ML20154L004

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Requests Util Provide Schedule for Resolution of Issues Noted in Encl FEMA Review of Offsite Emergency Plan to Ensure That Plan Inadequacies & Areas Requiring Corrective Action Corrected
ML20154L004
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 09/19/1988
From: Brown S
Office of Nuclear Reactor Regulation
To: Leonard J
LONG ISLAND LIGHTING CO.
Shared Package
ML20154L009 List:
References
NUDOCS 8809260073
Download: ML20154L004 (4)


Text

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September 19, 1988 Docket No.: 50-322 DISTRIBUTION fDoctet FUej NRC PDR/LPDR Mr. John D. Leonard, Jr.

PDI-2 Reading WButler Vice President - Nuclear Operations M0'Brien SBrown/GRivenbark Long Island Lighting Company OGC EJordan/BGrimes i

Shoreham Nuclear Power Station ACRS (10)

RTHogan P. O. Box 618, North Country Road RWKrimm, FEMA Wading River, New York 11792

Dear Mr. Leonard:

SUBJECT:

FEDERAL EMERGENCY MANAGEMENT AGENCY REVIEW OF THE OFFSITE EMERGENCY PLAN FOR SH0REHAM The enclosed letter from Grant Peterson, Federal Emergency Management Agency (FEMA) dated September 9, 1988, is in response to our request of May 23, 1988, for FEMA to review the offsite emergency plan for Shoreham and our request to conduct a full-participation exercise of that plan.

The letter transmits the FEMA Region II report on the review of Revision 10 to the SNPS Local Offsite Radiological Emergency Response Plan and the evaluation of the full-participation exercise.

In its finding on LILCO's offsite emergency response plan for Shoreham, FEMA concluded that alth0 ugh seven plan elements were rated inadequate, the exercise held on JWe 7-9, 1988 demonstrated adequate overall preparedness on the part of Local Emergency Response Organization personnel.

Therefore, based on the evaluation of the plan and exercise, FEMA reached a finding of reasonable assurance.

FEMA's plan review and exercise evaluation were based on the assumptions that in an actual radiological emergency, State and local officials that have declined to participate in emergency planning will (1) exercise the best efforts to protect the health and safety of the public,

(?) cooperate with the utility and follow the utility plan, and (3) have the resources sufficient to implement those portions of the utility plan where State and local response is necessary.

I LILCO is encouraged to continue to coordinate with FEMA Region II to ensure that the plan inadequacies and exercise areas requiring corrective action i

identified by FEMA are corrected in a timely manner. We request LILCO provide j

a schedule for resolution of these issues.

i Sincerely, i

/s/

Stewart W. Brown, Project Manager

, h Project Directorate I-2 i Sc.a.

Division of Reactor Projects I/II E.8 ou

Enclosures:

I U 1.

Ltr. to V. Stello from y

G. Peterson 9/9/88 2.

FEMA Report dtd. 9/8/88 gg OFa/

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cc:

See next page k,,M0'bqren PDI-?/(t 1

PDI lA PDI-2/D h

ro WButler j

'N1/88 88

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ff UNITED STATES i'

s NUCLEAR REGULATORY COMMISSION i

E TeNemYeY1I"ID8 s.... /

Docket No.: 50-322 Mr. John D. Leonard, Jr.

Vice President - Nuclear Operations Lorg Island Lighting Company Shoreham Nuclear Pcwer Station P. O. Box 618, North Country Road Wadino River, New York 117n?

Dear Mr. Leonard:

SUBJECT:

FEDERAL EMERGENCY MANAGEMENT AGENCY REVIEW 0F THE OFFSITE EMERGENCY PLAN FOR SPOREHAM The enclosed letter from Grant Peterson, Federal Emeraency Management Agency (FEMA) dated September 9,1988, is in response to our reauest of May 23, 1988, for FEMA to review the offsite emergency plan for Shoreham and our request to conduct a full-participation exercise of that plan.

The letter transmits the FEMA Region II report on the review of Revision 10 to the SNPS Local Offsite Radiological Emergency Response Plan and the evaluation of the full-participation exercise.

In its finding on LILCO's offsite emergency response plan for Shoreham, FEMA concluded that althcugh seven plan elements were rated inadequate, the exercise held on June 7-9, 1988 demonstrated adequate overall preparedness on the part of Local Emergency Response Organization personnel.

Therefore, based on the evaluation of the plan and exercise, FEMA reached a finding of reasorable assurance.

FEMA's plan review and exercise evaluation were based on the assumptions that in an actual radiological emergency, State and local officials that have declined to participate in emergency planning will (1) exercise their best efforts to protect the health and safety of the public, (2) cooperate with the utility and follow the utility plan, and (3) have the resources sufficient to implement those portions of the utility plan where State and local response is necessary.

LILCO is encouragad to continue to coordinate with FEMA Region !! to ensure that the plan inadequacies and exercise areas reouf ring corrective action identified by FEMA are corrected in a timely manner. We request LILCO provide a sch?dule for resolution of these issues.

Sincerely, hrdhfxx Stewart W. Brown, Project Manager Pro,iect Directorate I-2 Division of Reactor Projects I/!!

Enclosures:

1.

Ltr. to V. Stello from G. Peterson 9/9/88 2.

FEMA Report dtd. 9/8/88 cc: See next page

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 O. Letsche, Esq.

U.S. Nuclear Regulatory Comission Kirkpatrick & Lockhart I

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 l

Post Office Box 1535 North Shore Comittee l

707 East Main Street Post Office Box 231 l

Richmond, Virginia 23212 Wading River, New York 11792 l

Howard A. Wilber Fabian G. Palomino, Esq.

Atomic Safety & Licensing Appeal Board Special Counsel to the Governor l

U.S. Nuclear Regulatory Comission Executive Chamber - State Capitol Washington, D.C.

20555 Albany, New York 12224 Atomic Safety & Licensing Board Panel Anthony F. Earley, Jr., Esq.

U.S. Nuclear Pegulatory Comission General Counsel Washington. 0.C.

20555 Long Island Lighting Company 175 East Old County Road Atomic Safety A Licensing Appeal Board Hicksville, New York 11801 I

Panel l

U.S. Nuclear Regulatory Comission Mr. Lawrence Britt l

Washington, D.C.

20555 Shoreham Nuclear Power Station l

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. Esc.

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 New York, New York 10007 U.S. Nuclear Reaulatory Comission Post Office Box 8 Jonathan D. Feinbero. Esq.

Rocky Point, New York 11778 New York State Department of Public Service Regional Administrator, Region 1 Three Empire State Plaza U.$. Nuclear Regulatory Comission Albary New York 12223 475 Allendale Road King of Prussia, Pennsylvania 19406 l

e 0

~

i Long Island Lighting Company Shoreham (1)

CC:

Robert Abrams Esq.

Town Attorney 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 State of New York 120 Broadway Department of Law 3rd Floor ATTN:

Charlie Donaldson, Esq.

New York, New York 10271 1?O Broadway 2

New York, New York 10271 Mr. William Steiger Plant Manager i

4 Shoreham Nuclear Power Station Post Office Box 628 3

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 / Legislative Building Veteran's Memorial Highway Hauppauge, New York 11788 l

Vs. Donna Ross New York State Energy Office I

Agency Building 2 Empire State Plaza Alba'ny, New York 12223 l

Ms. Nora Bredes Shorehan Opponents Coalition 195 East Main Street Smithtown, New York 11787 l

Chris Nolin New York State Assembly l

Energy Comittee

)

626 Legislative Office Building 1

Albany, New York 12248 Peter S. Everett Esq.

r j

Hunton & Williams 2000 Pennsylvania Avenue, NW a

Washington, D.C.

20036 1

I

- _. - _. - _ - -. _ - _ - ~.

4h Federal Emergency Managernent Agency Washington, D.C. 20472 SEP - 91988 Mr. Victor Stello, Jr.

Executive Director for Operations Nuclear Regulatory Ccmission Washington, D.C.

20555 Dear Mr. Stello On January 27, 1988, the tbclear Regulatory Ccmission (NRC) requested i

that the Federal Ehergency Management Agency (FEMA) review Revision 9 of Lorg Island Lightirg Canpany's (LILCO) offsite preparedness plan for the Shoreham Nuclear Power Station (SNPS), under the provisions of the April 1985 l

FDiA/NRC Memorandtzn of Understardirg and the criteria and assumptions of NUREG-0654/FDiA-REP-1, Rev.1, Supplement 1.

FDiA was also requested to I

provide a findin, i.e., indicate whether in the freework of those criteria and asstrnptions, FDtA had reasonable assurance that the plans can protect the health ard safety of the public livirg in the vicinity of the plant.

Dat finding was delivered to the NRC on May 31, 1988.

Cn February 8,1988, NRC requested that FDiA evaluate a full-participation exercise of LIICO's offsite preparedness plan for Shoreham. Cn May 20,1988, and May 26, 1988, NRC staff agreed that the prcposed objectives subuitted by FD1A on May 13, 1988, were sufficient to demcostrate the capabilities of LIICO's local Dnergency ks;uns<, organization in a full-participation exercise.

they also stated their position that the objectives were sufficient to ecostitute a "qualifyirg " exercise under 10 CFR 50, Appendix E, Section IV.F.1 in that it srculd test as much of the emergency plans as is reasonably achievable i

without mandatory public participation.

On May 23, 1988, NRC requested that FD4A conduct a review of Revision 10 of the LItro of fsite plan against the criteria of.NUREG-0654/FDiA-REP-1, kv.1, i

Supplement 1 and the three asstanptions stated below.

NRC also requested that Nvision 10 charges be incorporated into the exercise play of the upcaniry Shorehe exercise. Since a full Regional Assistance Ccmittee (RAC) review cculd not be conducted in the short time frame remainirg before the exercise, FD4A Region II agreed to review the charges, coordinate with the RAC where necessary, and incorporate them into the evaluation of the exercise.

The asstinptions upcn which the plan review aid the exercise were based are that in an actual radiolcgical emergency, State and local officials that have declined to participate in energency plannirg wills s

1) Exercise their best offorts to protect the health and safety of the publics
2) Cocperate with the utility ard follow the utility plan, and
3) Have the resources sufficient to implement those portiens of the utility offsite plan where State aid local response is v

necessary.

gq()9rGiO3%

It is further understood that in any subsequent hearings or litigation related to the plan review or exercise, NRC will defend the above assu.ptions.

On August 31, 1988, yow also aquested that FWA review certain updated letters of agreement in conjunction with FE4A's ongoing review of Revision 10.

Enclosed is a report on the results of a full review of Revision 10 of the LIICO plan and the abovementioned letters of agreement, conducted by FTA Region II and the RAC. De Shoreham exercise was conducted on June 7-9, 1988.

Enclosed is a copy of the Post-Exercise Assessment, dated Septa-ter 2,1988, containing the results of FWA's evaluation.

It was prepared by F&A Region II.

Were were no deficiencies identified in the exercise. However, there are scme areas requiring corrective action. FWA is requesting LIIf0 to sutmit a schedule of actions that they have taken or interd to take to correct both plan-related and exercise-related inadequacies.

As indicated in the plan review, Revision 10 contains 94 plan elements rated adequate and 7 plan eierwnts rated inadequate.

Scne of the inadequacies were revealed as shortecnings in the exercise requiring further implementing detail in the plan. However, the exercise demonstrated adequate overall preparedness on the prt of Ia0 personnel, and therefore, based on the evaluation of the plan and the exercise, and the reccrrmendation of FWA Region II, FC% has reached a finding of twasonable assurance.

By way of clarification, w would like to note for the record that the enclosed plan review did not reevaluate Elements C.2.b, C.2.c, E.3 and E.4 a-n, since they are to be removed frm the final version of NUREG-0654/FDtA-REP-1, Rev.1, Supplement 1.

Se review also does not take into consideration any possible ramifications of ongoing litigation in the State of New York concerning LIIf0's reception center at Bellmore. Although the Supreme Court of the State of New York, Nassau County, has ruled on that issue, it is our understanding that LIIf0 is appealing that ruling.

Finally, the review also did not consider the so-called ministerial changes listed as part of Revision 11 of the LIIf0 plan, although incorporated in Revision 1 of the SNPS Prt:rtpt tbtification ard Design Report. You requested that FDtA review that revision to the design report on August 16, 1988. Our consolidated report on the SNPS alert and notification syste will contain our evaluation of those changes, unless a full RAC review

(.f any potential Revision 11 of the entire plan is produced first.

We hope that the above infomation is useful. If you have any questions, please feel free to call me at 646-3692.

Si ad.

t.

n Associate Director

. Statt and local Programs and Support Enclosurus As Stated

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