ML20154R647

Forwards Rept on Results of Full Review of Rev 9 of Util Offsite Emergency Plan Using Criteria & Assumptions Specified by Nrc.Based on Evaluation,Rev 9 Contains 17 Inadequacies.Suggests Postponement of Exercise

ML20154R647
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/31/1988
From:	Gordon Peterson Federal Emergency Management Agency
To:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20154P084	List: ML20154P080 ML20154R641 ML20154R647 ML20154R682 ML20154R704
References
RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8806080096
Download: ML20154R647 (6)

Text

-

Federal Emergency Management Agency l Wuhington. D.O. 20472 MAY 31 1988 Mr. M ctor Stello, Jr.

Executive Director for Operations belear Regulatory Commission Wa shington. 0.C. 20555

Dear Mr. Stello:

On January 27, 1988, the Nuclear Regulatory Connission (NRC) requested the Federal Emergency Managment Agency (FEMA) to review Revision 9 of Long Island Lighting Company's (LILCO) offsite emergency plan for the Shoreham Nuclear Power Station, under the provisions of the April 1985 WtC/ FEMA Femorandum of Understanding and certain criteria and asseptions,

.s indicated below. FEMA was also requested to provnb a finding, i.e.,

indicate whether in the framework of those criteria and asseptions, FEMA has reasonable assurance that the plans can protect the health and safety of the public living in the vicinity of the plant.

We were requested to review the plan under the criteria of the interie-use i document entitled Criteria for Preparation and Evaluation of Radiological j Emergency Response Plans and Preparedness in Support of Nuclear Power l Plants (Criteria for Utility Of fsite Planning and Preparedness). That document has been pubitsbed as 5' upp1 ment 1 to NmEG 0654/ FEMA REP-1, Rev.1.

As requested by NRC, FEMA also used 3 assumptions in reviewing and evaluating the LILC0 plan. Those asseptions are that in an actual radiological misency, State and local officials that have declined to participate is energency 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 offsite plan where State and local response is necessary.

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

Enclosed is a report on the results of a full review of Revision 9 of the LILCO p1 An, conducted by FEMA Region !! and the Regional Assistance Cowalttee (ItAC), using the criteria and asstrnptions specified by MtC. Ba sed on 7 :: Of 2 ; .

hL 6 .t . Eg c m k .. 4: f' f' " ' a'

( $ t C(e Di> O@qb. V1 J

-t o that evaluation, Revision 9 contains 17 inadequacies. More detail on the review process and the inadequecies is contained in the enclosed report f rom FDA Region !! to F EMA Headquarters. 84 sed on these inadequacies, and the recomendation of FDM Region 11. FmA does not have reasonable assv-ance under Revision 9 that the public health and safety can be protected in the vicinity of the Shoreham Nuclear Power Station.

Monever, planning for the exercise may go forward for the reasons noted bel ow. First, the utility has already provided FDA Region II and the RAC with proposed plan changes to address these inadequacies. lie understand that these changes were incorporated into Revision 10 of the plan. Eleven of the inadequacies in Revision 9 required relatively minor changes and the utility's J t

proposed changes were responsive to the RAC/FmA concerns. For the six taadequate elements requiring more substantive revision, five of these ((i.e.,

previsions for communication with New York State (F.1.b), the pubite information program for residents, transients, 44 the agricultural comunity (6.1.a e,  !

G.2, and J.11), and written agreements for "first-call' connitaents with '

companies supplying supplementary buses for a "one-wave' evacuation of school (J.10 9)), will not affect the conduct of the exercise, ntith regard to the remaining inadequacy that must be evaluated at the exercise (i.e., planning for the monitoring and decontamination of school children evacuated after a release (J.12)), FEMA Region 11 provided technical assistance to the utility to expedite the resolution of this issue for its inclusion in Revision 10.

b May 23,1988, NRC requested FEMA to conduct a full RAC review of Revision 10 of the plan and provide a finding by July 29, 1988. *C has also requested that the Revision 10 changes be incorporated into the exertise play of the upcoming Shoreham exercise, now scheduled for the week of June 6,1988.

Since FEMA would not be able to complete a full RAC review in that short time frame, FEMA Region 11 has agreed to review the changes, coordinate with the RAC where necessary, and incorporate them into the evaluation of the exercise.

A cursory review has been performed by FDiA Region !! of the sections of tavision 10 relating to the inadequacy concerning the monitoring and decon-tamination of school children mentioned above in connection with elsnent  :

j J.12. Based on that review, we have concluded that the inadequacy has been '

eddressed in a manner sufficient to permit an adequata demonstration of the acnitoring and decontadnation function in the exercise.

net note also that on April '!?,1988, the Director of the Connecticut Office of Civil Preparedness notifwi LILC0 that his office 'would participate in an interstate exercise oni) in full coordination with the participating states and local goverroents. ide have received no such coordination."

Me further indicated that his of fice will not "conduct any exercise evaluation activities or any simulation activities during the proposed exercise conducted by LILCO.' This as fully discussed by members of our staffs on May 3,1988.

As discussed at the meetinfi, although the State of Connecticut has not withdrawn frta participation in offs te emergency planning for the Shorehen plant. It urill be considered by MRC as a non-participating government for purposes of the exercise. As a consequence, as stated in RC s memorandum of May 26, 1988, stC stafI finds appropriate that the role of the State will be simulated through the use of a control cell, since the participation of the State is act reasonably achievable.

3 nde have also received the May 26, 1988 confirmation from NRC staff that the May 25,1988 advisory opinion from the Atomic Safety Licensing and Appeal Boah$ does not change NRC staf f's view that the current objectives for the exercise would constitute a qualifying exercise under SC regulations. It is also our understanding that this confirmation has the concurrence of the NRC Of fice of General Counsel. j 1

The above pre-exercise arrangements notwithstanding, we think it only prudent to raise the question of whether the planned FD4A evaluated exercise should proceed at this time. It is our understanding that only recently, LILC0 and the State of New York reached 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 $horeham will not continue to operate. In light of the additional expenditure of funds about to be spent related to the Shoreham exercise, it would be more judicious, in FD4A's view, to postpone a FD4A-evaluated exercise at least until further resvits from the negotiations between LILCO and New York are made public. Of course, postponenent of the exercise would not prohibit consinued planning and plan review litig: tion. Since there are only 4 working days left before the s,cheduled start of the exercise activities, please let vs know in writing by COB June 1,1988, of your position on this matter. If you agree with FDtA s position, we would also ask you to advise LILCO. If you disagree, please include your full rationale.

If you have any questions, please feel free to contact se or Dave McLoughlin at 646-3692.

$1 erely, Grant C. Peterson Associate Director State and Local Programs and Support Enclosure As Stated

Federal Emergency Management Agency Region 11 26 Feders! Ptaza New Yort. New Yort 10278 May 6. 1988 NEMORANDUM FOR: Grant Peterson Associate Director.

State and Local Programs and Support l

Jack Sable M*

FROM :

Regional Director

SUBJECT:

RAC Review Comments for the !.!LCO Local Of f site Radiological Energency Response Plan for Shoreham, Revision 0 Per your request of February 16, 1988 attached is the review of the ref erenced plan which has been conducted As ref erenced by the Region on each!!page IRAC).

Regional Assistance committeethis review has been conducted in accoraance of the document , jointly developed by with the interin-use and consent documentfor Preparation and Evaluation of FEMA and NRC entitled: Criteria  !

Radiological Emergency Response Plans and Preparedness in Support I of Nuclear power Plants (Criteria for Utility Of 1. fsite Supp.Planning

1. In l and Preparednessi; NUREG-0654/ FEMA-REP-1, Rev. in an reviewing this plan. FEMA and the RAC have assumed that actual radiological ene?gency. State and local of ficials that have declined to participate in emergency planning for the  ;

Shoreham plant will. i (1)

Exercise their best ef forts to protect the health and safety of the public; (2) Cooperate with the utility and follow the utility offsite plan; and to implement those (3) Have the resources suf ficient l portions of the utility of f aite plan where State atad local respor.se is necessary.

A2though Revision 9 constitutes a major revision, af fecting more than 3000 pages of L1LCO's plan, the Local Energency Response Organization's (LEFO's). concept of operations remains essentially unchanged from previous versions of the plan that have been reviewed. Therefore, this review builds upon RAC comments developed for previous revisions (Revs. 1, 3, 6, 6, 7, and Si of tha plan and this updated review reflects current operations, resources and stat.us of the utility's of fsite emergency planning effort. The following steps were taken in completing this review:

4 G. Peterson May 6 1983 Page of 3 (1) RAC comments for Revisions 5. 6. ano i heretofore cetailed in sepsrate documents. Ana : omments on Revision 8, were censolidated into one document dated 2/11/88 and was distributed to the RAC members.

I2) A preliminary review dated 3/17/88 of Revision 9 was conducted by FEMA Region II and contractors to the REP program. This preliminary review was distributed to the RAC, FEMA Headquarters and LJINU on : larch 18. 1988.

(3) Region 11 met with LILCO representatives on April 8, 1988 and received the utility's proposed actions to resolve items rated Inadequate til i n the 3/17/88 preliminary review comments.

(4) Detailed review comments on Revis on 9 of the plan were received f rom RAC member agencies and *.ere consolidated into an updated review document dated 4/21/s8.

(5) A RAC meeting, chaired by FEMA Regien 11 was held in our l of fices to finalize the attaened A record comments o1 this meeting ontranscribed.

was Revision 9 l of the plan.

In the course of developing the attached upcsted review, the following nomenclature has neen adapted from previous reviews:

A (Adequate) The element is adequately aodressed in the plan. Recommendations for improvement shown in italies are not mandatory, but their consideration would further improve the utility's of fsite emergency response plan.

I (Inadequate) The element is inadequately addressed in the plan for the reasontal stated in bold type.

The plan and/or procedures must be revised before the element can be considered adequate.

For ease of understanding, the reasontal an element has been rated inadequate is, where possible, stated first.

As a means of summarizing this rather lengthy review and for ease in understanding abbreviations used, an Element Rating Summary and List of Acronyms are provided at the end of the document.

t

' Seventeen (17) elements are currently rated inadequate (1) and.

in accordance with your request, Region 11 recommends a negative

' finding that the plan does not presently provide reasonable n + - - , , . - - - . - - _ - . = - , . _,---,y, -_- ,_,_ __, nn.,,,n ,_,_____, _-e._n_,._,,.,,,,

o .

l G. Peterson May 6, 1988 Page 3 of 3 i

i n the l assurance that adequate protectiveatmeasures Shorehan.can be taken event of a radiologleal emergency Planning First.

f or the exercise can go forward for two reaso ld be I proposed. plan changen to address these inadequacies that wouif  ;

incorporated, prior to the exercise. inadequacies require relatively minor plan. Elesen (III of these l

changes, and the utility's for proposed changes the six (6) inadequate elements are responsive to th I

RAC/ FEMA concerns. Second, five (5) of the se (i . e . , )

requiring more substantive revision, provisions for communications elements 0.1with New a-e. 0.2 York S and J.11; and the agricultural community, and written agreements for "first-call" cosaitments with companies supplying supplementary J.10.g) buses for a "one-wave"will no evacuation of schools, element With regard to the remasning inadequacy that must be evaluated at planning f or the monitoring and the exercise decontamination of school (i.e.. childron evacuated af ter a release, is providing technical assistance to the element J.12). FEMA utility to expedite the resolution of this issue for its inclusion in Revision 10.

With respect to LILCO's submission of Revision 10. FEMA will review the plan changes, coordinate with the RAC, and Should any incorporate them in the evaluation of the exercise.

additional changes be forthcoming, every ef fort will be made to incorporate them in the exercise as well.

I recommend that the exercise proceed Ihor Based on all of If the you above.

have any questions, please contact Mr.

as planned.

W. Husar. Chairman, Regional Assistance Cossittee, at FTS 649-8203.

i Attachment l

- - - - - - , - - .-,-------,-,---cw--,,----,,,-,---,_,,,,,--e,m..ncn---,--,-ann,,--,-n-~----,s-n---,,