentrations of trara-lent population, at local institutions, and at places with public bulletin boards. There will also be Inserts in local telephone directories. Public edu-cation materlaj will be reviewed and updated an-nually. The Emergency Preparedness Coordinator is responsible for coordinate:g the development and dissemination of public education material. The .

public information brochure has not been distri '.

buted. Public information material should not be disseminated mtil it is presented such that it can be used effectively by its Intender

• Ludience (see com-ments element G.la,r).

G.3 The NUREG-0654 cross reference does not include A references to this alement. Appropriate additions

. should be mado.

- . _ _ _ _ __ - E._. ._ ,._. ____ _ _

. Review Comments Brsed On NUREG-0654/ FEMA-REP-1, Rev.1,  !

Supp.1

• Local Offsite Radiological Emergency Response Plan for Shoreham Final Regiona! Assistance Cornmittee (RAC) ?* view of Revision 9  !

Dated Aprl! 28,1988 Page 3a of 90 NUREC-0654 El e; men t Review Comment (s) Rating G.3 The emergency news center (ENC) is to be estab-(Cont'd)  !!shed in the LILCO Training Center, Haupjausge, '

New York. Desk space and telephones wiu Le pro-vided to accommodate the public l mtmation perse mel from New York State and Suff.nx County and the various representatives of the ne' s media.

LILCO's Corporate Communications Center in Hicksville is designated as an alternate ENC facility.

This facility will be set up as the central clearing house for the release of Information received from the utility and LERO representatives (see Section 3.8, page 3.8-4-4a). ,

G.4.a The LERO Coordinator of Public 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

• l Information (to the media) on a timely basis."  ;

1 insufficient copying capabilities at the ENC l resulted in delays in the distribution of hard copies i of EBS messages to the media during the February 13,1986 exercise. \

l No detailed discussion could be found in the plan , l that describe LERO's provisions for reliable and l rapid equipment to reproduce, in hard copy, all ,

appropriate me,ssages for distribution to the ENC s staff. However, since this capab(Itty will be

• evaluated at an exerciss, it ls not necessary to include these details in the plan. Also see comment for element G.4.c in this review.

I j

, - . - - . . , . . , . _ - - .- - - . -n ., ...,--w , , , . . , - - , , .

m-~n,,

- , . -, ------e,, , _ . . - - , . - , _ , . ,_,,._,n,_

.' Review Comments Based On NU REG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Fin 11 Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 39 of 90 NUREG-0654 Element Review Consnent(s) Rating G.4.b The plan has beer. modified to create an additional (Cont'd) position, LERO Spokesperson, and additional staff ,

have been assigned to assure better coordination of Information in the ENC. The LERO Spokesperson is responsible for coordinating the release of int'or-mation working in conjunction with the Suffolk County Executive, or his designee, if he chooses to participate. The LERO Spokesperson will represent L2RO at press conferences. Press releases are to be distributed to utility, government and rnedia personnel at the ENC.

G.4.c The delegation of responsibility for rumor control to I the SNPS orputization is not in compliance with NUREG 0654/ FEMA-REP-1, Rev.1, Supp.1, which ,

requires that the offsite response organfration shall estabilsh coordinated arrangements for dealing with rumors. Onsite procedure EPIP 4.4 does not provide i for managerial responsibilitles in rumor control for LERO personnel and the responsibilities given LERO personnel in Procedure OPIP 3.8.1 do not amount to a coordinating role. Also, in light of the NUREC- ,

0654 requirement for the provision of rumor control

• by offsite emergency response organizations, cort- ,

sideration should be given to det*gna'.ing EP!P 4-4  :

as et offsite (OPIP) as well as pa onsite (EPIP) procedure or, altamatively a separate offsite rumor control procedure should be developed. The LERO plan does not provide information about rumor control staffing, and the number of rumor control telephone lines that will be available and staffed.

Insuffic!ent copying capabilities at the ENC.

resulted in delays in the distrIDutton of informattore, during the February 13, 1986 exercise. Rumor Control personnel were not able to answer questions received from the public because they were not given accurate up-to-date status report?.

I r_

. o

.' Review Comments Basad On NUREG-0654/rEMA REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham FinrJ Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page t.0 of 90 NUREC-0654 Element Review Comment (s) Rating G.4.c The ENC is designated as the central location for (Cont'd) 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.

As provided in OP!P 3.8.1, Section 5.2.4, changes in important emergency information will be elec-tronically transmitted to Rumor Control District offices and call boards via TSO printout (also see OPIP 3.8.1, Section 5.3.4).

The effectiveness of the rumor control system would be evaluated during ati exercise of off-site radiological emergency preparedness.

G.5 LERO will coordinate an annual orientation program i for the news media. This program will familiarize the media with the following:

• Utility emergency plans ,

• Radiation information

• Points of contact for release of public l information in the event of an erriergency  ;

• The location and operation of the ENC. )

l As specified in NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1, the media rust also be familiarized with the role of offsite response organizations vs. the State and local omanizations during the emergency.

H. Emer1rency Facilities and Equipment H.3 The local EOC to be operated and staffed by LERO A personne!' is located at the - LILCO Operations -

Facility in Brentwood, Long Island, New York.

'the Local EOC has desk space and telephones for use by Suffoik County Offletals.

-.n -

1

. 1 Review Comments Btsed On NUREG-0654/ FEM A-REP-1, Rev.1, i Supp.1 i Loes.1 Offsite Radiological Emergency Response Plan for Shoreham Fins.1 Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 41 of 90 NUREC-0654 Review Connent(s) Rating Element The activation and staffing of the local EOC by A H.4 LERO personnel is specified in Section 3.3, page ,

3.3-1; Section 4.1 page 4.1-1-4 and Procedures OP!P l 4.1.1, 4.2.3, 4.3.1, 4.5.1, 4.6.1 of the plan.

The plan states that upon his arrival at the local EOC, the Director of Local Response will establish contact with the LILCO EOF and the New York State EOC (see P!nn, Chapter 4; Section 4.1, A).

in an earlier plan review the RAC stated 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 Warning Point. (See comment for element F.1.b.)

The NUREG-0654 cross-reference in the plan has been revised to include Procedures OPIPs 4.2.3, 4.3.1, 4.5.1, and 4.6.1 as citations for element H.4.

H.7 The two (2) Off-site Radiological Sursey (ORS) A i teams, each consisting of two (2) individuals from DOE RAP (BHO) are provided for in the plan (see Section 3.5, pages J.5-2-2a). These teams will obtain their ORS kits at Brookhaven National Laboratory (BNL), which is located approximately six (6) miles from SNPS.

i Equipment is given for the two ORS teams in Attachment 2.2.1 (the NUREG 0654 cross reference should be changed from page 4.4-1 to Attachment.

i 2.2.1). ',

l In response to a previous RAC comment, the plan hu been revised to delete reference to LILCO ORS kits.

l

Review Comnents Based On NUREG-0654/ FEM A-REP-1, Rev.1, (

Suop.1 Local Offsite Radlological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 42 of 90 NUREG-0654 Element Review Connent(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, and af ter each use. Calibration of instruments will be done at intervals recommended by manufacturers. The plan also makes provision for reserve equiprient.

References to the availability and maintenance of backup field monitoring equipment at the local EOC in Brentwood have been deleted from the plan. It is assumed that DOE-RAP (BHO) teams will provide their backup field monitoring equipment.

H.11 Detailed lists of equipment to be used in the A emergen?y response by LERO are located in the plan in Attachment 2.2.1 and Sections 3.4, 4.1, and 4.4, and in Procedure OP!P 5.3.1.

In response to previous RAC comments, the incon-sistency regarding the ORS kits has been removed since Procedure OP!P 3.5.1 has been deleted.

References to the LILCO ORS kits have been

• deleted.

Radio communications will be maintained between the field teams and the DOE-RAP (BHO) team  !

captain located at thc DOE Brookhaven Area Office i (see page 3.5-2a of the plan). A DOE-RAP (BHO) I team liaison will be deployed to the local EOC in Brentwood to complete the communications between field teams and the EOC.

H.12 Page 3.5-2a of the plan states that field data will be A )

radioed back to the Environmental Survey Function at the DOE Brookhaven Area Office and all samples will be returned to the Brookhaven Area Office, or as directed, for laborstory analysis by DOE-RAP (BHO) or SNPS labs.

Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 l Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 43 of 90  ;

l NUREC-0654 Element Review Corrnent(s) Rating

1. Accident Assessment The plan specifies that LERO will depend upon DOE-RAP (BHO) for radiological field monitoring and dose assessment functions. (Figure 3.5.2 indicates that LlLCO personnel from the Radiological Environmental Monitoring Program (REMP) may support BHO teams in field monitoring and sampling.) Although the review of DOE-RAP (BHO) procedures is outside its responsibility, the

. RAC acknowledges that the DOE-R A P (BHO) systems are adequate to accomplish the field menitoring and dose assessment functions describet, in the plan.

1.7 The capability and resources for field monitoring A within the plume exposure EPZ are to be provided through the DOE-RAP (BHO) resources at the Brookhaven Area Office. The capabilities, mobil-ization, and equipment for these resources are provided in the FRMAP plan for the support of local emergency response plans.

In response to previous RAC comments, the LERO radiological procedures, OP!P 3.5.1, Downwind Surveying, has been deleted from the plan, however, it i,s still referenced in Section 6 of Procedure OP!P 3.5.2 and should be deleted). The plan calls for DOE-RAP (BHO) to use their own procedures. The DOE-RAP (BHO) Team Captain is responsible for collecting the required information for assessment and dose projection and providing the Radiation Health Coordinator with ,the results of the inde '

pendent radiological evaluations performed by the .

DOE-RAP (BHO) Teams (see Procedure OPIP 3.5.2, ,

page 1). ,

l The plan has been clarified and specifies that the equipment inventory in Attachment 2.2.1 is the equipment in the DOE-RAP (BHO) team kits.

l

. 0

.' Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 44 of 90 NUREC-0654 Element Review Coment(s) Rating i.8 The capabilities, equipment and expertise for A accident and dose assessment are found in Procedure OP!P 3.5.2. Section 3.5 of the plan, pages 3.5-1-4, provides that LERO will rely on DOE-RAP teams deployed from the Brookhaven Ares Office (BHO) for offsite radiological survey (ORS) teams. These two-person teams will be capable of being deployed within one hour after notification and will carry the equipment specified in Attachment 2.2.1 of the plan. There ORS teams will provide their own trardportation; however, LILCO vehicles will be available to supplement DOE-RAP (BHO) vehicles (see page 4.4-3 of the plan). At the Alert DOE-RAP (BHO) support personnel will be notified to report to their duty stations (see Figure 3.3.3 of the plan), including the -

DOE-RAP (BHO) Team Liaison who reports to the local EOC. Ccmmunications between the local EOC and ORS teams is via dedicated or commercial tele-phone to BHO and by radio from BHO to the ORS teams in the field (see Figure 3.4.1).

Pages 3.1-1 and 4.1-2 of the plan specify that the Director of Local Response, in conjunction with the '

Radiation Health Coordinator, is responsible for formulating the protective action decisions.

)

A Nuclear Engineer has been added to the LERO 1 emergency response staff (see Figures 3.3.3,3.3.4, 3.5.21 page 3.5-2). This individual is essponsible for evaluating the plant status to determine the poten-tial for a radiological release in making protective action recommendations.

According to Procedure OPIP 3.6.1, Section 5.0, theI Nuclear Engineer is directed to obtain information' from the Radiological Emergency Data Form (see Attachment 5). This form contains all the radio-logical informationmeeded. Prior to r radiological- -

release, protect!ve actions are based upon an I

1 l

1 1

. l

.' Review Comments Based On )

NUREG-0654/ FEM A-REP-1, Rev.1,  ;

Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham .

Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 45 of 90 NUREC-0654 Element Review Coreent(s) Rating 1.8 evaluation of plant systems and an estimate of when (Cont'd) these systems are expected to degrade to the point of causing a radiological release. After a radio- '

logical release has begun, wind speed enters into  :

dose assessment calculations (e.g., Section 5.1.1.d of Procedure OPIP 3.6.1).

I.9 Section 2.2, Attachment 2.2.1, page 3 of 17, states A that the DOE Brookhaven Area Office can provide support to LILCO for airborne radiolodine sampling and analysis to concentrations as low as 5x10E-08 microcuries per cubic centimeter.

Procedure OPIP 3.5.2 (see Section 3.3) includes an explanation and precaution for the mix and decay of radioisotopes released. OPIP 3.5.2, Section 3.3 also includes provisions to verify field measurements with laboratory measurements for samples exhibit-ing activity when release assumptions are not valid.

In response to previous RAC comments, Section 3.3, OPIP 3.5.2, was modified to provide for expedited return of field samples to Brookhaven National Laboratory or another capable laboratory for

• analysis. If other capable laboratories are SNPS laboratories, they are located in New Jersey and Massachusetts. If Brookhaven National Laboratory, which is 6 miles form SNPS, is unavailable and a SNPS laboratory is to be used, provisions for transporting samples to those laboratories were not located and should be addressed (see comments for element C.3).

Previous RAC concerns about Procedure OPIP 3.5.2, Attachments 4 and 5 that the heading of the tables' should be changed to read, multiply results by 10E-6, have been addressed.

i

,,,m__ . , , , . _ , . _ , , . , . , . . - , - ~ . . . , _ ..-__,--_..._,q.,,,.

. c

[ Review Comments Based On NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 46 of 90 MUREC-0654 Element Review Comment (s) Rating

!.9 In addition to DOE-RAP (BHO), LERO can perform (Cont'd) Independent dose assessment using Procedure OPIP 3.5.2. Prov!alons are included in Section 2.3 of that procedure to obtain field monitoring data from either the DOE-RAP (BHO) liaison in the local EOC or from SNPS field teams via the EOF. Section 3.5 of the plan (see page 3.5-2 and Figure 3.5.2) assigns primary responsibility for LERO's capability to the Radiation Health Coordinator.

I.10 Procedures for estimating integrated dose from the A projected and actual dose rates (plume exposure) are found in Procedure OPIP 3.5.2. Ingestion pathway dose estimations for particulate ground deposition are also found in Procedure OPIP 3.5.2 (see Section 5.3 and Attachment 3). Procedu es OP!P 3.6.1 and 3.0.6 contain protective action recommendations for the plume exposure EPZ and the ingestion pathway EPZ, respectively.

The plan adequately describes provisions for relating measured parameters to projected esti-mated dose commitments (see Section 3.5 of the plan, pages 3.5-3-4) and provides for relating ground

• deposition to the need for additiona,1 protective actions.

LILCO has speelfled !n its response to previous RAC comments that the DOE-RAP (BHO) team use the IRDAM dose assessment model on a portable Osborne Computet. LERO uses the ACCDOS dose assessment model described in Procedure OP!P 3.5.2, on an HP-85b portable computer. .

The RAC had found that the use of the IRDAM code

• by DOE-RAP and the availability of the ACCDOS code in the local EOC will provide sufficient backup calculational capability. With these two separate calculational systems available, there is no need for

, a backup hand calculational method. It is noted

, . , , - - , , , - - - - , - - - , - - - - - - - - e . - -

. Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 i Dated April 28,1988 Page 47 of 90  ;

NUREG-0654 Element Review Comreent(s) Rating I.10 that Procedure OPIP 3.5.2 contains a manual (Cont'd) method for backing up the computer method for determining thyroid dose commitment. Provisions '

have been made to obtain field data for input to the ACCDOS code in the local EOC (see Procedure OPIP 3.5.2, Section 5.5.22 et. seq.).

t Two (2) plan changes have been made to address .

Issues identified at the February 13,1986 exercise.

t The plan has been modified in Procedure OP!P 3.5.2 i Section 3.6, to require that when field data are received, the data are identified as actual measurements or as extrapolated data. All extra-polated data are now to be posted under "projected data" on the status board. .

Procedure OP!P 3.5.2, Section 3.5 has been revised ,

to specify that all distances reported by DOE-RAP (BHO) teams are to be recorded in miles.

1.11 Capabilities to locate and track the plume (fleid A i monitoring) are to be provided through DOE-RAP *

(BHO) resources requested by the Brookhaven Area 1 Office. The capabilities, mobilization, respense time, and equipment for these resources are pro-vided in the FRMAP plan for the support of local i

emergency response plans (see Attachment 2.2.1 of the plan). ,

l l

J. Protective Response l l

J.2 The provisions for evacuation of SNPS non-essential' . A site personnel in Section 3.6 (page 3.8-8a) describe

• l the route to be taken. The plan specifies that, depending on radiological or meteorological condl_

l tions, SNPS non-essential personnel would be instruated either to report home or to the Wildwood Substation. The Brentwood District Office is an alternative site if the Wildwood Substation is uninhabitable.

Review Comments Based On NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 48 of 90 NUREC-0654 Element Review Coment(s ) Ratina J.2 The plan also specifies that evacuees from the SNPS (Cont'd) site would leave in the same personal vehicles they used to travel to the site and that evacuation will be via the SNPS access road to Route 25A (see Attachment 5, OPIP 3.6.3).

J.9 EPA's plume exposure and FDA's ingestion pathway A PAGs are given in Section 3.6 (see Table 3.6.1 and page 3.6-2). Current FDA response level tables including all footnotes which are necessary for proper use of the numeric data contained in the tables are found in Attachments 1 and 2 of Procedure 3.6.6.

The Plan describes the means for recommending protective actions to the public (see Procedures OPIP 3.8.1 and 3.6.5), for activating the alert and notification system, and for notifying the public of protective action recommendations (see Procedures OPIP 3.3.4, 3.8.1, and 3.8.2).

A Nuclear Engineer has been added to the LERO emergency response staff. The procedures to be ,

used by this individual are set forth in Procedure OPIP 3.6.1 (see comments for elements !.8 and J.10.m).

The number of dosimetry record keepers at the staging areas has been increased to 5 at Patchougue and Port Jefferson and to 6 at Riverhead (see page 4 of Figure 2.1.1). Selected dosimetry keepers are notified and ordered to repart to their duty stations at the Alerts others are not mobilized until Site.

Area / General Emergency. Further information on'.

the number of dosimetry record keepers mobilized at the Alert and their usignments was not located (e.g., are they assigned to staging areas so that they can set up the dosimetry distribution areas and zero direct reading dosimeters (DRD)).  ;

I e

- - - - - - - . . . , , _ , - - - - -.-- - . , - - - - . , , - . ~ . , - - -----m .,.

j

\

Review Comments Based On l NUREG-0654/ FEM A-REP-1, Rev.1, '

Supp.1 1 Local Offsite Radiologies! Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 i Page 49 of 90 l

NUREG-0654 Element Review Consnent(s) Rating J.9 Procedures OP!P 3 6.2, 3.9.1, and 4.5.1 address (Cont'd) issuance of dosimetry and Ki at the staging areas.

Dosimetry record keepers are to distribute dosimetry to all LERO emergency workers who will  !

enter the EPZ and will brief them. Attachment 6 to OPIP 3.91 has been added to provide a script for the briefings. Dostmetry record keepers are to be assisted by Route Alert Drivers and volunteers in zeroing DRDs. The effectiveness of the additional Dosimetry Record hepers in facilitating dispatch of bus drivers will be evaluated at an exercise.

J.10.a The Evacuation Plan (Appendix A Section I-Preface A 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), LILCO has 8ntegrated the two studies into Appendix A.

Maps illustrating evacuation routes for the designated evacuation zones are ~ provided in Appendix A Figures 9 through 27. The map showing .

evacuation areas is referenced in Appendix A, Page U-5 as Figure 3. However this figure was not contained in the copies of Appendix A that were available for this review.

i Preselected radiological sampling sites are discussed and listed in the plan (Section 3.5 Tacle ,

3.5.1) and keyed to an offsite survey map (Figure 3.5.1). The Figure 3.5.1 map was not contained in the copy of Appendix A that was available for this * ,

review. -

The reception centers have been assigned to facilities at LILC O'r, Operations Centers in l Bellmore, Hicksville, 'and Rof.yn, New York. Pro- I cedure OPIP 4.2.3 prr,vides details on the set up and )

use of facilities at these locations as reception centers for evacue'ss in t'.e event of a Shoreham radiologiest emergency Reception Center loca-tior.s are o. .g!onal map (Figvc 4.2.11. i

i Review Comments Based On NU REG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergenev Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 50 of 90 NUREG-0654' Element Revier Coment(s) Rating J.10.b The plan has been revised to speelfy that some A evacuation zones (i.e., Zones F and E) have been subdivided into subzones for planning purposes.

Zones would be evacuated in their entirety and therefore, a map depleting subarea boundaries within these zones is not necessary.

A map (see Figure 7.1) has been included in the plan f which depicts the population by ERPA projected for 1985 for winter and summer.

J.10.c The means for notifying the transient and resident A population consists of fixed strens (89 units) and EBS. In the event of a partial or total siren fa!!ure, backup notification to the public is available through route alerting using vehicles and a hell-cupter equipped with sound systems (see Section 3.3 page 3.3-4 and Procedure OPIP 3.3.4, Section 5.0, pages 2-16 through 10-16). (See comments element E.6.)

J.10.d Evacuation of population groups with special needs A will be coordinated by the Special Facilities

• Evacuation Coordinator, Vehicles (buses and l ambulances) will be provided to health facilities and to home bound Individuals. A list of special, non-Institutionalized Individuals will be developed from mall-in cards included in a public-information brochure and this Information will be maintained by LILCO (see Section 3.6 page 3.6-7, and Procedure ,

OPIP 3.6.5). The listing to be compiled (OPIP 3.6.5 '

Attachment 1) codes five needs categories:.

ambulance, ambulette, curbside pickup, hearing',

impaired with assistance and hearing impaired requiring notification.

4

.,., _ _ r _

Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 51 of 90 NUREC-0654 Element Review Connent(s) Rating J.10.d The !! sting of noninstitutionalized mobility impaired (Cont'd) individuals will be placed into LILCO computers to allow for updating and quick retrieval. The Special Facilities Evacuation Coordinator will have a print-out of the Invalid / Disabled Evacuation Listing to facilitate notification and the coordination of transportation equipment if relocation of these persons is necessary.

This directory of noninstitutionalized mobility impaired individuals which is maintained by LERO under separate cover would be examined by FEMA at an exercise of off-site emergency preparedness.

J.10.e The provisions for use of K! for emergency workers I are discussed. The plan (see page 3.6.5, lines 10-12) and procedures (see Procedure OPIP 3.6.2, Sections 5.1.lb, 5.1.1c, and 5.1.1d and 5.2) specify that each emergency worker who will enter the 10-mils EPZ will be issued on+ (1) K! tablet prior to being deployed to the f! eld from the staging area to which he reported. -

Procedure OPIP 3.6.2 (see Sec. 5.1.1 and Attachment 4) specifies that emergency workers will be issued K! by the Dosimetry Record Keepers at the Staging Areas and would be briefed not to swallow this KI tablet until told to do so by their LERO supervisor. However, OP!P 3.3.4, page 16c of 16, instructs Lead Traffic Guides to instruct the Traffic Guides to ingest El prior to leaving the Staging Area or when a General En.ergency is declared over the EBS station. In this case Traffic-Guides would be instructed to take E! without an'.

lodine dose equivalent being determined by LERO.

OP!P 3.3.4 should be changed to specify that Traffic Gu! des wculd be instructed to take Elin the field or at the Staging Area by their supervisor.

Review Comments Based On NUREG-0654/ FEMA-REP 1, Rev.1, l Supp.1  ;

Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 .

Page 52 of 90 NUREG-0654 '

Element Review Comment (s) Rating J.10.e Several issues involving emergency worker know-(Cont'd) ledge and use of K! were identifled at the February 13, 1986 exercise. This element was rated inadequate because bus drivers used for school ,

evacuation had not been trained in K! policy and the use of Kl. Sufficient supplies of KI are not available for school evacuation Bus Drivers. In Procedure OPIP 3.2.2 page 3 of 11, there is a state-ment that only LERO EmerTency Workers who will enter the EPZ should be given E!. However, El is not listad as a component of the LERO School Bus Driver Assignment Packet which contains personal doelmetry and record-keeping cards (see Procedure  !

OPIP 3.6.5 page 63 of 75 Attachment 14). El is reported in Procedure OPIP 3.6.2 page 2 of 11 to be Issued to emergency workers mobilized at the staging areas as described in the plan, section 4.5 '

page 4.5.-1). Provisions should be made to supply K!

to LERO bus drivers used for school evacuation since these emergency workers are not mobilized at the staging area %

LILCO's commitment to provide tralning and equip-ment for exposure control to school bus drivers is

• understood. However, it is not evident in the plan how these non-LERO workers are to be informed that they need to initiate the request to obtain training. It would appear that the lasue of training has been resolved as LILCO states that it has I mailed letters offering training to every non-LILCO )

organization mentioned in the LERO Plan that does I not receive training, These letters however could l not be toeated in the materials supplied. Sehool bus drivers are listed in OPIP 5.1.1 (attachment 1, page. l 23 of 37 and page 27 of 37) for training in personne!',

doelmetry and exposure control l

l l .

Review Comments 8: sed On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiologleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 53 of 90 NUREC-0654 Elernent Review Comenent(s) Racing J.10.e The bottles of K! tablets have a thirty-six (36) l (Cont'd) month shelf life (or more if extended by FDA).

Tablets are not to be issued if they are beyond their indicated expiration date. The Radiation Health  ;

Coordinator at the LERO EOC is to be contacted by the Staging Area dostmetry record keepers for replacement supp!!es if the stored K! is out of date (see Procedure OP!P 3.6.2, Section 5.1.la). The .

bottles of potassium lodide are checked every three  ;

months as part of Emergency Equipment Inventory, OPIP 5.3.1 (see Procedure OP!P 3.6.2, Section 3.1 and Procedure OP!P 5.3.1, Section 5.4.2). Pro- l cedures OPIP 3.6.2, page 2 of 11, and OPIP 3.9.1, i Attachment 1, provide that K! Is to be stored in a locked storage area at the Staging Areas. K! Is listed in the equipment inventories for the Staging Areas (see OP!P 5.3.1, page 4 of Attachments 9-11).

J.10.f This element is rated inadequate for the same  !

reason as element J.10.e of this review. Traffic Guides would be instructed to take KI without an lodine dose equivalent being determined by LERO.

OPIP 3.3.4 should be changed to specify that Traffic -

l Guides would be Instructed by their supervisors to '

take El by their s'gervisor (i.e., after a dose  ;

projection has been established). I l

Page 3.6-3 of the plan states that the PAG for use of K! as a thyroid blocking agent is a projected dose l

commitment of 10 rem to an emergency workst's

. thyrold. No provisloc is made for the general i population which is consistent with New York State polley (see letter from J.L. Smith to Harold R.

Denton, N.R.C. S.N.R. C-539 Attachment 1, page; 4-J-10c clarification). The 10 rem PAG is consider -

acly lower than the FDA Final Recommendation of 25 rem or greater projected thyroid dose commit-ment. It would appear that LILCO has taken the 1

. Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 54 of 90 NUREC-0654 Element Review Coament(s) Rating J.10.f more conservative lower limit of NCRP Report No.

(Cont'd) 55 (10-30 rem) or the original FDA draf t recom-mendation (10-20 rem). Current FDA guidance (7/24/85 Federal Register) for use of K!is at 25 rem projected thyroid dose commitmenti not 10 rem as provided in Procedure OPIP 3.6.2 (see Attachment 1, page 1 of 1).

The plan specifles that all LERO emergency workers will be taught about K! and its possible side effects during their training program. The plan states that if emergency workers have allergic reactions to lodide, they will be told not to take the K! tablet issued to them at the staging area.

In response to previous RAC comments, LILCO <

stated that it is company policy to direct anyone suspecting they are allergic to El to see their physician (Section 3.9 of the plan page 3.9-1). If ,

they are confirmed to be allergic to El they are reassigned to positions outside of the EPZ.

Field measurements or dose projection model results must ce used as the bases for determin!ng when the distribution of K! to LERO emergency workers is to be initiated (see Procedure OPIP 3.6.2, Attachment 1, page 1 of 1 footnote).

J.10.g The plan reflects the resources necessary for school I 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 (see comments-element C.4). .

e The public Information brochure for residents llsts nine nursery schools in the plume exposure EPZ that could not be locatert in Procedure OPIP 3.8.5, Atti. hments 3 and 3a. Therefore, the plan does not allot school buses for the evacuation of these nine schools and does not identify their relocation centers.

Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiolorfeal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 55 of 90 NUREC-0654 Element Review Coment(s) Rating J.10.g With respect to school evacuation, the ASLB has (Cont'd) expressed concern that there were not enough buses for a "one wave" evacuation of schools. In OP!P '

3.6.5 Attachment 3a, LILCO identifies the number of buses required for evacuation of all schools in the EPZ, the number of buses that normally service these schools and the number of supplementuy buses required for one wave evacuation (153).

Further, LILCO identifies the names of the bus companies providing these supplementary buses, i.e., from this table a suffielent number of buses are available to transport students in "one wave."

However, the letters of agreement between LILCO and these bus companies are not sufficient to definitely establish that these 153 buses will be available on a "first-call" basis as stated in Appendix A (p. 0-20s). (See also comment for  ;

element C.4 in this review.) Only 5 bus companies have provided firm commitments to supply their l buses on a "first call" basis. Of these 5 companies, l only two are scheduled to provide supplementary buses for schools and these two are only scheduled j to provide 25 of the 153 required supplementary buses. Therefore, the letters of agreement between LILCO and the remaining bus companies need to be

• completed to ensure that buses committed to other uses will be released to LILCO in the event of an emergency.

On page IV-180 of App. A it h stated that Table XWC contains a IUt of the bus companies where buses for school evacuation are obtained. Although the table does not contain this information, it is contained in OP!P 3.6.4 Attachment 3 and OPIP.

3.6.5 Attachment 3a. It is suggested that this',

information be added to Table XWC of Appendix A.

i

Review Comments Based On '

NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 ,

Local Offsite Radiolorleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1983 Page 56 of 90 NUREC-0654 Element Review Comment (s) Rating J.10.g Also with respect to school evacuation, the ASLB (Cont'd) stated that they could not make a finding that a sufficient number of school bus drivers can be relied upon to perform their duties. In response to this, according to LILCO, the plan now provides enough LERO drivers to ensure 150% of total bus driver needs (App. A: 11-200). Trained LERO drivers will l drive the supplementary buses and will be available to back up the regular school bus drivers. LERO ,

school bus drivers will report directly to bus yards as pre-assigned (App. A: 11-20a, OP!P 3.3.3, OP!P 3.6.5 Attachment 14). However, the plan does not enumerate how many school bus drivers are assigned to which bus yards. This numerical assignment should be provided.

The ASLB stated in effect that LILCO should have fulfilled the same planning obligations for possible hospital evacuation as for nursing / adult homes.

Evacuation time estimates for the hospitals have i now been provided. OPIP 3.6.4 also contains revisions to some procedures related to the hospitals and the one infirmary in the EPZ.

l The plan Indicates that hospitals would be i evacuated with vehicles earlier used for evacuation of special facilities. As the hospitals are at the edge of the EPZ this seems reasonable. Based on a count from contracts for ambulances, 63 ambulances and 130 ambulettes are available as resources. The needs are !!sted as:

Ambulances Ambulettes Vans Home handicappe<j 13 9 8 -

• Facilities for 88 111 2 .

l handicapped  !

l f

. Review Commen8s Based On NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 57 of 90 NUREC-0654 Element _ Review Consnent(s) Rating J.10.g *(Included in facilities for handicapped is the (Cont'd) Suffolk inf!rmary need for 1 bus, 65 ambulances, 9 ambulettes).

4 As Suffolk infirmary is not to be evacuated with the general population there are adequate ambulances.

. It is recommended that the utility prepare a comprehensive needs vs resources charts for the vehicles intended for relocation. This would be very I

useful.

Some inconsistencies exist between the number of buses available as shown in the letters of agreement for the Suburbia, Bruno, Coram, WE Transport and l Towne bus companies and the maximum values shown in OPl? 3.6.4 Attachment 3. These should be' .

clarified.

J.10.h The present concept of operations regarding relo- A cation centers for the general population has been to separate the reception and conpegate care func-tions. Reception, monitoring and decontamination are to be conducted by LERO personnel at the LILCO operations centers in Bellmore, Hicksville, Roslyn. Evacuees requesting conpegate care ser-vices 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 4.3-1).

l /rocedure 4.2.3, Section 5.2.3 addresses congegate care centers. It requires that upon an evacuation recommendation for the general public, the Health Services Coordinator is to ensure that ARC has; designated conpegate care centers and that their *

., locations have been transmitted to the reception -

centers. . The Procedure recommends that the Hicksville Conpegate Care Center be one of those l designated. Section 4.8 of the plan states that LILCO will distribute maps to evacuees that show d a 7- --- --- n,,- -

,,-.,,,,,.,-,,-p,----e- , - - - . - . . . , , - . . - - - . - - - . - - , - - , , - - , . , - . , . - m--,, - , , --

Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1

! Local Offsite Radiological Emergency Response Plan for Shoreham t l Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988  ;

Page 58 of 90 NUREC-0654 Element Review Comment (s) Rating J.10.h how to get from reception centers to large LILCO i

(Cont'd) and non-LILCO facilities chosen by ARC as con-gregate care centers. A list of non-LILCO can-didate congregate care centers could nA be located  ;

and in view of ARC's disavowal of tae list in its  !

1984 letter (see App. B-10), it is not clear that the ,

identity and location of non-LILCO congregate care facilities are known to LERO. Evidence of LERO's knowledge of the up-to-date list of potential ARC non-LILCO congregate care centers and maps  !

showing how to get to those faellities from  !

i reception centers should be provided to TEMA.  !

l School relocation centers are to be operated at Nassau County Community College and the Nassau  ;

County Veterans Memorial Coliseum. The Nassau County Executive's authorization for use of these  ;

facilities will be requested. (See plan, sec. 4.2.) i j The designation of these facilities resolved the issue  ;

of school reception centers raised by the ASLB.

l l

The ASLB Ind!cated concern that relocation centers  !

had not been identified for all special facilities. In l Revision 9,' specific reception centers have been Identified for nearly all special facilities in the EPZ *

(OPIP 3.6.5 Attachment 2). Some of the EPZ  ;

faellities will relocate to their own facilities  !

outside the EPZ. Many special facilities will I

, relocate to LILCO fac!!!tles. Whether these latter  !

j facilities would be adequate for a substantial stay j by handicapped persons, nursing / adult home residents, and/or others will be evaluated in an

] exercise.

} Reception centers for hospitals are not spectfled In' the plan. Rather LILCO states that reception -

hospitals will be selected at the time

• of the emergency. A ILst of potential reception hospitals

should be provided in the plan.

l l

l -

i

Review C:mments Based On NUREG-0654/ FEM A-REP-1, Rev.1, l Supp.1  !

Local Offsite Radiological Emer1rency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 59 of 90 NUREG-0654 Elea:ent Review Coment(s) Rating 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. t 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 aircraf t activity, etc.). fNote: Procedure OP!P 3.6.3, Section 5.1 should direct the Evacuation Coordinator to contact the FAA as called for by the plan (see page 2.2-21]). 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 traffic control posts are specified in Appendix A,Section IV, Figure 8, pages IV-52-65.

Provisions for access control, to limit access to evacuated areas, are contained in Appendix A.

Section IV. Evacuation Procedures (see Traffic

• Control, page IV 5).

1

)

J.10.k in response to an exercise issue, the plan has been  !

revised to add a traffic engineer to the staff at the EOC to evaluate any possible impediments to evac- l 1

untion and to make recommendations on necessary changes to evacuation routes in response to poten-  !

, tlal Impediments. However, OPIP 3.6.3 contains no l I

speelfle procedures to be followed by the Traffle; Engineer. Such procedures need to be developed..

(One RAC member dissented from the deelslon that the absence of speelfle procedures for the Traffic Engineer warrants a rating of inadequate.). -

I

l Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offst'te Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 ,

Dated April 28,1983 Page 60 of 90 NUREd 0654 Element Review Conunent(s) Rating J.10k The means for dealing with potential Impediments  !

(Cont'd) to evacuation are addressed in Section 3.6, page 3.6-6 of the plan, Procedure OPIP 3.6.3 and Appendix A, page IV-5. ?rovisions for the removal of cars by tow trucks are adequate.

i The plan discusses the occurrence of adverse weather during evacuation (see Appendix A, '

page 11-4).

The RAC in a previous review of the plan, Indicated ,

that pre-emergency planning for snow removal on '

the evacuation routes should be further developed to include administrative procedure, SOPS, etc.

These procedures were recommended to ensure that the snow removal strategy would coincide with any evacuation scheme that might be chosen.

In response to the RAC recommendation LILCO has identified the routes to be snowplowed during an evacuation in Attachment 18 to Procedure OPIP 3.6.3. The procedure (Sec. 5.1.8 of OPIP 3.6.3) speelfles that local snow removal organizations (i.e., Suffolk County and New York State Departments of Public Works) will be notified of these road clearing prioritlos by the Evacuation Coordinator (or designee) In the event an evacuation recommendation is to be implemented during, or immediately following a snowfall. However, the Towns of Brookhaven and Riverhead are also listed ,

in Attachinent 16 and should also be notified.

Assuming that State and local officials will exercise their best efforts to protect the health and safety of the public, will cooperate with the utility, and ; i have the resources necessary to remove snow (per * '

NUREG-0654/TEMA'-REP-1, Rev.1, Supp.1) and ass"ming that the government units will plow the roads in the priority in whleh they are listed. this --

activity is now adequately addressed.

l I

Rev:ew Comments B sed On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radic ogical Emergency Response Plan for Shoreham Final Regional Ass'. stance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 61 of 90 WUREC-0654 Element Revt ew Consnent(s) Ra,tg J.10.k Procedures for fleid workers, i.e., bus drivers, (Cont'd) traffic guides, etc., have been modified to include instructions to make prompt notifications throvEh their communication network of any potential Impediment. Provisions have been made to issue an EBS message in the event that changes to evacua-tion routes are necessary.

Internal communications within the LERO EOC regarding assessment of a response to evacuation impediments has been adequctely addressed through modification to the procedures (esp. OPIP 3.6.3, Traffic Control). Tae Evacuation noute Coor-dinator is re:ponsible for obtaining periodic updates i from the Evacuation {toute Spotters, and for immediately reporting road imped!ments or other problems to the .:Aff!c Control Coordinator and Road Logistics Crovdinator (see OPIP 3.6.3, Section ,

5.6.2). Lead Traffle Guides (at the staging arees) are to report all traffic problems to the EOC (see OPIP 3.8.3, Section 5.4.10).

l J.10.1 The presentation of time estimates for evacuation A of various sectors in Appendix A, Table XV, page V8 conforms with the preferred format for ,

presenting the data and results for the t' ' '

types of evacuations j Conditions Normal Adverse 1

Permanent population ,

x x Transient population x x  ;

General population x Special population x x Hospital population x x l

The time for confirmation of evacuation is outlined on page V 9 in Appendix A. This reference is noted on Table XV. Summary of Results of Evacuation 4 Times Analysis, in Aependix A. I

Review Comments Bas:d Ou NUREG-0654/ FEMA REP-1, Rev.1, ,

Supp.1 l Local Offsite Radiological Em3rgency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 62 of 90 WR*c-0654 Et ement ReviewComrnent(sj Rating J.10.m According to page 3.1-1 and page 4.1-2 of the plan, A the LERO Director of LocM Response, in conjune-tio 'vith the Rtdlation Health Coordinator, formu-late the protect.ve #9 tion decisions.

Section 3.6 of the Plan, pages 3.6-3-4, discusses the bases for the choices of recommended protective 4 settons. Shieldini; factors for structures based on Sandla Report SAND 77-1725 are used (see Table 3.6.5) as .. ell as evacuation time estimates. Section 5 of Procedure 3.6.1 contain the algorithms used for dosc essessment calculations, whleh ha.a been prr-gammed in the ACCDOS program. The dc.e assessment fuc.etion at the local COC performs

.; these calculations and shows the results to the Radiation Health Coordinator for interpretation.

l A Nuclear Engineer has been added to the LERO l emergency response staff (see comment for element

!.8, above). The Nuclear Engineer is stacioned at the EOF to liaison with SNPS personnel at the EOF or TSC and to evaluate nlant status as part of the development of protective action recommendations (seo Prcicedure O.')!P 2.1.1, page 12b ef 79).

] Coordinated response with the Evacuation l Coordinator has been integrated into the deelslon-making process (see page 3.f-4 of the plan).

J.11 P ocedure OPIP 3.6.6 contains workshms for cal-  !

cul bg whether PAGs have been exceeded for l

mi" ir 3 and 'ther foods (Attachments 3-5).

'n . . a.: ,ec for tu'A and Section 5.1.1.3 (page Ib of .".' '4. ate the , .t.ptive pas can be recom-me ., Je :vis a cocentrations in pasture.

, so "

- ,aound derseltion etivity

• le;w

• e < a a. .e derived response level.

7 E li . + . - U.* $. federal guidance (47 FR 47074,...n ". W '., Ative PA's listed. ~'

l 1

i I

-_._._.._-...._.,_____-_..___,___.U

Review Comments Based On NUREG-0654/FF.M A-REP-1, Rev.1, Supp.1 Local Offsite Radiologica] Emergency Response Plan for Shoreham Final Regionu Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 63 of 90 NUREC-0634 Element Review Coment(s) Kating J.11 Federal guidance (FEM A-R2P-11) states that (Cont'd) written public Instraction material directed at farme:s, food processors, and distributors be disseminated during an emerfency in a timely manner. Reference to dissemination of written

public Instruction material to this audience could not be located (see comrnents G.la-e).

Section 3.6 page 3.6-8 of the plan states that coordination of ingestion exposure pathway EPZ sempling and dose assessment activities will be a responsibility of the LERO Radiation Health Coordinator. The Director of Local Response !=

res;,onsible for decision-making regard!ng pro-te,etive action recommendations (PA Rs). In accordance with the Federal Radiological >

Emergency Response Plan (FRERP), the federal

, government will assist LERO in developing and I

! Implementing Petective actiora with respect to impoundment, decontamination, processing, decay, product diversion, and prese vation. Under the aegis ! FRERP, USDA, DOE and HHS will assist LERO u developing and impimenting the ingestion pathway protective actions.

Procedure OP!P 3.6.6 contains ingestion pathway l procedures, PAGs, protective action (PA) work- l sheets, and agricultural resource information (in  !

Attschment 9-16c) such as listings of dairy farmt,

, duck growers, beef farms, vegetable and fruit growers, food pr> cessing plants in New ork. .

'ecause Connecticut is committed to cdntinr samples and Interdicting food, water, and milk within the Ingestion pathway EPZ, u r2 quired. .

within Connecticut (see App. B-72), it is aswmd a that OPIP 3.6.6 does not contain ugricultural

• I resource information for Connecticut. A reference to the Connecticut rodlological emergency resporue plan should be modes - - -

l

~

1

Review Comment.s Based On NUREG-0654/ FEM A-REP-1, Rev.1,  ;

Supp.1 Local Offstte Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 3

Dr.ted April 24, 1988 l Page 64 of 90  ;

r NUREC-0654 ,

Element Review Conunent(s) Ratins l J.11 Procedure OPIP 3.6.6 lists preventive pas and j j (Cont'd) emergency pas for the Ingestion pathway (see  !

!' Attachments 7 and 8). Discussion of the distinction l between preventive and emergency pas is found on l 1 page 3.6 2 of the plan. pas are not appropriate if  :

the negative social, economic and other health effects outweigh the expected dose reductions.

? Section 1.0 of OPIP 3.6.6 states "It is intended that  ;

sound judgment and personal assessment of the  !

progress of events will be supplemented with the [

guidance found in this procedure." A clearer, more f explieft statement that these negctive factors w(!! 7 be cmsidered in recommending ingestion pathwoy pas is in order.

! The plan is now speelfic in imposing ingestion ,

pathway protective procedures for food, milk, L water and livesteck feed control. This includes USDA support under FRERP. Within New York l State, the primary means of food control would be  !

voluntary, based on radio messages (Jee Plan, ,

Chapter 3, Section 3.6, page 3.6-8 and page 3.6-8a) and telephone calls to food producers, processors j and distributors indicating that LILCO will com-  !

! pensate for food that is not salvagable (see ,

j Procedure OP!P 3.f J. Section 6.4.2.3 and Attach-  !

ment 18). The SNPS 50 mile ingestior, rathway EPZ extends into Connecticut. Upon notification by

] LILCO, Connecticut w!!' provide an ingestion j j pathway emerTency n spense within their l boundaries, as described in a letter from the State 1 of Connecticut. 1 1

1 Procedure 3.6.4 places primary re!!ance on New Y:rk cr.d Contacticut for implementing PARS for .

1 mulatad by LERO (see Section 5.1.3.6). If the state '

! officials are unable to do so, then it is the j responsibilit~ of Radiation Health Coordinator with the cooperation- of"the Environmental--Survey 1 Function, the Dose Auessment Funetton, and the i

.I t

Review Commen%s Bosed On NUREG-0654/FEMAoREP-1, Rev.1, Supp.1 Local Offsite Radlological Emergency Response Plan for Shoreham Final Regional Assistance C'ommittee (RAC) Review of Revision 9 Dated April 28,1988 Page 65 of 90 ,

NVREC-0654 Element Review Comment (s) Rating J.11 DOE-RAP (BHO) Captain to do so (see Section 5.4).

(Cont'd) The Radiation Health Coordinator will formulate appropriate messages and affected facilities will be notified by telephone by a battery of "com-municators." The Director of Local Response will direct the Public Information Coordinator to inform the public of PARS.

The plan correctly names FDA and USDA as the Federal agencies to request a!d regarding food fr.terdiction (Chapter 3, Sec. 3.6, p. 3.5-8, line 47).

Four ingestion pathway maps are now referenced which include all of the 50-mile ingestion pathway

. EPZ (see Procedure OP!P 3.6.6, page in of 50, and page 4 of 50, Sec. 5.7). The plan (see page 3.6-Sa) states that the facilities id9ntified in attachments to Procedure OP!P 3.6.6 are plotted on these maps (only facilities in New York State are listed in these attachments). It is urtclect whether th6 ingestion pathuay maps identify the ?ocation of facilities in Connecticut. There are U.S. Geologlet) Survey topographic maps for New York for recording surveying and monitoring data. The plan now ,

includes references to data sources for water  !

resources, cairies, farms and food processing plants in New York State. Ingestion pathway and j topographic maps of 50-mile EPZ are housed at the i local ECC (see Plun, page 3.6-8a Procedure OP!P

. 3.6.6 Sections 5.1.1.2, 5.1.2.3, 5.1.3, 5.4. 5.4.1, 5.7 5.8, 7.0, and Attachment 19).

Procedure OP!P 3.6.6 makes reference wage 5 of

50) to Procedure OPIP 3.5.3, which does not exist. ,

Review Cemments Besed On

• NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 66 of 90 NUREC-0654 Element Review Coment(s) Ratig ,

J.12 The plan provides for school children being directly I transported to school relocation centers at the '

Nassau County Community College and the Nassau County Veterans Memorial Collseum in the event of an evacuation. School children would be reunited with their parents at the school relocation center.

Procedure OP!P 3.6.5, page 19 of 75, emphasizes I

that this procedure will allow school children to be r reunited with their parents at the earliest oppor-tunity. However, if there has been a radiological release, direct transport to the school relocation centers without prior personal radiological mont-toring and decontamination, if necessary, subjects the school children to risk of unnecessa.y exposure.

For example, contaminated clothes will continue to irratJ! ate the wearer and may contaminate others.

Parents after being reunited with their children may l not drive them to reception centers for personal radiological monitoring and we could not locate in the plan that parents would be instructed to do so.

The LERO Reception Centers are designated as ,

three (3) LILCO fac!!! ties located in Bellmore, ,

Hicksville and Roslyn. The adequacy of these

• l facilities as reception centers will be evaluated at an exercise.

The plan t$ection 3.9, page 3.9-5 and Procedure OPIP 3.9.2 Section 5.5) speelfles that evacuees i arriving at the reception centers will be monitored  ;

• lthin approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. A Traffic Guide will take a smear swipe of the automobile and two moni-tors will check for radiation on all automobl%

, passengers. Attachment 0 to Procedure OPIP 3.9.2, j 4 gives a trigrer level for declaring items con .

I taminated. If no contamination is found above

• j acceptable limits a "clean tag" will be attached to the car. Procedures (OPIP 3.9.2 Section 5.6) are i l also in place for monitorirc incoming bus evacuees j l

and srparating contaminated and non-contaminated persons. All general population evacuees arriving on busei previded by LERO will be monitored on the j bus by monitors working in the aisle of the vehle'e i (see OPOP 3.0.L See::en 5.4.3.9.

• Review Comrients Based On

• NUREG-065477EMA-REP-1, Rev.1,  !

Supp.1 Local Ottsite Radiologleal Emergency Response Plan for Shoreham

~

Final Regional Assistance Committee (RAC) Revww of Revision 9 Dated April 28,1988 Page 67 of 90 NUREC-0654 Element Review Comment (s) Rating J.12 Bus evacuees, private vehicles and passengers that (Cont'd) have contamination above acceptable limits will be directed to a decontamination area. Evacuees will r be directed to trailers where they will be monitored for surface and thyroid contamination in accordance with procedures specified in OP!P 3.9.2. Trallers are equipped with sinks and showers to perform decontamination and paper clothing is available.

All waste water from the decontamination trailers l will be collected and contained in collapsible l storage tanks. These tanks are sized to enable full-flow operations of the trailers for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Upon

! termination of the emergency, all potentially con-l taminated liquid and solid waste will be transported to the plant for disposition (see Section 4.2.B. page 4.2-1). Evacuees will be issued "clean tags" when they have been remonitored and determined r.ot to have contamination above acceptable levels. Pro-l visions are also in place for transfer of evacuees that have non-removable contamination to hospitals (plan Section 3.9, page 3.9-5).

I Monitoring personnel notification and deployment is included as part of the Standby and Mobihration Procedures set forth in OPIP 3.3.3, Attachment 1

• and Attachment 2, part G.b.

1 Monitoring stations and staff espabilities have been

, developed for accommodating over 30% of the est!-

mated EPZ vehicles during the summer period.

j Should the demands for monitoring exceed these capabilltles, plans are in place for developing

] , additional monitoring stations and acquiring trained

} monitors knd equipment from DOE and the Institute, for Nuclear Power Operators GNPO). If, these.

resources are in.uffielent and it is expect d to still*

take more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to monitor the population, the reception center personnel will be directed to monitor only the vehicle and driver-of the-ears-in- - - --

which two or mcre persons traveled together.

These measures are in compliance with Federal

}

l .

- Review Comments Btsed On

- NUREG-0654/ FEM A-REP-1, Rev.1, ,

Supp.1 l Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 2

Page 68 of 90 I l q NUREC-0654 ,

1 Eleuent Review Comment (s) Rating  ;

i J.12 Guidances which allows for the development of ed j (Cont'd) hoc measures if more than 20% of the estimated .

]

EPZ population to be evacuated in a radiological [

j emergency (see Section 3.9, page 3.9-6). [

l Procedure OP!P 4.2.3 provides details regarding the activatfort, layouts with diagrams of monitoring l 4

station positions, and operation of the reception i centers. Procedure 3.9.2 establishes the procedures i i for the monitoring / decontamination of evacuees j (and emergency workers). The effectiveness of the

reception center and procedures used to monitor /

l decontaminate evacuees at these locations will be j evaluated at an exercise.

i j Procedure OP!P 3.9.2, page 13 of 52 calls for an  ;

initial car survey with the HP 210 or 260 probe to be considered contaminated at 0.1 mR/hr (360 CPM) 4 but when later monitoring is performed that i acceptable contamination level is actually higher <

(0.3 mR/hr (1360 CPM] - HP 270) page 26 of 52. j i This procedure is appropriate only if the second t monitoring is done after decontamination of the l

! vehicle.  !

l  ;

! Procedure OP!P 3.9.2 avoids the possibility of a I l contaminated person entering the relocation center.

! "Clean" and "contaminated" tags have been added to 1 Procedure OPIP 3.9.2 (see Attachments 5 and 6) to ,

ensure that potentially 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 mont-

{ toring and decontamination will be !ssued a "clean" tag and be required to sign out before being'

directed to the mass care faellities operated by tha

• American Red Cross at the Relocation Centers.

Aceerding to Procedure OP!P 3.9.23 Section 5,1.5, all completed monitoring and decor tamination J f arms will be collecteo at the reception centers by

] the Decontamination Coordinator and returned tu

the EOC and filed.

, -.,,.,-.__.__.,..,,_.__.-,c._,.._.,.m. - ,,_,mm_ - _ - - ,____._..,,___..._.__..,,_,.,.-%.,,

Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 local Offsite Radiological Emer1rency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 69 of 90 NUREC-0654 Element Review Coment(s) Rating  ;

J.12 Nowhere in the decontamination procedures for (Cont'd) evacuees is it mentioned that decontam(nation efforts should be halted if the skin becomes abraded or broken. No precautions that the decontamination procedure may cause such problems are mentioned (OPIP 3.9.2 pg 15 of $2).

The polley for American Bad Cross involvement in a possibit peacetime acc!(.ent is within the Admints-trative Regulations (ARC 3003) which states in part:

"In disasters with company or owner 1:abl1!ty implications, the customary emergency services are extended on either a mass care basis or to individuals or fami!!es, if such help is not or cannot be provided immediately by the owner of the property..."

This policy has been incorporated into statements of understanding between states end the American Red

! Cross:

"Peacetime _ Radiolotrical E:nerteney/ Nuclear Accidents" "In the case of peacetime radiological emer-

gencies/ nuclear accidents, which have company or owner implications, the American Red Cross .

{ will conduct shelter and feeding operations in ,

centers and fact!!tles designated in advance by I the (nr.m e of agency) under arrangements '

! worked out among the (naine of agency), the American Red Cross and the officials or owners ,

i of the buildir.g."

j Red Cross Responsibilities l

1. Sheltering and feeding of relocatees in shelters-and feeding centers at ! cast a ten mile radius'. I from the point of the nuclear emergency. l l

I 2. To thJ extent that it has staff available beyond ~

Its primary r'esponsibilit!'es, a'ove, b assist i government and other agencies responsible for l aid stations. registration of relocatees, t

communications and transportatten.

4

. Review Cemmon%s Based On

. NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 70 of 90 NUREG-0654 Etement Review Comment (s) Rating J.12 At this time, LILCO does not have written (Cont'd) agreements for a suff!cler.t number of buildings beyond the ten mile radius for sheltering and feeding of relocatees.

Special populations will be monitored and decon-taminated *.t reception faellities located at the Emergency Worker Decontamination Facility (EWDF) in Brentwood and the Staging Artas in Port Jefferson, Patehougue and Riverhead. According to Figure 2.1.1, the following monitoring and decon-tamination personnel are assigned to these locations:

• Brentwood Emergency Worker Decontamina-tion Facility - 45 Monitoring /decon. personnel

• Port Jefferson Staging Area - 5 Dostmetry Record Keepers t

• Patchoque Staging Area - 5 Dostmetry Record Keepers

• Riverhead Staging Area - 6 Dosimetry Record Keepers

• All Health Care speelal facilities including Nursing / l Adult homes are assigned to the predesignated  :

t monitoring locations and to predesignated reloca-2 tion (i.e., congregate care) centers. The speelal populations are usigned to the monitoring locatfora as follows:

Faellity Speelal populations (Number) j l

4 Brentwood EWDF 1641* -

Port Jefferson Staging Area O Patchougue Staging Area 483*

Riverhead Staging Area 186 .

• includes preschool populat'.on assigned to these faellities.

1

. I

Review Comments Based On NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1 Loct! Offsite Radiolorleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28, 1988 Page 71 of 90 NUREC-0654 Element Review Corsnent(s ) Rating

' J.12 According to information provided by LILCO with  ;

(Cont'd) its submission of Rev. 9, sufficient perso nel are i available to monitor the special population evacuees  ;

) at approx!ma'.' sly the same rate at which they arrive st the monitoring locations.

l j in the event it becomes necessary to evacuate i hospitals, these populations will be monitored at .

reception hospitals "to be selected at time of l emergency" (see OP!P 1.6.5, Attachment 2). Al- '

though it would be preferable to have hospital reception centers preassigned in the procedures.  ;

current plans to arrange these facilities at the time j of the emergency are reasonable in view of the fact l l that any evacuation of hospitals would be carried l' i out under the direction of the Hospital Administra- '

tor (s) responsible for those instita ,lons. (See comments element J.10.h.) .

{

1 in the event it becomes necessary to evacuate the l l approximately 28,000 public, parochial and nursery i school children in the Shoreham EPZ, school l I relocation centers have been designated at the  !

1 Nassau County Community College and the Nassau i l County Veterans Memorial Coliseum in Uniondale. -

l These two facilities have a combined capaelty of I j appraximately 32,000 and would be activated to i hold the children until they can be reunited with

! their familles. The Director of Local Response will '

} be responsible for contacting the Nassau County i Executive and obtaining permissloa to use these

) facilities if needed.

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. Review Comments Based On

. NUREG-0654/ FEM A-REP-1, Rev.a.

Supp.1 Local Offsite Radiolorleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 72 of 90 NUREC-0654 Element Review Consnent(s) Ratina E. Radiological Exposure Control E.3.. Section 3.9, page 3.9 2 of the plan states that all A emergency response personnel will be lasued self-reading pocket dostmeters (typically 0-200 mR and 0-5 R) and TLDs. All emergency workers with the exception of school bus drivers report to emergency worker staging areas, or other facilities where Record Keepers maintain emergency worker dose records. 'the LERO Dosimetry Coordinator is responsible for maintaining exposure control records on a 24-hour per day basis.

The plan clarifles that the dosimeters will be zerced at the staging areas, and that the chargers will not be taken into the field (Chapter 3 Section 3.9. page 3.9-2, !!nes 6-12).

Procedure OPIP 3.9.1, Attachment 7 Indicatn that dosimetera must be zerosd and then distributed.

However, in Procedure OPl? 2.1.1, p.14 of 70, Record Keepers, parog.'etph C, reference to the Record Keepers calibrating dosime:ers should be deleted, o.s they do not have the capability to ,

perform such calibentions, rather, they zero the dosimeters.

Procedure OP!P 3.9.1 now correctly states that emergency workers are directed to notify super-visors at 3.5R and to leave posts at 5R.

The numbers and types of dosimeters and the numbers of TLDs available are listed in the Inventory master listing in OPIP 5.3.1 (e.g., on page ;

26 of 90, for the Patchougue staging atta). It would .

appear that an adequate number of thtrmo-luminescent detectors and low- and mid-range dostmeters are available for all LERO workers. - . .

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Review Comments B sed On NUREG-0654/ FEMA REP-1, Rev.1, Supp.1 Local Offsite Radiolorteal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1984 Page 73 of 90 NUREC-0654 '

Element Review Coment(s) Rating

? ,

K.3.a Severe.1 issues involving cmergency worker ,

l (Cent'd) knowledge and use of dosimetry were Identified at

) the February 13, 1986 exercise. This element had

, previously been rated inad_quate because dosimetry and training were not provided to the Bus Drivers used for school evacuation.

i (1) Bus Drivers used for school evacuation i should be trained in the use of dosimeters.

(2) Adequate supplies of dosimetry should be provided for Dus Drivers used for senool 2

uncuation.

] LILCO's commitment to provide training and equip-ment for exposure control to school bus drivers is j understood. However, it is not evident in the plan '

how these non-LERO workers are to be informed

. that they need to initiate the request to obtain training. It sould appear that the Leeue of training l has been resclved as LlLCO states that it has ,

mailed letters offering training to every non-LILCO (

) organintion mentioned in the LERO Plan that does  :

i not receive training. These letters however could '

l not be located in the meterials supplied. School bus l

drivers are listed in OP!P 5.1.1 (attachment 1, page

) 23 of 37 and page 21 of 37) for training in personnet j dosimetry and exposure control, j i The LERO School Bus Denver Procedure. OPIP 3.6.5,

] Attachment 14, provides for distribution of 4 dosimetry (but not EI) to LERO School Bus Drivers

! at bus yard dispatcher's offices. Each LERO School i

! Bus Driver is to obtain there an Assignment Packet. '

i that includes two DRDs, a TLD, and an Emergency *, l

Worker Dose Record Form. This procedure (step 5) '

f directs them to check the readings on the DRDs and i

to zero the DRDs if necessary. Each bus yard is 4

e

Review Commen8s BGsed On NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 74 of 90 NUREC-0654 Element Review Coment(s) Rating H.3.a equipped with two DRD chargers. As some bus (Cont'd) yards provide up to 150 buses, it !s not clear that two chargers are sufficient. There are sufficient inventories at the bus yards to supply dosimetry to one emergency worker per bus (see Procedures OP!P 5.3.1, Attachments 13-32 and OP!P 3.6.4, Attachment 3). If many buses have both a LERO and a regular School Bus Driver the inventory may be inadequate. It is not clear that regular School

, Bus Drivers are given procedures similar to the LERO School Bu.s Driver Procedures so that they

have been refreshed on radiological exposure control. School bus drivers have been included in the LERO classroom training matrix (OPIP 5.1.1, Attachment 1), but they are not included in the drill matrix for do Vetry/ exposure (OPIP 5.1.1, Attachment 2.)

K.3.b The LERO School Bus Driver Procedure. OP!P 3.6.5, 1 Attachment 14, dirent them to report directly to bus yards to obtain an Assignment Packet that  !

Includes dosimetry and an Emergency Worker Dose Record Form (see Procedure OPIP 3.9.1,

, Attachment 2). OPIP 3.8.5, Attachment 14 does not -

instruct School Bus Drivers to read their doelmetry approximately every 15 minutes while in the field.

l The EmerTency Worker Dose Record Form does not 4 do so. School Bus Drivers do act receive brieftr.gs i from Dosimetry Record Eeepers that instruct them i to do so. Page 3.b2 of the plan Indicates that emergency workers are instructed to read their DRDa at 15 minute intervala; however, we could not locate procedures for ensuring that School Bus , l Drivers read their doelmeters at such frequencies. .

School Bus Drivers have been included in the LERO

• classroom training matrix (OP!P 5.1.1. Attachment 1), but they are not included in the drill matrix for dosimetry / exposure (OPIP 5.1.1. Attachment 2.)

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Review Cemments Baed On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 75 of 90 NUREC-0654 Element Review Coernent(s) Rath K.3.b Section 3.9, page 3.9 2 of the plan states tnat each (Cont'd) person performing emergency service functions inside affected areas are (sic) Instructed to take dcsimeter readings at 15-minute Intervals.

Emergency Worker Dose Record and Emergency Werker Exposure Record forms are contained in Settlon 3.9 and the former is 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 School bus drivers have been included la the LERO  !

elassroom training matrix (OP!P 5.5.1, attachment 1), but they are not included in the drill matrix for dostmetry/erposure (OPIP 5.1.1, attachment 2).

While LERO has established a dectslot chain, they have not made adequate provisions for giving training to those non-LERO emergency workers and providing them with knowledge in regard to con- .

tacting their supervisory personnel so that proper authorization gets to them.

The plan provides for emergency workers to be trained to inform their immediate supervisor if the -

reading on their low range dosimeter goes beyond ths 200 mR that it will register and read the 0 5 R dosimeter. At a reading of 3.5 R, workers are to inform their immediate supervisor, request further instructions and prepare to be relieved: when directed by their superior or a reading of 5 R, they will return to the Emergency Worker Decontamina-

tion Center (pages 3.9-2 and 3 of the plan). Pro-l cedure OP!P 3.9.1. Attachment 2 correctly directs ,

an emergency worker to leave the EPZ immediately .

If the 0-5R dosimeter reads 5R or greater. The plan

• should be clarified to remove the impreuion that an emergency worker could be authorized by an immediate super'. hor to remain in the EPZ with an off-scale 0-5R dosimeter. The Director of Local Response, as advised by the Radiation Health 4

Coordinator, is responsible for authorizir.g expo-sures in excess of the EPA General Public PAGs.

The pidFM 3 e 9 <eep>g with EP A PAGs.

Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiolorleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of havision 9 Dated April 28,1988 Page 76 of 90 NUREC-0654 Element Raview Coment(s) Rating K.4 It should be noted that the plan Indicates with (Cont'd) respect to some emergency personnel (local law enforcement, fire, and snow removal personnel ,

reference page 2.2-7) that if no training is provided i

i prior to an emergency event, LERO will designate j LERO personnel trained in radiation fundamentals and dosimetry to accompany personnel performing their duties within restricted areas. These LERO personnel will provide dosimetry and ensure that i they do not receive doses in excess of the Pro-tective Action Guides for the general public. The plan does not explicitly state that this provision  !

applies to school bus drivers however.

K.5.a The plan speelfles use of CPM for all"probe shield A open" readings (see Table 3.9.1).

Action levels for determining the naed for decon-taminating individuals and proper. .e adequately speelfled. Procedure OPIP 3.9.. and Table 3.9.1 of l the plan provide consistent guidance.

{ i j K.5.b Page 3.9-4, line 39 and page 4.3-2,!!ne 5 of the plan A*

i and Procedure OP!P 3.9.2 (Section 5.8.1-C) state  !

that any emergency worker witL .hyroid contamina-  !

tion resulting in readings in excess of .13 mR or 150  !

CPM, will be sent to a designated hospital for fur- l l ther medical treatment. The plan consistently uses i j 0.13 mR or 150 CPM as the thyroid contamination i level. j I Some information and procedures for deallag with contaminated solid and !! quid waste are contained In' .

the plan. (Section 5.0, 5.1.7 - 5.1.9) (OPIP 3.9.2, '

section 5.9.91 OPIP 3.10.11 Section 4.2.b). The

effectiveness of these procedures will be evaluated

In an exercise.

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Review Commentss Based On NUREG 0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radloterical Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 77 of 90 NUREC-0654 Element Review Comment (s) Rating 4

K.5.b No (itstructions are given for what to do with an (Cont'd) *ssentfal car which (s contaminated above the !(mitJ after 3 decontamination attempts.

The decontamination equipment list is contained in attachment 4 of Procedure OPIP 5.3.1, and the plan references this list (see Chapter 4. Section D. 4.3, pages 4.3-1 and 4.3-2). .

, First ald kits have been placed at the Emergency l Worker Decontamination Facility (EWDF) and at the primary Relocation Centers, Reception Centers, and vehicles (OP!P 5.3.1, attachment 4: Chapter 4 Section 4.3, A, page 4.3-1, lines 28-32 ar.3 page

. 4.4-3, lines 18-20; OPIP 5 3.1. Attachments 2, 7 and 12).

i L. Medical and Public Health Support l

L.1 Provisions are adequately described for hospital and A medical services with the capability for handling contaminated or exposed persons, j The Brunswick Hosoital Center in Amityville is the -

2 primary hospital for contaminated, injured members l of the public and the V.A. Medical Center in i Northport and the Nassau County Medical Center in  ;

, E.ast Meadow will be used as backups. LERO l workers can also be assigned to Central Suffolk ,

Hospital. Additional Long Island facilities that are accredited for treatment of contaminated Indivi-

, duals are listed in Procedure OPIP 4.2.2. Attach- i ment 1 (see also Section 2.2 page 2.2-8 and Sec. 3,7 '

pages 3.7-1 and 3.7-2). '.  !

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Review Commenss Based On NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated ' April 28,1988 Page 78 of 90 WURIC-0654 Element Review Connent(s) Rating L.1 Brunswick General Hospital has agreed (App. B-86) 4 (Cont'd) to act as the primary facility for members of the I general public who become injured and contam- '

., insted. Central Suffolk Hospital (App. B-75) has l agreed to serve as the priraary care facility to treat ,

injured or injured and contaminated Individuals from .

j SNPS or LERO (see plan Section 2.2 page 2.2-8).

L.3 A new list of hospitals capable of treating A

contaminated / Injured Individuals, with the number of beds available, has been incorporated in Procedure OPIP 4.2.2 (Attachment 1, pages 1-7).

j The plan has been revised to include in Section 3.7, j reference to the list of hospitals capable of treating contaminated / Injured Individuals contained in

l Procedure OP!P 4.2.2, Attachment 1.

L.4 When contaminated / Injured persons are not located A at a LILCO facility, the Emergency Medical /Public Service Coordinator will contact the police or local volunteer ambulance and rescue company (OP!P

) 4.2.2 page 5 of 13). A list of ambulance and rescue *

] companies is contained in Procedure OPl? 3.1.1 Attachment 11, page 1 of 1 (see also 3.7 page 3.7-1). The assumption that local police, ambulance, and rescue units will respond is in accordance with i Section !.D. of NUREG-0654/TEMA-REF-1, Rev.1, Supp.1.

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Review Comments Based On NUREG-0654/ FEMA-REP-1, Rev.;,

Supp.1 Local Offsite Radiolorleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Resision 9 Dated April 28,1988 Page 79 of 90 NUREG-0654 Element Review Cournent(s) Rating M. _

Recovery end Reentry Planning and Postaceldent <

Operations M.1 Section 3.10, pages 3.10-1 and 2 and Section 3.11. A i pages 3.11-1 and 2 of the plan and Procedure OPIP 3.10.1 discuss Re-entry and Recovery. Procedure l OP!P 3.10.1 provides for participation of the following agencies / organizations on the Recovery

, Action Committee if they are available. i

• FEMA representative

• DOE representative l

• EPA representative j

• State representative

!

• County representative i

The Manager of Local Response will chair the Recovery Action Committee that will assist !. ate  ;

, and county officials to plan and trJplement actions l for the restoration of the affected to their pre-emergency conditions. Recovery operations includes determination of whether all utilities are j functioning, that food supplies are adequate, and that the evacuation effects on public health and

! sanitation are mitigated.

• General plans for recovery and reentry have been

! developed which take into account the ergineering evaluation of plant conditions as well as radiologleal conditions (see comments for elements 1.8, J.10 m.

and 0.4.b). The plan includes a Nuclear Engineer who will review plant conditions (see Procedure i OP!P 3.10.1, Section 5.0, 5.11, g). This individual is

, assigned u a member of the Recovery Action, Committee and is responsible for emerTency status, evaluation of the plant. ,

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Review Comments Bued On NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1 Locit! Offsite Radlological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated Aprl! 28,1988 Page 80 of 90 NUREG-0654 Element Review Coment(s)

Rating M.1 Procedure CPIP 3.10.1, Sections 5.4.4 and 5.4.5 (Cont'd) considers procedures for recovery when sheltering may have been recommtnded.

EPA is listed u the cignizant Federa4 agency responsible for coordinat.ng the intermediate and long term radlological monitoring af ter the initial phases of an emergency (see plan, Chapter 3, Section 3.11, page 3.11-1, !!nes 34-39 also, Procedure OPIP 3.10.1, Section 5.3.8).

M.3 According to the Plan (see Section 3.11 P. 3.11-1-2), A the Health Servlees Coordinator has primary responsibility for coordination with State and county officials, for recommending protective actions for overseeing the total related radiological program and for modifying, relaxing and discon-tinuing protective actions. Long term operations ,

are comprised of the estat:11shment of Federal assistance, a radiation monitoring program and a medical follow-up after protective actions are relaxed.

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The Director of Locti Response is responsible for

• Initiating and approving recovery /re-entry opera-tions and directs the formation of the Recovery Action Committee. The Manager of Local Response <

is the Chairmsn of the Recovery Action Committee l and Is responsible for implementing recovery /re-entry procedures and for managing communicatiens (see Procedure OP!P 3.10.1, Sections 2.0, 5.1, 5.2, 5.3.4 and 5.3.7).

Review Comments Based Oa NUREG-0654/ FEM A-REP-1, Rev.l.

Supp.1 Local Offsite Radlolorleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1948 Page $1 of 90 NUREC-0654 Element Review Coment(s) Rating t

M.3 Procedure OPIP 3.10.1 provides deelston-making (Cont'd) ruldance for the Initiation of recovery operations including the implementation of evacuee re-entry into evacuated areas and guidance for the informa-tion and operation of the Recovery Action Com-mittee. Initial recovery actions include Ingestion Pathway Samp!!ng under the director of the Radla-tion Health Coordinator.

i j M.4 Section 3.10 of the plan and OP!P 3.10.1, Section A

$.3.2, provide for the completion of radiation field surveys to determine whether contamination levels in an evenated area a:e within acceptable limits for reentry of the publ!c into formerly .

! contaminated areas. '

The plan has been revised to include a procedure for j calculation of total population dose, and is  :

referenced in Chapter 3. Section 3.10, W/ e, page j 3.10-2. Procedure OP!P 3.10.2 documents the  :

procedure to be used by the Radiation Health ,

Coordinator to calculate total population dese.

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N. Exercises and Dritis N.1.a The plan describes the purpose, scope, frequency A and procedures for exerelses (Sec. 5.1, p. 5.1-3 See.

5.2 p. 5.2-1 and OPIP 5.1.1, pp.19 and 20). The 1 plan states that an exercise shall simulate an '

emettency that results in offsite radiological esleases which would require the overall emergency  :

! response capabilities of SNPS and LERO.

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4 Review Commeats Based On [

NUREG-0654/ TEM A-REP-1, Rev.1, t Supp.1 i Local Offstte Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 t 3

Dated April 28,1988 l j Page 82 of 90 l WAEC-0654 gement Revie n comment(s) Rating

)i f

] H.1.a The plan lists the following emergency response l

(Cont'd) capabilities to be tested, at a minimum, in an l exercises command and controls communleations i radiological assessment protective action j recommendations; public Information activities

'

fire, medical, security and traffle control activities l initial notifications and recovery and reentry (OPIP l 5.1.1, p. 2 0). "Each exercise will test the overall [

emergency response capabilities of SNPS respond to l an emerteney that results in offsite radiologleal  ;

releases and will be conducted as set forth in NRC  ;

and TEMA rules"(OPIP 5.1.1, Section 5.3.2, p. 20).  !

"An emergency response exerelse will be conducted  !

prior to adoption of this plan and at least once every two years depending on federal guidelines" t (Section 5.2, p. 5.2 1).

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N.1.b The plan does establish the means for mobilizing A {

LERO personnel and resources that would be l adequate to verify the capa'cility to respond to an  !

aceldent scenario requiring response. The plan j states that an exerelse will demonstrate LERO's j capability to Interface with non-participating State

• l and local governments, but does not include the use l

of stand-Ins for the anticipated State and local  !

response (OP!P 5.1.1, pp.19 and 20). The LERO [

Emergency Preparedness Coordinator is to arrange i a post-enereise critique for key observers and l partielpating personnel (OPIP 5.1.1, p. 21). The plan l calls for varied exercise scenarios (includig time, '

season, and unannounced exercises) as requested by this element (OP!P 5.1.1, p. 20). ,

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l Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiolerleal Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 83 of 90 WREC-0654 Element Review Ceseent(s) Rating N.2.a The plan (OP!P 3.4.11 OP!P 5.1.1, Sec. 5.2.5 and A 5.3.1) adequately addresses the testing of communication systems with the following:

• Shoreham and LERO - monthly.

• Federal emergency response organizations and states within the ingestion pataway - -

quarterly,

• The nuclear f acility (SNPS)- annually.

• The State and local (LERO) EOCs - annually, and

• Local (LERO) radiological monitoring teams -

annually.

The plan provides for drills of communication with the State and local EOCs, if practicable.

N.2.e Page 5.2-1 of the plan and Procedure OPIP 5.1.1, A -

Section 5.3.le adequately provide for a Medical drill ,

to be conducted annually in conjunction with the '

annual exerelse.

N.2.d Page 5.2-1 of the plan and Procedure OPl? 5.1.1, A Section 5.3.16 provide for Radiolotteal Monitoring drills.

l The DOE RAP (BHO) Team and radiological assessment personnel will participate in the annual, drill. The procedures do not speelfleally state that.

all sample media will be collected and analyzed as' identified by this element. Nevertheless, LERO will conduct the Radiological Monitoring drills in accordance to federal regulatory guidelines (OPIP 5.1.1. Section 5.3, p.18).

1

. Review Comments Based On

. NUREG-0654/ FEMA-REP 4, Rev.1, 4

Supp.1 Local Offsite Radiological Emerzeney Response Plan for Shoreham i Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1984 l Page 44 of 90 t WUREG-0654 j Element Review Consent (s) Ratins I

i N.2.e Page 5.2-la of the plan and Procedure OPIP 5.1.1 A ,

i Section 5.3.1d adequately provide for Health -

1 Phystes dt!!!s to be conducted semi-annually.

i I N.3.a f Procedure OP!P 5.1.1., Section 5.4 adequately A provides for exercise sevnarlos to include the (

! following l

• The basle objectives:

I

• The date(s), time period, place (s) and ,

participating organizations: i i e

• The simulated events:

• A time schedule for real and simulated

! Initiating events i

l

• A narrative summary describing the conduct l l of exercises or drills:  ;

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• Arrangements for scenario aaterial to be i provided to offletal observers. l i

N.4 Procedure OP!P 5.1.1, Sections 5.2.6 and 5.3.2 A i

establishes that the LILCO Emergency Preparedness i 1

Coordinator (EPC) is responsible for having l J

exercises (and drills) critiqued by Federal observers l and LERO controllers as soon as praetleable i following the exercise (or drill). Formal evaluations  :

l (reports) will result from these critiques.  !

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Review Comments Based On NUREG-0654/ FEMA-REPol, Rev.1.

Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Tinal Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 85 of 90 NUREC-0654 Etement Review Cormoent(s) Rating N.5 Procedure OPIP S.1.1, Sections 5.2.6 and 5.3.2 A adequately provide for LERO to evajuste observer and participant comments and implement corrective actions. The LILCO Emergency Preparedness Coordinate? Is responsible for incorporating plan changes indicated as a result of the drills and annual exercise critiques.

Procedure OP!P 5.1.1 specifies that the comments from Federal observers will be available at a post-exercise critique and in the post-exercise assessment which summarizes the evalustion of 'the Federal Observers.

N.6 Section 5.1 of the plan states that LERO w!!! offer A .

training to and shall attempt to involve the State and local governments in the exercises and drills, but their participation is not required.

O. Radiolorleal Emerteney Response Traln'ng 0.1 The LERO Classroom Training Matrix (OP!P 5.1.1 A Attachment 1), details emergency response training

• for LERO personnel through a training program consisting of 20 modules the speelfic toples of which are iteml ed in Section 5.1.2 of the pro-cedure; lasues covered in each module are !!sted in Attachment 3 of OP!P 5.1.1. Also, as discussed in Section 5.1, page 5.1-1. LILCO would avail itself of a number of federally sponsored training courses, some given by FEMA, some by NRC, and some by EPA. Training of workers to handle injured / con .

taminated individuals has been incorporated in the* ,

,lan.

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. Review Comments Based On NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 86 of 90 NUREC-0654 Element Review comunent(s) Rating 0.1 Procedure OPIP 5.1.1, Section 5.1.5 provides that (Cont'd) the records maintained by LILCO will show the names and emergency position of Individuals tralned, sessions / drills completed, and the date on which they completed training.

Procedure OPIP 5.1.1, Section 5.1.3 states that Emergency Response Traininit will be offered to all members of LERO support orgsnizations, such as the U.S. Coast Guard helicopter personnel and I

ambulance personnel.  :

EBS personnel, and ambulance company personnel, rad!o station personnel, commercial school Bus Drivers, and EPZ telephone survey personnel will be provided with trainlag speelfic to their LERO function (see OPIP 5.1, Section 5.1.3).

)

Training and information sessions will also be offered annually to other organizations such as schools, hospitals, nursing homes, special facil'tles

and the American Red Cross, which may be called on to take actions during an incident at SNPS (see

page 5.1-1 of the p'.an).

• O.4 Procedure OP!P 5.1.1 establishes a training program A  !

for emergency response personnel which is keyed to i 4

speelfic emergency response training topics. In  !

accordance with NUREG-0654 FEMA-REP-1, Rev.

1. Suppl. 1, the following subelements of this planning criteria have been reviewed as follows: *

O.4.a Training will be provided to directors or , '

coordinators who are LILCO employees. In .

response to an earlier RAC comment.

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training module 11 (Contaminated injured Individuals) is now provided for personnel assigned to the following positions:

Emergency Medical Coordinator, Hospital Coordinator, and Ambulance Coordinator.

Review Commentss Based On NUR2G-0654/ FEMA-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emerirency Response plan for Shoreham Final Retrional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 87 of 90 NUREO-0654 Element P.eview Conenent(s ) Rating 0.4 0.4.b Training is provided for accident assessment A (Cont'd) personnel, both engineering and radiological health. It is assumed that personnel designated to fill the positions of Radiation Health Coordinator and Nuclear Engineer are required to be technically quallfled in their fields of responsibility. Both positions are !!sted on the LERO Training Matrix (see Attachment 1 of OP!P 5.1.1).

0.4.c Training is provided for radiological A monitoring teams and radiological analysis personnel. In response to a previous RAC comment, LILCO now requires that per-sonnel assigned to the Emergency Worker Decontamination Facility and the Reception Centers receive training in Module 11 (Contaminated injured Individuals).

O.4.d Police, security, and fire f!ghting personnel A O.4.f First aid and rescue personnel A O.4.g Local support services personnel A O.4.h Medical support personnel O.4.) Personnel responsible for transmission of A emergency information and instructions.

O.4.1 The Emergency Preparedness Advisors A responsible for advising Suffolk and Nassau County officials are designated to receive complete traluing in LERO emergency operations (see OFIP 5.1.1, Attachment 1). ;

o aview Commen9s Based On

. NUREG-06!4/ FEM A-REP-1, Rev.1, Supp.1 Local Offsite Radiological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 88 of 90 NUREC-0654 Element Review Comreent(s) Racing 0.5 Section 5.1 of the plan, (Training) states that the A LERO training program is conducted on an ongoing basis and requires periodic training on at least an annual basis for personnel with emergency response responsibilities.

0.6 The tilan (see page 5.1-3, lines 49-42) states that A "LERO will offer training and shall attempt to involve Suffolk County and New York State officials In the exercises and drills, but their participation is not required."

P. Responsibility for the Planning Effort P.1 Section 5.1.1 of the plan ~and procedure OPIP 5.1.1 A provide for the training of LERO personnel who are responsible for tht planning effort. The LILCO Emergency Preperedness Coordinator (EPC) is responsible for overseeing this training.

l P.2 The LILCO EPC is responsible for the administra- A tion of the LERO Plan and Procedures (see Plan. .

Section 5.4, page 5. A.1). ,

1 i P.3 The LILCO EPC is responsible for conducting an A annual review and update of the LERO Plan includ-int procedures and letters of agreement (see Plan, Section 5.4, page 5.4.1).

1 i

i P.4 In Section 5.4 of the plan, it is stated that the

• A L..CO EPC is responsible for annually incorporating

• lI plan and procedure changes resulting from exercises and drills and assigning the responsibility for Implementing corrective actions. . .. . -.

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. - , _ ._. - - _ . _ , _ . - , _ _ . , ,_,.,m _ , , , _ , , , .__,.,,m_ , _ . . _ _ _ _ , , . _ _ . _ . s _, _

Review Comments Based On NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1 Local Offsite Radlological Emergency Response Plan for Shoreham Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 89 of 90 NURIC-0654 Element Review Comment (:) patins P.4 Various agreements necenary to implement the -

(Cont'd) Plan will be updated annually or upon revision of the I plan (see Section 5.4, pages 5.4-1 and 2).

t P.5 According to the plan (Sec. 5.4), the L!LCO EPC is A responsible for distributing the Plan and approved changes to the organizations and appropriate .

Individuals responsible for their implementation.

In Revision 9 of the plan, dates of all revisions have been addsd to the List of Effective Pages of all documents. They are as follows:

Rev.0 5/26/83

! Rev.1 7/28/83 .

j Rev.2 11/7/83

Rev.3 12/22/83 .

l Rev.4 6/29/84 f Rev.5 8/02/85 Rev.6 1/10/86 ,

Rev.7 6/30/86 Rev 8 8/19/86 Rev.9 1/18/88 '

'l P.6 Section 1.4, pages 1.4-2 and 1.4-2a, and Attachment A 1

1.4.2, contain the required list of supporting documents.

i P.7 Appendix C to the plan lists by title, the procedures A

) required to implement the plan.

l The plan includes a reference to Procedure OPIP; 1.1.1, Offsite Preparedness Implementing Procedure' Development (see Plan, Chapter 1, Sec.1.1, lines l -

11-13). OP!P 1.1.1 establishes procedures for the Implementation and use of'th4 LERO procedurtsr a

t 9

Review Comments Based OR

- NUREG-0654/ FEM A-REP-1, Rev.1, Supp.1

' Local Offsite Radiological Emergency Response Plan for Shorshtm _

Final Regional Assistance Committee (RAC) Review of Revision 9 Dated April 28,1988 Page 90 of 90 NUREG-0654 Etement Review Commentis) Ratina P.8 The plan contains a specific Table cf Contents, and A is cross-referenced to NUREG-0654 criteria.

The NUREG-0654 cross-reference has been revised in response to previous RAC reviews (Rev. 3 through 4).

Further revLsion should be made to make the cross-reference more in agreement with NUREG-0654 Rev.1 Supp.1 (i.e., addition of elements G.1.e, G.3, and 0.4.g: change of element M.3.a to M.3: and l deletion of element !.3).

i 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 5.3.4 calls for telephone numbers in emergency procedures to be updated quarterly.

P.11 LERO will provide copies of the plan and its A I

revisions to non-participating State and ' local l government entitles (Section 5.4, p. 5.4-2). -  ;

1 a

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1 I

I

l

Element Rating Summary NUREC-0654 Element Rating Rev. 9 A.1.a A A.1.b A A.1.c A  ;

A.1.d A A.1.e A A.2.a A A . 2 . 's A A.3 A

< A. , A I

4 C.1.a A 4 C.1.b A C.1.c A ,

' C.2.a A C.2.b A C.2.c A C.3 A i

C.4 I C.5 A D.3 A D.4 I i E.1 A E.2 A i E.3 A E.4.a-n I j  !!. 5 I

? E.6 A -

1 E.7 A E.8 A I' l

] F.1.a A  !

F.1.b I t F.1.c A l F.1.d A ,

7.1.e A ,

F.2 A F.3 A i

C.1.a-e I .

I C.2 I C.3 A i i C .' 4 . a A

.i C.4.b A i j C.4.c I l C.5 I l 1

i I ,

j i d

l FUREC-0654 Elernent Rating Rev. 9 (

i H.3 A H.4 A l H.7 A-  !

H.10 A W.11 A f H.12 A l t

I.7 A f I.8 A l I.9 A '

I.10 A I.11 A  !

J.2 A [

J.9 A J.10.a A J.10.b A J.10.c A ,

J.10.d A J.10.e I J.10.f I J.10.s I l J.10.h A l

J.10.i A J.10.j A i J.10.k I i J.10.1 A ,

J.10.a A  !

J.11 I '

J.12 I l i

K.3.a A K.3.b I '

K.4 I  !

K.5.a A l K.5.b A ,

I L.1 A  ;

L.3 A p

L.4 A l M.1 A M.3 A -

j M.4 A ', ,

N.1.a A

N.1.b A N.2.4 A t N.2.c A f

. I

4 g 4 i  !

i NUREC-0654 Element Rating Rev. 9 l L

i N.2.d A '

N.2.e A 3 N.3.a-f A

N.4 A  ;

l N.5 A i N.6 A O.1 A  :

0.4 A i

0.5 A l 0.6 A  !

P.1 A 4

, P.2 A (

1 P.3 A l

! P.4 A P.5 A

(

P.6 A f

P.7 A l P.8 A i l

P.10 A j . P.11 A L f d I l

.i l

4 i

4 a

'I i

q f

f 2 i 1  :

i i i l i l 5

1 i 1 .

]

1 1

i FI i .

+

]

t O

i l LIST OF ACRONYMS A

ARC American Red Cross ASLB Atomic Safety and Licensing Board B

BHO DOE's Brookhaven Area Office C

CPI Coordinator of Public Information CPM Counts per minute D -

DOC U.S. Department of Commetce DOD U.S. Department of Defense DOE U.S. Department of Energy DOT U.S. Department of Transportation DRD Direct Reading Dosimeter E  !

! EBS Emergency Broadcast System ~

1 ENC Emergency News Center

EOC Emergency Operat'ons Center

EOF Emergency Operations Facility

]

EPA U.S. Environmental Protection Agency i EPC Emergency Preparedness Coordinator EPIF Emergency Plan Implementirig Procedure EPZ Emergency Planning Zone ERPA Emergency Response Planning Area EWDF Emergency Worker Decontamination Facility -

l F FAA Federal Aviation Administration FCC Federal Comisunications Commission FEMA Federal EmerTency Management Agency ,

FRERP Federal Radiological Emergency Response Plan '

FRMAP Federal Radiation Monitoring Assistance Program H

HHS U.S. Dept;tment of Health and Human Services '

i K

4 l K! Potassium lodine  ;

t s

0

• . Q LIST OF ACRONYMS (cont'd)

L 1

LERO Local Emergency Response Organization LILCO Long Island Lighting Company LIRR Long Island Railroad N

NCS National Communications System NEST Nuclear Emergency Search Team NRC U.S. Nuclear Regulatory Commission  ;

i O

OP!P Offsite Plan implementing Procedure 1

ORS Offsite Radiological Survey

P PA Protective Action i PAG Protective Action Guide P A P. Protective Action Recommendation t

R RAC Regional Assistance Committee RAP Radiological Assistance Program RECS Radiological Emergency Communications System  :

REMP Radiological Environmental Monitoring Program

! S ,

l SNPS Shoreham Nuclear Power Station i i

T ,

1

, TLD Thermoluminescent Dosimeter i f

TSC Technical Support Center l 5 TSO Was used in the plan (Procedure OP!P 3.8.1) but was not defined j i i

U '

USCG U.S. Coast Guard <

USDA U.S. Department of Agriculture I l y I J l

YA U.S. Veterans Administration l

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LOCAL OFFSITE RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR SHORERAM .

a Final Review of Revision 9 by Regional Aaststance Committaa (RAC) 4

i a p J,

t Apru 28,1988  !

I 9 p 4

1 EKHIBIT 1 4

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I-._.,___.._..___,_...._.__._, . . . . , _ _ _ . _ . - _ _ _ . - - , . . , _ _ . . _ _ . _ _ _ _ _ _ _ _ _ _ _ , . . . - . . _ _ _ . . . _ . _ _ _ . _ _ _ . . _ . , _ , , _ , _ . _ _ _ _

EVALUATIOP FORM The following checklist identifies the characteristics and content of an effecti/+ public emergency information document.

This checklist, f rom FEMA REP-11, has been employed to evaluate the document using the symbols below:

Y .... Yes, fully meets identified criteria "

r M ... Marginally acceptable; could be improved I ... Inadequate or Missing

? ... Insufficient information to evaluate; item i

should be checked for consistency with the emergency plan or f or being acceptably j addressed through another medium.

Items on the checklist have been divided into three categories Category 1:

These items are critical to the effectiveness of

~~

a public emergency information document.

i identified as not fully meeting the identified criteria, i.e.Allthose items items marked (I), (M), or (?), should be improved prior to the next scheduled distribution. If a sufficient number of items in this  ;

' category are identified as missing or inadequate (I), steps should be immediately taken to address and make necessary changes in the t

j document.

Category 2:

These items are important to the effectiveness of a public emergency information document.

j Items in this category identified as missing or inadequate (I),

or as marginally acceptable (M), should be addressed prior to the ,

1 next revision of the document. '

Category 3:

l

-~

These items are enhancements to the overall  !

quality document. Items in this category identified as missing or of a public emergency information

! inadequate (I), or as marginally acceptable (M), might be -

considered when planning future revisions of the document.

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1  ;

i f

I j 1. The ?ollowing Items Are critical To The Effectiveness of, tuergency Public Information: .

l 4

i t,

l I

i 2

{

i e

v -r -,e, - . . - - , - . - - - - ,...-y . -_, , _ - - . - --.--- .. , --- , . ., - ,--. ,.-~-.,_-,-,-,.----y

l .

, CONTENT M Document ha. a clear emergency focus. It should tell the reader what to expect, in what sequence.

It should tell what actions, in order of priority, should be taken if notification is gi' van.

THIS BOOKLET HAS AN EMERGENCY FOCUS WHICH CAN ONLY BE CT ASSIFIED AS SUPTRFICIAL. WHILE THE COVER AND LEAD PAGES OFFER A CLEAR MESSAGE AS TO THE EMERGENCY CONTENTS OF THE BOOKLET, THE DOCUMENT AS A WHOLE IS NOT APPROPRIATELY ORGANIZED TO REINFORCE THE EMERGENCY MESSAGE, MAKE IMPORTANT ACTIONS CLEAR TO THE READER, NOR TO PROVIDE UNAMBIGUOUS GUIDANCE TO THE READER SEEKING l IMPORTANT INFORMATION IN A HURRY. EMERGENCY ACTIONS ARE DESCRIBED IN A PRIORITY ORDER BUT THEY ARE DISPLAYED LARGELY AFTER OTHER, MORE EXTRANEOUS EDUCATIONAL OR OTHER INFORMATION IS PROVIDED. PAGE 1, EMERGENCY PROCEDURES, IS A GOOD START THAT IS NOT ADEQUATELY TAKEN ADVANTAGE OF AS IS PAGE 3,

SUMMARY

. THE READER MUST THEN WADE BACK TO PAGES 8 THROUGH 17 TO FIND ADEQUATE s DETAIL ABOUT EMERGENCY ACTIONS THAT SHOULD BE TAKEN.

?

The content is consistant with the emergency plan and EBS messages.

WITHOUT ACCESS TO THE SHORTHAM PLAN AND EBS SCRIPTS, THIS CANNOT BE VERIFIED. .

Y There is'a clear statement of purpose.

I THE FRONT COVER (INSIDE AND OUTSIDE) PROVIDES A DEFINITION OF  ;

' PURPOSE AND A CLEAR STATEMENT IS FOUND ON PAGE 4, RIGHT COLUMN, i SECOND FULL PARAGRAPH. ,

I 1

?

i If the emergency plan calls for an emergency phone number, it is given, along with instructions on the ,

i procedures to be f ollowed relative to its use. Be sure to distinguish "hotline" numbers for use during emergencies as separate from information numbers during non-emergency times. l L

NO EMERGENCY NUMBER IS GIVEN AND READERS ARE TOLD NOT TO USE THE TELEPHONE DURING A'N EMERGENCY (SEE PAGE 13, CENTER COLUMN, ITEM 7 4 FOR AN EXAMPLE). NO REFERENCE WAS FOUND TO PLANNED PUBLICATION l

I OF EITHER. AN EMERGENCY PHONE NUMBER VI A EBS UNDER AN EMERGENCY CONDITION J

3

M There is a contact given for additional information.

AN ADDRESS IS PROVIDED (PAGE 20) FOR WRITTEN REQUESTS FOR FURTHER INFORMATION, NO TELEPHONE NUMBERS WERE OBSERVED IN THIS DRAFT BOOKLET. .

M Information is given regarding notification procedures.

SEE BRIEF. PAGE 1 WHERE SIREN AND EBS STATION INFORMATION IS PROVIDED IN FURTHER INFORMATION IS FOUND ON THE PAGE 3

SUMMARY

PAGE AND LATER (PAGE 8) MORE DETAIL IS PROVIDED. IT IS HELPFUL THAT THIS INFORMATION IS LOCATED IN A VARIETY OF PLACE.;, MAKING IT MORE LIKELY TO BE NOTICED. THE MEANS AND STYLE OF PRESENTATION IS NOT AS CLEAR AS IT COULD BE, NOR DOES IT COMMAND THE ATTENTION OF THE READER IN AS EFFECTIVE A WAY AS IT COULD. USE OF DESIGN ELEMENTS SUCH AS KEY GRAPHICS, BOLD TYPE, ADDED WHITE SPACE, SECTION BOXES OR BULLETED LISTS WOULD IMPROVE THE COMMUNICATION THETHIS OF IMPORTANT INFORMATION AND MAKE IT MUCH MORE ACCESSIPT.E TO READER.

Y Identification of EBS stations is given, with stations / channels.

SEE INSIDE FRONT COVER, PAGE 1, PAGE 3 AND PAGE 8. SEVERAL AM sND FM STATIONS ARE LISTED BY CALL LETTERS AND BY DIAL NUMBERS.

IN ADDITION, ON PAGE 8 A DIAL CHART IS PROVIDED WITH EACH STATION NOTED BY CALL LETTERS, NUMBER AND RELATIVE POSITION ON THE DIAL.

THIS CHART IS A GOOD IDEA THAT NEEDS TO BE MORE 1FFECTIVELY IMPLEMENTED; IT WAS DIFFICULT TO ASSESS THE FI9AL EFFECTIVENESS OF REVIEW. T!!IS CHART FROM THE RATHER CRUDE PASTE-UP VERSION PROVIDED FOR Y

There is a highly visible statement on the cover about keeping the document for use in the event of ,

an emorgency.

SEE FRONT COVER, IN ADDITION A RETENTION STATEMENT IS FOUND ON THE INSIOE FRONT COVER AND PAGE 1. IT WAS NOT CLEAR FROM THE PHOTOCOPIES PROVIDED WHAT THE BACK COVER WOULD LOOK LIKE.

4

Y Educational Information. Tho vory basic information on radiation must be included irs the emergency brochure to convey a sense of health risk.

PAGES 18 AND 19 PRESENT A VERY COMPLETE OVERVIEW OF INFORMATION ON RADIATION, INCLUDING DATA THAT HELPS THE READER ASSESS THE RELATIVE HEALTH RISXS OF VARIOUS LEVELS OF EXPOSURE. SECTIONS ON l NATURAL RADIATION, DETECTION, EXPOSURE LEVELS, RADIATION AND NUCLEAR POWER PLANTS, RADIATION GUIDELINES AND THE BIOLOGICAL EFFECTS OF RADIATION ARE INCLUDED. A CHART OF TYPICAL RADIATION SOURCES IS ALSO FOUND ON PAGE 19.

THE EMERGENCY INSTRUCTIONS SECTION INCLUDES A DISCUSSION Ort Y Sheltering.

FIRST NOTICE IS ON PAGE 1, WHERE THE READER IS REFERRED TO PAGE 13 FOR A MORE COMPLETE DISCUSSION. THE PAGE 13 CISCUSSION CONSISTS OF TWO BRIEF PARAGRAPHS FOLLOWED "Y A LIST - 10 BOLLETED POINTS ON SHELTERING. THE LEAD PARAGRAPHS CN PAGE 13 COULD BE MADE CLEARER THROUGH REWRITIhG SINCE THEY ARE AWKWARDLY PHRASED.

THE FINAL ITEM IN THE JULLETED LIST IMPLIES THE POTENTIAL FOR RESPIRATORY PROTECTION INDOORS AS WELL AS OUTSIDE (??).

ADDITIONAL REFERENCES TO SHELTERING CAN BE FOUND ON PAGE3 3 AND 7.

M Evacuation routes, both written explanations in the text and illustrated directions on an evacuation map of the EPZ.

ROUTE MAPS AND WRITTEN EXPLANATIONS ARE FOUND ON PAGES 9-12.

PAGE 9 IS AN OVEPVIEW MAP OF T!!E EPZ WITH ZONES AND ROUTES MARKED.

PAGE 10 IS AN EVACUATION MAP FOR ZONE A (IN THE SAMPLE REVIEWED), IT ALSO DISPLAYS WRITTEN DIRECTIONS OUT OF THE ECNE TOWARD APPRDPRIATE RECEPTION CENTERS. PAGE 11 IS A MAP SHOWING .

ROUTES TO RECEPTION CENTERS AND SCHOOL RELOCATION CENTERS (THE RELATIONSHIP OF THIS MAP LOCALE TO THE EPZ IS UNCLEAR!). PAGE 12 DISPLAYS AN EMERGENCY BUS ROUTE MAP FOR ZONE A. THE MAPS ARE IN DRAFT FORM AND HARD TO EVALUATE.

5

=

s M Transportation provisions.

6 PAGE 3, LOWER RIGHT COLUMN REFERS TO TPECIAL PLANS FOR THE HANDICAPPED AND FOR THOSE WITH SPECIAL TRANSPORTATION NEEDS.

PAGES 13 AND 14 CONTAIN INFORMATION ABOUT TRANSPORTATION PROVISIONS THAT HAVE BEEN MADE. ON PAGE 13 A SOMEWHAT PUZZLING

~

CAR GRAPHIC IS USED THAT COULD BE INTERPRETED AS ADVICE NOT TO USE AN AUTOMOBILE. THIS COULD BE CONFUSING. PAGE 14 INDICATES THAT TRANSPORTATION PROVISIONS INCLUDE THE USE OF PRIVATE CARS AND EMERGENCY BUS ROUTES, WITH SPECIAL VEHICLEE FOR THE DISABLED TO BE DISPATCHED BASED ON ADVANCED REGISTRATION OF THE HANDICAPPED. A MAP OF THE EMERGENCY B'JS ' ROUTE FOR ZONE A IS FOUND ON PAGE 12 BEFORE ANY REFERENCE IS MADE TO IT IN THE TEXT, POTENTIALLY CONFUSING.

i M School provisions; including guidelines and/or instructions for paronts.

SCHOOL PROVIh/ONS ARE MENTIONED.MAINLY ON PAGES 16 AND 17 WITH  ;

ADDITIONAL REFERENCES ON PAGES 11 (A SCHOOL RELOCATION CENTER MA P) , 14 AND 15. t THE INFORMATION ON PAGE 14, CENTER COLUMN, IS AMBIGUOUS AND DOES NOT CLEARLY DEAL WITH THE ISSUE OF WHETHER 1

PARENTS SHOULD ATTEMPT TO GO TO THE SCHOOL. THE ROLE OF THE EBS l 8N NOTIFYING PARENTS OF THE STATUC OF SCHOOL CHILDREN IS NOT CLARTFIED HERE EITHER. (THE PREVIOUS COMMENTS APPLY TO PAGE 15, LEFT COLUMN TOO). PAGE 16 AND 17 PROVIDE THE MOST COMPLETE DETAIL ABOUT CHILDREN IN SCHOOL BUT EXTENSIVE REWRITING WCULD BE ISSENTI AL IF OPTIMUM CLARITY IS TO BE ACHIEVED.. THE WRITING 4

STYLE IS AWKWARD AND THE PRESENTATION IS IN A NARRATIVE TEXT .

FORMAT. NO USE OF DESIGN ELEMENTS, SPACING, BULLETED LISTS, BOLD TYPE OR GRAPHIC ORGANIZERS IS MADE AT ALL. SUCH ELEMENTS COULD MAKE THE INFORMATION MUCH MORE ACCESSIBLE AND UNDERSTANDABLE TO l

PARENTS READING THESE PAGES. THE SCHOOL AND ZONE LISTINGS THAT  !

COMPLETE THESE SECTIONS MAY BE HELPFUL BUT NO CLEAR INDICATION OF

• THEIR PURPOSE OR USE IS PROVIDED THE READER, MAKING IT DIFFICULT ,

TO INTERPRET OR USE THE INFORMATION PRES ENTED.

j i 1  !

i M Instruction on the care and feeding of livestock,  ;

f if appropriate, in the area. '

THE ONLY REFERENCE FOUND WAS ON PAGE 13, CENTER COLUMN, POINT 2.

NO ADDITIONAL INFORMATION WAS PROVIDED, NOR WAS A FURTHER CONTACT POINT PROVIDED FOR SUCH INFORMATION (OTHER THAN THE GENERAL

{ 8NFORMATION ADDRESS GIVEN AT THE BACK OF THE BOOKLET).

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6

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. I roc 0ption COntors, r010 cation and/or congregate care centers.

' THE MAIN SOURCE OF THIS INFORMATION IS ON PAGE 15, "WHERE WCULD YOU GO?" RECEPTION CENTERS ARE MENTIONED BUT NOT SPECIFICALLY IDENTIFIED BY ZONE ON THIS PAGE. FOR SPECIFIC CENTER  ;

IDENTIFICATION THE READER MUST TURN TO MAP PAGES 10 AND 11 (WHICH ARE NOT REFERENCED ON PAGE 151). EVEN ON THE MAP PAGES THE 4 READER MAY FIND IT DIFFICULT To LOCATE OR IDENTIFY THE APPROPRIATE CENTER SINCE NO CLEAR WRITTEN INSTRUCTIONS OR INFORMATION IS INCLUDED BEYOND GENERAL, NON-SPECIFIC REFERENCES IN OTHER TEXT SECTIONS. THE COMMUNICATION OF RECEPTION CENTER / CONGREGATE CARE CENTER INFORMATION.IS NOT HANDLED OPTIMALLY IN THE DOCUMENT REVIEWED.

Provisions for the handicapped.

Y A SPECIAL NEEDS CARD !$ INCLUDED AND REFERENCED IN SEVERAL PLACES. ON PAGE 8, RIGHT COLUMN, NOTIFICATION PROV!SIONS FOR THE HEARING IMPA! RED ARE DESCRIBED AND E). TENSIVE PLANS HAVE BEEN MADE l TO ACCOMMODATE SUCH NEEDS. PAGE 14 DESCRIBES ARRANGEMENTS THAT HAVE BEEN MADE TO TRANSPORT THE DISABLED.

ORGANIZATION j M

' The emergency instructions occupy a highly, visible place in the front of the document.

SOME INFORMATION IS PROVIDED AT THE FRONT OF THE DOCUMENT IN THE i FORM OF

SUMMARY

AND OVERVIEW PAGES (SEE PAGES 1 ANO 3) BUT THE DETAILED INFORMATION IS NOT FOUND UNTIL PAGES I-17 AS NOTED IN  !

] VME FIRST ITEM 0F THIS REVIEW, EMERGENCY FOCUS COULD BE IMPROVED THROUGH REORGA!!!2ATION TO BRING THE CRITICAL EMERGENCY ACTION INFORMATION TOGETHER AT THE FRONT OF THE DOCUMENT.

SUMMARY

PAGES ,

AND A TABLE OF CONTENTS ARE QUITE HELPFUL BUT THE BOOFLET COULD

{ BE MUCH MORE EFFECTIVE WITH BETTER ORGANIZAtl'0N.

i 4

j 1 The information is logically sequenced.

I SEE PRECEDING COMMENTS. THE EMERGENCY INFORMATION NEEDS TO BE BROUGHT TOGETHER AT THE FRONT OF THE DOCUMENT. EXTENSIVE REWRITING AND THE CONSIDERATION OF BETTER GRAPHIC DES!GN 70 i

ENHANCE BOTH THE COPPREHENSIBILITY AND EMERGENCY FOCUS Of THE l

DOCUMENT SEEMS INDICATED.

1 7

. I Inforaation is clearly organi:cd and rolovent to '

tha purposo of providing emergency guidance.

WHILE EXTENSIVE INFORMATION IS PROVIDED, IT IS NOT WELL ORGANIZED

)

10R THE PURPOSE OF PROVIDING EFFECTIVE AND EFFICIENT EMERGENCY GUIDANCE TO THE READER. THE INFORMATION IS NOT ADEQUATELY CROSS REFERENCED AND THE READER IS NOT PROVIDED WITH AN EFFECTIVE "ROAD MAP" THROUGH THE MAZE OF I NF ORd.;TI ON IN THE BOOKLET. THE TABLE OF CONTENTS IS A VERY HELPFUL FEATURE AND 00ES MITIGATF. 'fME LACK OF ORGANIZATION SOMEWHAT.

i M

Public education passages, if included, are not distracting.  !

THE SECTION ON RADIATION (PAGES 18 AND 19) IS COMPLETE AND GENERALLY WELL DONE. THE SECTIONS ON GENERAL EMERGENCY PLANNING, SAFETY SYSTEMS AT THE PLANT, EMERGENCY EVENTS AND EMERGENCY CLAS$!FICATION LEVELS ARE EXTENSIVE BUT LOCATED INAPPPOPRIATELY IN FRONT OF THE.!MPORTANT DETAILED SECTION ON EMERGENCY ACTIONS 70 BE TAKEN BY THE PUBLIC. THESE LATTER PASSAGES, WHILE HELPFUL, SHOULDSECTIONS.

ACTION BE RELOCATED 50 AS NOT TO DISTRACT FROM THE EMERGENCY t

1 COMPREHENSION FACTORS M

The document layout is such that the text is easy to follow from paragraph to paragraph and from page to page. Page and section breaks are consistent '

with the logic and organization of the materials.

I AS n RULE, THE PAGES ARE SELF CONTAINED AND MAJOR SECTIONS ARE NOT BROKEN UP ACROSS PAGE BOUNDARIES. COLUMN BOUNDARIES ARE  !

SOMETIMES CROSSED BY 3ECTIONS.

ON RUNNING TEXT AND VERY LITTLE ATTENTIONTHERE IS PAID TO EFFECTIVEIS A GENERAL OVE i

4 USE OF DESIGN DOCUMENT. OR GRAPHIC ELEMENTS TO ENHANCE THE CLARITY OF THE THE LOGICAL FLOW OF THE DOCUMENT, FROM AN EMERGENCY '

]

ACTION STANDPOINT, COULD BE IMPROVED BY. EXTENSIVE REWRITING AND REDESIGN.  ;

l

! M The information is presented in such a way that

)

I there is a logical sequence of topics. The "flow" of information is smooth and not disjointed.

1 AS A GENERAL RULE, THE WRITING STYLE IN MANY SECTIONS IS AWKWARD 3 AND SOMEWHAT UNCLEAR! THIS INTERFERES WITH THE SMOOTH "FLOW" 0F

!NFORMATION SECTIONS. AND CREATES AN IMPRESSION OF DISJOINTEDNESS IN MANY PAGE 15, "WHERE WOULD YOU GO?" !S A REPRESENTATIVE.

EXAMPLE OF TEXT THAT COULD BE IMPROVED THROUGH REWRITING.

• e S

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I T Within a given topic, actions to bo takon como i

first, follow:d by rationa10 er oxplanotion. ,

! IN THOSE SECTIONS WilERE LISTS OF ACTIONS ARE PROVIDED, THERE !$ A  ;

j 2000 ACTION FOCUS. SEE PAGE 13 FOR AN EXAMPLE OF EFFECTIVE '

ACTION FOCUS. PAGE 14, HOWEVER, IS LESS EFFECTIVE IN THIS REGARD. '

M Vocabulary is simple, comprised of non-technical'

, terms likely to be found in the vocabularies of the  ;

1 intended population.  :

i

! THE VOCABULARY CHOSEN COULD BE $!MPLXFIED AND MADE MORE READABLE.  !

WITHOUT FURTHER DATA ABOUT THE INTENDED POPULATION !T '!S '

1 D!FFICULT 70 JUDGE THE APPROPRIATENESS OF THE VOCABULARY USED.

SENTENCES TEND TO BE RATHER LONGER AND MORE INVOLVED THAN l

} NECESSARY AND PRONOUN OR ANAPHORIC REF'ERENCES ARE OFTEN VAGUE OR l

INCON8! STENT. IN GENERAL PURELY TECHNICAL TERMS ARE AVO!DED --

> I THIS IS A POSITIVE FEATURE -- BUT THE GENERAL TONE OF THE '

i DOCUMENT IS SOMEWHAT MORE FORMAL OR "0FFICIAL" THAN NEED BE.

j M Sentences are brief and concise. I I

WHERE A LIST FORMAT IS USED, THE LANGUAGE IS BRIEF AND CONCISE.

WHERE LONGER PARAGRAPHS AND RUNNING TEXT IS USED, THERE IS A  !

TENDENCY TOWARD LONG, COMPLEX SENTENCES AND THE USE OF PARAGutAPHS  !

{ WITH MORE THAN ONE MAIN POINT. THIS INTERFERES WITH DOCUMENT l LARITY. - l i

1 5 i l

Y Typography is legible and easy to perceive. I I A SANS SERIF TYPEFACE !$ USED AND TYPES!2E IS ADEQUATE FOR MOST.

SOME INDIVIDUALS WITH SEVERE VIS!0N PROBLEMS, OR MISPLACED j GLASSES MAY MAVE DIFFICULTY READING THE TEXT.

i I

i

. i Y

The cover clearly states that the document contains important emergency instructions.

)  ?

The choice of colors is appropriate for culorblind i individuals. I I

j THIS MATERIALS FACTOR CANNOT BE FULLY ASSESSED GIVEN THE PHOTOCOPY DRAFT PROVIDED FOR REVIEW, 4

INDICATED SHADES CHOSEN, NOWEVER,ESPECIALLY FOR THE MAPS. THE J

COLOR 5LIND. ARE NOT APPROPRIATE FOR THE l r i-i i S 4

i l

l I

~~ The reading level is appropriate. This is based on the following:

X host of the emergency procedures section of the document has a reading level above grade 9, as character.ized by the Dale-Chall readability f ormula.

2. The Following Items should se included When The Document i

!s Revised:

C ONTENT  !

Y Information is given regarding emergency action  ;

levels, and enough educational information on radiation is given to provide an understanding of sources and relative effects, or provision is made l in a separate document.

EMERGENCY ACTION LEVELS (EALS) ARE DESCRIBED IN DETA!L ON PAGE 7,

'HOW EMERGENCIES ARE CLASS!FIED." !N ADDITION, REFERENCE TO THE EAL CONCEPT IS MADE IN PARAGRATH 2 RIGHT COLUMN, PAGE 3. AH ADDITIONAL REFERENCE TO THE EAL SYSTEM IS FOUND IN THE LAST PARAGRAPH OF PAGE 6.

l r

? Information has been provided for transients and visitors through appropriate means.  :

PROVISIONS FOR BOATERS ARE MENT!0NED ON PAGE 8. NO OTHER DETAIL ABOUT NOTIFtCtT!ON OF TRANSIENT POPULAT!0NS WAS FOUND IN THE 1 DOCUMENT REVIEWED. -

? A method of identifying special needs has been I provided in such a way that it cannot be lost ,

during shipment or during the initial reading.

l A DRAFT OF THE TEXT FOR SUCH A CARD WAS INCLUDED (LAST PHOTOCOPY PAGE) EUT THE MEANS BY WHICH !? IS BOUND INTO THE DOCUMENT !$ NOT CLEAR FROM THE REVIEW MATERIALS PROVIDED.

Y Consideration has been given to the needs of any special population.

PROCEDURES FOR BOTH THE HEARING IMPAIRED (PAGE 8) AND OTHER GENERAL MAND!

THE INSIDE CAPPED (PAGEALSO FRONT COVER 24) ARE INCLUDED ADVISES IN THE THE READER TH, DRAFT DOCUMENT REV!$WED.

A SPECIAL.NEEDS CARD PROVIDEb. SHOULD EE COMPLETED AND RETURNED AND THAT SPECIAL HELP WILL BE 19 I l

~

'. . 1

' THE EMERGENCY INSTRUCT 80NS. SECT 80N 8HCLUDES A DISCUS $80N Ort l

M Respiratory protection.

I WHILE A DISCUSSION OF RESPIRATORY PROTECTION IS FOUND ON PAGES A3 AND 14, THE MESSAGE ON PAGE 13 IS VAGUJ, POSING THE  !

POSSIBILITY THAT RESPIRATORY PROTECTION MAY BE NEEDED UNDER SHELTERING AS WELL AS WHEN OUTDOORS. IN CONTRAST, PAGE 14 ONLY MENT!0NS THE POSSIBLE NEED FOR PROTECTION WHEN OUTDOORS AND ADVISES THAT THE EBS WILL PROVIDE APPROPRIATE ADVICE. THE '

MESSAGE IS MIXED ON THIS TOPIC. l l

? Radioprotective drugs (if adopted by State or local  !

government agencies for use by the general public). l No MENTION OF Re.MOPROTECT!VE DRUGS, K!, FOR THE PUBLIC WAS FOUND IN THE DOCUMENT REVIEWED.

Y Encouragement to alert neighbors, by means other than the telephone, to ensure that they also heard and understood the warning signals.

PAGE 3, "

SUMMARY

OF IMPORTANT INFORMATION" !NDICATES (CENTER GOLUMN) THAT "PEOPLE IN THE AREA TO BE EVACUATED ARE URGED TO BE GOOD NE!GHBOR$." THIS !$ VERY HELFFUL ADVICE. PAGE 8 WOULD 1ENEFIT FROM A $!MILAR STATEMENT, ESPECIALLY SINCE THIS PAGE DEALS DIRECTLY WITH NOTIFICATION PROCEDURES AND ACTIONS. '

l Y Emergency supplies checklist to have in the home.  !

PAGE 20 IS ON THE TOP!C "BE PREPARED" AND DOES INDICATE THE NEED FOR ADVANCED PLANNING, BRIEF MENTION OF SUPPLIES SUCH AS FIRST A8D KITS, FLASHLIGHTS, RADIO AND BATTERIES IS MADE ON THIS PAGE. ,

Y Supplies checklist for use in the event of evacuation.

SEE PAJE 14. (NOTE THAT THIS 70P!C "EVACUATION" IS SPLIT ACROSS TWO PAGES).

Y Home preparation for sheltering.

SEE PAGE 13 FOR A BULLETED !LST.

s

_Y Home preparation for evacuation.

SEE PAGES 13 AND 14 FOR A BULLETED LIST OF PREPARATORY ACTIONS.

11

CRCANIZATION

._ General educational material, if included, is l placed after the emergency procedures information.  !

SEE PRECEDING COMMENTS. GENERAL PLANNING AND PLANT INFORMATION IS LOCATED AHEAD OF THE DETA! LED EMERGENCY ACTIONS 3ECTIONS.

COMPREMENSION FACTORS-

Y The cover design encourages one to open the publication and to read what it contains.

THE COVER IS CLEAR AND UNAMS!GUOUS, INDICATING THE EMERGENCY NATURE OF THE CONTENTS.

?

The format is appropriate for the emergency information included by the document, and the size  !

is appropriate.  :

i TH!S !$ O!FFICULT TO FULLY ASSESS GIVEN THE DRAFT NATURE OF THE i

MATERIALS PROVIDED FOR REVIEW. IF THE SIEE IS THE SAME AND A SADDLE ST!TCHED FORMAT WITH GOOD QUALITY PAPER IS USED, TFE i

'ORMAT MAY BE APPROPRIATE.

i

• i M Photographs, maps, charts, tables, and artwork are used effectively to enhance the text and are not ,

i distracting. -

] MORE EXTENSIVE USE OF GRAPHIC ELEMENTS IS NEEDED TO IMPROVE TH"e

DOCUMENT. PHOTOS ARE NOT USED.

I i

,  ! The various elements of graphic design work t

I together harmoniously to achieve the desired effect.

4 THE GRAPHIC DOCUMENT DESIGN.COULD BENEFIT FROM MORE EFFECTIVE USE OF ELEMENTS OF

', SEE PREVIOUS COMMENTS THROUGHOUT THIS REV!EW. <

1 i l l

j 12 j

3. Tha F01*>cwing ItcCs W;uld 33 Enhancemants To Tho Ov0rall Quality of The Documentt i CONTEN; Y

The document contains the date of issue and the name of the issuing agency.

ON THE COVERS.

Document contains blank space in the emergency procedures section for personal notes.

I

)

SOME SPACE IS AVAILABLE WHERE MARGINAL NOTES COULD THIS BE MADE BUT  !

IS NOT, APPARENTLY, A CONSCIOUS PART OF THE DES!GN.

Y cocument contains a section on family preplanning. i THE BACK COVER OR LAST PAGE.  !

COMPREHENSION FACTORS s' ,

Key symbols or graphic images are used to assist the reader in locating and/or understanding the text.

j

{ i

VERY LITTLE USE OF SUCH ELEMENTS IS MADE AND WHERE FOUND, SEE PAGE 13, THEY ARE AMBIGUQUS.

l  !

, l M

The format encourages retention.

NO ENC 0URAGE SPECIFIC ASPECT OF THE FORMAT IS SPECIFICALLY DESIGNED 70 RETENT!0N.  !

I

? ,

Color has been used effectively te enhance and highlight important details relctive to the i

emergency information.  ;

i THIS CANNOT REVIEWER. BE JUDGED FROM THE DRAFT PHOTOCOP!ES PROVIDED FOR ,

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! . Enclosure 1 (

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)^ 4hIi k [

Federal Emergency Management Agency Wuhingtrn, D.C. 20472 1

HAY 3 l l968 ,

i I

, Mr. Victor Stello, Jr. '

1 Executive Director for Operations Nuclear Regulatory Commission i Washingten, D.C. 20555 4

Dear Mr. Stello:

On January 27, 1988, the Nuclear Regulatory Commission (NRC) requested i the Feoeral Emergency Management Agency (FEMA) to review Revision 9 of  ;

i Long Island Lighting Company's (LILCO) offsite emergency plcn for the L l Shorehaz Nuclear Power Station, under the provisions of the April 1985 j l

4tC/FENA Memorandum of Understanding and certain criteria and assumptions,  :

as indicated below. FEMA was also requested to provide a finding, i.e..  !

indicate whether in the framework of those criteria and assumptions FEMA i 1

has reasonaole assurance that the plans can protect the health and safety of the public living in the vicinity of the plant.

I ,

j We were requested to review the plan under tne criteria of the interin use document entitled Criteria for Preparation and Evaluation of Radiological i l' Emergency Response Plans and Preparecness in Support of Nuclear Power  !

] Plants (Criteria for Utility Of fsite Planning and Preparedness). Ttat J

document has been published as Supplenent 1 to NWLEG-0654/ FEMA-REP-1, Rev.1.  !

1 As requested by NRC, FEMA also used 3 essumptions in reviewing and evaluating  !

{ the LILCO plan. Those assumptions. are that in an actual radiological  !

i emergency, State and local officials that have declined to participate i l in emergency planning will:

1 1

1) Exercise their best efforts to protect the health and safety  ;

j of the public,

. 5 l 2) Cooperate with the utility and follow the utility plan, and i 3)Heve the resources sufficient to implement those portions j of the utility offsite plan where State and local response i is necessary, i i

l I It is further understood that in any subsequent hearings or litigation i

reltted to the plan review or exeretse, NRC will defend the above assumptions.

I  !

Enclosed is a report on the results of a full review of Revision 9 of the  !

LILCO plan, conducted oy FEN.A Region !! and the Regional Assistancti Conmittee

, (RAC), using the criteria and assumptions spectfied by hRC. 64 sed zn (

l 1 -

1 i i

?$$ $ $ NS ?!  ?

1 .

,' 2- ,

i that evaluation, Revision 9 conta;ns 17 inadequacies. More detail on :ne review process and tne inadequacies is contained in the enclosed report l

from FEMA Region !! to FLMA Headquarters. Based on tnese inaceauacies, and the reca9mendation of FEMA Region !!, FEMA does not have reasonable assurance under Revision 9 that the public health and safety can te protected

! in tne vicinity of the Shoreham Nuclece Power Station.

l >

However, planning for the exercise may go forward for the reasons noted i 4

bel ow. First, the utility has already provided FEMA Region !! and the RAC

) with proposed plan changes to address these inadequacies. We understand that  ;

these changes were incorporated into Revision 10 of the plan. Eleven of the inadequacies in Revision 9 cequired relatively ninor Gnanges and the utility's (

t i '

proposed changes were responsive to the RAC/FCMA concerns. Foa the six i inadequate elements requiring more substantive revision, five of these [(1.e.,

provisions for ca,munication with New York State (F.1.b). the public infomation program for residents, transients, and the agricultural coimunity (G.1.4 e, G.2, and J.11), and written agreenents for "first call" cenit.9ents with  !

companies supplying supplementary buses for a "one wave" evacuation of school i

(J.10 9)), will not af fect the conduct of tN exercise. With regard to the '

i remaining inactquacy that must be evaluated at the exercise (i.e., planning for the monitoring and decontamination of school children evacuated af ter a

+

l release (J.12)), FEMA Region !! provided technical assistance to the utility to expedite the resolution of this issue for its inclusion in Revision 10.

1 On May 23,1988, NRC requested FEMA to conduct full RAC review of Revision 10

) of the plan and provide a finding by July 29, 1088. NRC has also requested

]

s that the Revision 10 changes be incorporated Inta the exercise play of the I

upcming Shoreham exercise, now scheduled for the week of June 6,1968. '

I

$1nce FEMA would not be able to complete a full RC review in that snort time l I frame, FEMA Region 11 has agreed to review the changes, coordinate witn the  !

RAC where necessary, and incorporate them into the evaluation of the exercise. l A cursory review has been perfomed by FEMA Region !! of the sections of  ;

i Revision 10 relating to the inadequacy concerning the nonitoring and decon-  !

I tamination of school children mentioned above in connection with elenent J.12. L Based on tnat review, we have concluded that the inadequacy has been

• i addressed in a manner sufficient to pemit an adequate demonstration of the i i

monitoring and decontamination function in the exercise. >

i l

We note also that on April 27, 1988, the Director of the Connecticut Of fice j

of Civil Preparedness nott fied LlLCO that his of fice "would participate {

j in an interstate exercise only in full coordination with the participating states and local governments. We have received no such coordination."

l l

He further indicated that his effice will not "conduct any exercise evaluation }

activities or any simulation activities during the proposed exercise conducted '

by LlLCO.

• This w s fully discussed by nembers of our staffs on May 3.1988.

As discussed at the meeting Although the State of Connecticut has bot withdrawn j from participation in offstte emergency planning for the Shoreham plant, it will be considered by NRC as a non-participating government for purposes of the exercise. As a consaquence, as stated in NRC's memorandum of May 26, 1938, MC staff finds appropriate tnat the role of the State will be simulated  !

1 i through the use of a control cell, since the participation of the State is j not reasonably acntevable.

i

,s .

3 We have also received the Kny 26, 1988 confimation from NRC ;caf f that the Kay 25, 1938 advisory opinion frce the Atonic Safety Licensisg and 4 peal Board does not change NRC staf f's view that the current oojectives for the exercise would constitute a qualifying exercise under faC regulations. It is also our understanding that snis confimation nas the concurrence of tne NRC Of fice of General Counsel .

The above pre-exercise arrangements notwithstanding, we think it only prudent to raise the question of whether the planned FEMA-evaluated exercise should proceed at this time. It is our understanding that only recently, LILCO and the State of New York reacned agreement in principle which will allow for the closing of the Shoreham plant. While it is possible that final agreement may not be reached, there is also the probability that Shorena t will not continue to operate. In light of the additional expenditure of funds about to be spent related to the shorehan exercise, it would be more judicious. In FEMA's view, to postpone a FEMA-evaluated exercise at least until further results fran the negotiations between L!LC0 and hew York are made puolic. Of course, postpone ent of the exercise would not prohibit continued planning and plan review 11tivation. Since there are only 4 working days lef t before the scheduled start of the exercise activities, please let us know in writing by CCB June 1,1988, or your position on this natter. If you agree with FEMA's position, we would also ask you to advise LILCO. If you disagree, please include your f ull rationale.

If you have any questions, please feel free to contact me or Dave McLoughlin at 646-3692.

$1 erely,

$$  ?/ .

Grant C. Peterson

/ Associate Director State and Local Programs and Support Enclosure As Stated ,

4