ML20207D900
| ML20207D900 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/29/1986 |
| From: | Cumming W Federal Emergency Management Agency |
| To: | |
| References | |
| CON-#486-2030 OL-3, OL-5, NUDOCS 8612310286 | |
| Download: ML20207D900 (30) | |
Text
203E December 29, 1986 00cy rce 09 C
'86 DEC 30 p2:14 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION crrn -
nag: 7.
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
Docket No. 50-322-OL-3 (Emergency Planning)
)
LONG ISLAND LIGHTING CCMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1) )
FEMA GUIDANCE OF POTENTIAL APPLICABILITY TO SHOREHAM PLAN AND EXERCISE PROCEEDINGS FEMA Counsel hereby supplements the Decenber 17, November 25, 1986, and November 21, 1986 guidance documents served on all parties with the attached Dave McLoughlin to Regional Directors Memorandums both dated November 13, 1986, subjects: (1) Guidance Memorandum (GM) MS-1, Medical Services; and (2)Guldance memorandum (GM) EV-2, Protective Actions for School Children.
Respectfully submi ted, NM M.
William R. Cumming Counsel for FEMA Dated this 29th day of December, 1986 Washington, D.C.
8612310286 861229 PDR ADCCK 05000322 0
.hSo3
s i Federal Emergency Management Agency El Washington, D.C. 20472 L
MDORANDGi POR: Regional Directors M k g g@6 Acting Ngional Directors FROl:
Ioughlin puty Associate Director State and Tmal Programs and Supp3rt SUL7ECP:
Guidance Memorandtzn (Gi) MS-1, Medical Services he attached Gi MS-1, Medical Services, is forwarded for your use in providirg guidance to State and local officials in developing their radiological energency response plans and in evaluating the medical services capabilities of State and local goverments.
Se origins of this Gi and its development and approval have been somewhat i
different frm other Gl's.
'1his Gi was developed as a result of a series of legal decisions involvirq NRC which detemined that the existing interpretation of the required pre-accident medical arrangements for contaminated injured individuals was not sufficient. Those decisions led NRC to issue a policy statenent (Attachment B) on Septshr 17, 1936, irxlicating that the NRC staff (in ccusultation with FDiA) would develop detailed guidance on the necessary pre-accident arrargements for medical services by Novenber 17, 1986.
We have worked closely with NRC in recent weeks in the preparation of this guidance. Unfortunately, the short deadline did not permit our usual procedure of obtaining Ngional ard other emnents before issuing this final guidance.
If you have any questions about MS-1, you may contact Jees Tnomas at 646-2808. A list of all current operative Gl's ( Atuchment C) is also provided for your information.
ATTACHMENTS:
A.
Gi MS-1, Medical Services B.
Emergency Planning - Medical Services, Septenber 17,19 86, 51 FR 329 04 C.
List of Operative GM's l
l 1
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'i Federal Emergency Management Agency Washington, D.C. 20472 e
GUIDANCE MEMORANDUM MS-1 MEDICAL SERVICES Purpose This Guidance Memorandum (GM) provides interpretation and clarification of requiresents contained in the Nuclear Regulatory Comission rule,10 CFR 50.47 (b)(12) and the associated guidance in NUREG-0654/ FEMA-REP-1, Revision 1, re-Tated to the provision of medical services for members of the general public.
Background
The background is contained in a policy statement from the Nuclear Regulatory Comission (NRC) titled " Emergency Planning - Medical Services" (51 FR 32904).
In this policy statement, NRC states its belief that 10 CFR 50.47(b)TI2)
-(" arrangements are made for medical services for contaminated injured individuals") requires pre-accident arrangements for medical services (beyond the naintenance of a list of treatment facilities) for individuals who might be severely exposed to dangerous levels of offsite radiation following an accident at a nuclear power plant. As used in 10 CFR 50.47(b)(12) and planning Standard "L" of NUREG-0654/ FEMA-REP-1, Revision 1, the term " contaminated injured" means
- 1) contaminated and otherwise physically injured; 2) contaminated and exposed to dangerous levels of radiation; or 3) exposed to dangerous levels of radiation.
Guidance 10 CFR 50.47 (b)(12) requires that " Arrangements are made for contaminated injured individuals." In its policy statement the NRC determined that this standard requires pre-accident arrangements for medical services for offsite individuals who might be exposed to dangerous levels of radiation following an accident at a nuclear power plant. The following guidance applies to the eval-ua. tion of the medical services aspects of State and local emergency plans under the criteria in NUREG-0654/F04A-REP-1.
Standards, Evaluations Criteria. Areas of Reviews and Acceptance Criteria A.
Assignment of Responsibility (Organization Control)
Planning Standard Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various sup-porting organizations have been specifically established, and each principal
' response organization has staff to respond and to augment its initial response
's on a continuous basis.
~
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2 A.3. Evaluation Criterion Each plan shall include written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role within the Emergency Planning Zones. The agreements shall identify the emergency measures to be provided and the mutually acceptable criteria for their implementation, and specify the arrangements for exchange of information. These agreements may be provided in an appendix to the plan or the plan itself may contain descriptions i
of these matters and a signature page in the plan may serve to verify the agreements. The signature page format is appropriate for organizations where response functions are covered by laws, regulations or executive orders where separate written agreements are not necessary.
Areas for Review and Acceptance Criteria State or local governments should obtain written agreements with the listed medical facilities (Planning Standard L. Evaluation Criteria 1 and 3) and trans-l portation providers (Planning Standard L. Evaluation Criterion 4). The written d
agreements should contain simple assurances that the providers have adequate technical information (e.g. treatment protocols) and treatment capabilities for handling " contaminated injured" individuals. An indication of Joint Commission on Accreditation of Hospitals (JCAH) accreditation will suffice for such assurance.
(Note: Veterans Administration (VA), military and other government hospitals are not usually accredited by JCAH but usually have the desired capabilities.)
If state or local governments do not obtain written agreements, the licensee should obtain written agreements with the listed medical facilities and trans-4 portation providers.
If good faith efforts are not successful in a particular case, the licensee shall provide or arrange for adequate compensatory measures, e.g., obtain written agreements with other providers or provide temporary field medical care.
L.
Medical and Public Health Support Planninq Standard l
Arrangements are made for medical services for contaminated injured individuals.
L.I. Evaluation Criterion Each organization shall arrange for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.
=
1 3
Areas for Review and Acceptance Criteria _
There should be one primary local hospital and one backup hospital for each site for the evaluation and emergency treatment of " contamination injured" members of the general public. Hospitals are generally distributed proportional to the population. Thus, at sites with low population and few hospitals, the primary local and backup hospitals for members of the general public could be the same as those for the utility employees and emergency workers.
L.3. Evaluation Criterion Each State shall develop lists indicating the location of public, private and military hospitals and other emergency medical services facilities within the State or contiguous States considered capable of providing medical support for any contaminated injured individual. The listing shall include the name, location, type of facility and capacity and any special radiological capabili-ties. These emergency medical services should be able to radiologically monitor contaminated personnel, and have facilities and trained personnel able to care for contaminated injured persons.-
Areas for Review and Acceptance Criteria The lists should be annotated to indicate the ambulatory /non-ambulatory capaci-ties for providing medical support for " contaminated injured" members of the general public and any special radiological capabilities. This will enable state and local officials to direct members of the general public to those institutions capable of handling " contaminated injured" patients.
In the event that local and regional medical resources need to be supplemented, additional medical re-sources would be available through the Federal Radiological Emergency Response Plan. These resources would include the Radiation Emergency Assistance Center /
Training Site at'0ak Ridge, Tennessee and the National Disaster Medical System with headquarters in Rockville, Maryland.
L.4. Evaluation Criterion Each organization shall arrange for transporting victims of radiological acci-dents to medical support facilities.
Areas for Review and Acceptance Criteria Because the early symptoms of persons exposed to dangerous levels of radiation are usually limited to nausea and vomiting, ambulances may not be required to transport such persons to medical facilities. Rather, non-specialized public and private vehicles can be used, supported, if necessary, with agreements in accordance with A.3. above.
For other types of contaminated injured individ-uals, specialized transportation resources (e.g., ambulances) would be necessary and should be assured by agreements, if necessary, in accordance with A.3. above.
Provisions should be made for the use of contamination control in transporting contaminated persons to medical facilities.
. Planning Standard 0.
Radiological Emergency Response Training Radiological emergency response training is provided to those who may be called on to assist in an emergency.
0.4. Evaluation Criterion Each organization shall establish a training program for instructing and quali-fying personnel who will implement radiological emergency response plans. The specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided in the following categories:
h.
Medical support personnel Areas for Review and Acceptance Criteria Each hospital listed under Evaluation Criteria L.1 and L.3. shall have at least one physician and one nurse on call within about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> who can supervise the evaluation and treatment of radiologically " contaminated injured" members of the general public. There are several sources for this training including NRC licensee sponsored training. Transportation providers should have basic training in contamination control. Examples include but are not limited to:
1.
FEMA handbook, videotape, slides and instruction manual titled " Hospital Emergency Department Management of Radiation Accidents," SM 80/1984.
2.
Courses from The Radiation Emergency Assistance Center / Training Site (REAC/TS) at Oak Ridge Associated Universities.
3.
Audiocassette and text course, " Radiation Accident Preparedness: Medical and Managerial Aspects" by Science-Thru-Media Inc., 303 Fifth Avenue, Suite 803, New York, NY 10016.
N.
Exercises and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emer-gency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
i i
. N.2. Evaluation criterion A drill is a supervised instruction period aimed at testing, developing and A drill is often a component of maintaining skills in a particular operation.A drill shall be supervised and evaluate an exercise. Each organization shall conduct drills, in addition to the biennial instructor.
annual
- exercise at the frequencies indicated below:
c.
Medical emergency drills A medical emergency drill involving a simulated contaminated individual which' contains provisions for participation by the local support services agencies (i.e., ambulance and offsite medical treatment facility) shall be conducted The offsite portions of the medical drill may be performed as part annually.
of the required biennial annual
- exercise.
Areas for Review and Acceptance Criteria State or local governments should provide for the conduct of appropriate drills These medical and exercises which include " contaminated injured" individuals.
emergency drills involving the primary local (L.I.) hospital for state and local i
These drills should also test the governments should be conducted annually.
capability of relocation centers to direct " contaminated injured" members of the If State or local governments cannot general public to the appropriate hospital.
provide for the conduct of the drills, the licensee shall provide for the con-If good faith efforts are not successful in a particular duct of such drills.
case, the licensee shall provide or airange for adequate compensatory measures.
Implementation State and local emergency respense plans should reflect the provisions of this GM at the next annual update following 9 months from the effective date of this GM.
Plans for plants that do not have a full power operating. license should reflect t
The the provisions of this GM within 9 months of the effective date of this GM.
first medical drill reflecting the provisions of this GM should be conducted by the end of the next biennial exercise following I year from the effective date of this GM.
- Changes reflect language incorporated into GM PR-1.
Attachm2nt B 32908 Federal Register / Vol. 51. No.130 / Wednesday September 17.19ee / Roles and Regulations l such additional arrangements, the decision"), the Commission itself faced Commission leaves to the Informed for the first time the question whether s
Judgment of the NRC staff, subject to planning standard (b)(12) applied to general guidance from the Commission, members of the public who were the exact parameters of the minimally exposed to offsite radiation following an necessary arrangements for medical accident at a nuclear power facility but services. To fulfill this mandate the staff wm not otherwise injured, and if so to (and FD4A) willissue appropriate what extent. In considering this guidance to licensees, applicants, and quotion, the Commission sought the state and local governments.
views of the parties in the SONGS The United States Court of Appeals proceeding, reviewed the principal for the District of Columbia (" Court")
purposes of the planning standard.
vacated and remanded a previous analysed the likelihood of serious Conuaission Interpretation of plannint exposures to the public requinag l
standard (b)(12) which required only the emergency medical treatment, and
)
development and maintenance of a list evaluated the type of emergency of treatment facilities on which post-treatment likely to be required. Based on event, odhoe strangements for medical this review, the Commission concluded treatment could be based. CUARD v.
as a generic matter that:(1) Planning NRC 753 F.2d 1144 (D.C Cir.1985).
stanelard (b)(12) applied to individuals j
Pending final Commission acHon in both onsite and offsite:(2) response to the CUARD remand, the
" contaminated injured individuals" was Commission issued a statement of intended to include seriously irradiated interim guidance which permitted-members of the public as well as pursuant to 10 CFR 50.47(c)(1), the members of the public who are not i
issuance of full power licenses where seriously irradiated but also are the applicant satisfied the requirements traumatically knlured from other causes i
of planning standard (b)(12) as and radiologically contaminated: and (3) interpreted by the Commission prior to Adequate, post-accident arrangements CUARD, and where the applicant for necessary medical treatment of committed to full compliance with the exposed members of the public could be Commission's final response to the made on an adhoc basis if emergency CUARD remand.The Commission's ans contained a list of local treatment prior interim guidance will continue to cuides.
vern the issuance of full power censu unut issuance and On appeal the United States Court of implementation of the NRCstaff's Appeals for the D.C Circuit concluded specific guidance on this matter, at that the Commission had not reasonably which point the new policy will apply.
interpreted planning standard (b)(12) when it generically found that a pre-Errtemt sAft September 17,1906.
accident list of treatment faci.ities l
Pos PUWTHen *Fon88ATiON CONTACT constituted " arrangements" fer post.
C Sebastian Aloot. Office of the accident medical treatment. CUARD v.
General Counsel U.S. Nuclear NRC 753 F.2d 1144 (D.C Cir 1985). For NUCLEAR REGUl.ATORY Regulatory Commission. Washington.
this reason, the Court vacated and COMMISSION DC 20555. Telephone (202) 634 3224.
remanded that part of the Commission's SUPPLEaststfAnY asFOnesAftost SONGS decision that hadinterpreted 10 CFR Part 50 I. Introduction planning standard (b)(12) to require only the preparation of a list oflocal i
Emrgency __ _;
In the wake of the Three Mile Island treatment facilities. However. in doing
- - =
Semicos accident in 1979, the Nuclear Regulatory so, the Court made clear that the 3
Aesseev: Nuclear Regulatory Commission ("NRC" or "Conunissics")
Commission had on remand. in its sound aulgated mgulations mquiring its Conunission.
fcensees and applicants for licenses todisemtion. flexibility in fashionind a g
reasonable interpretation of planning AcTiest Statement of Policy on Emergency Planning Sunderd to CFR operate commercial nuclear power standard (b)(12).
i 50.471b)(12).
mactom to develop plans for emergency responses to accidents at their facilities.
D. A.T -
-ts Beyond A IJet Of e-aa=v:De Nuclear Regulatory Among those requirements waa10 CFR Tmatmot Faciudes Requimd Commies!on ("NRC"or " Commission")
50.47(b)(12)(" planning standard When originally faced with the believes that to CFR 50.47(b)(12)
(b)(12)"), which provides:
question whether the phrase
(" planning etandard (b)(12)") requires (b)m easies sad streite emersuncy
" contaminated injured individuals" was Pre-accident arrangements for medical response plan for nuclear power :=ectors Intended to encompass.intercha, services (beyond the maintenance of a must meet the following standards:
members of the public who, as a result list of treatment facilities) for (121 Arrangements are made for medical of an accident, were exposed to individuals who might be severely
"'** f*' *'**ia*d Lalud ladivid**!*-
dangerous levels of radiation, the exposed to dangerous levels of offsite In Southern California Edison Commission found no explicit and L
radiation following an acciden' at a Company et of. (San Onofre Nuclear conclusive definition of the phrase in the I
ruclear power plant. While concluding Generating Station. Units 2 and 3). C1J-regulation itself orits underlying i
that planning standard (b)(12) requires 83-10.17 NRC 528 (1963) ("SONCS) documents. Nonetheless, the l
NRC Coordination This Guidance Memorandum has been prepared in coordination with the NRC staff, As noted in the referenced NRC Policy Statement, the Commission has determined that these modifications fall under the backfit rule's exception as necessary to bring facilities into compliance with a rule of the Commission.
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Federal Register / Vol. 31, No.180 / Wednesday. September 17, 5986 / Rules and Regulations 32905 Commission concluded that the prudent De minimeTly necessary The Commission has determined that risk reduction purpose of the arrangements for the person that may be the arrangements contemplated under Commission's regulations required exposed need not be elaborate. As this Statement of Policy are the interpreting planning standard (b)(12) to previously atsted by the Commission, sninimu:n required by a reasonable apply to such offsite exposed
"[ijt was never the intent of the reading of planning standard (b)(12).
Individuals.given the underlying regulations to require directly or Accordingly, although implementation of assumption of the NRC*a emergency indirectly that state and local this reading of the standard will entail planning regulations that a serious governments adopt extraordinary some additions to, and some accident could occur and the measures, such as construction of modifications of, the emergency Commission presumption that such an additional hospitals or recruitment of procedures and organizations for which accident could result in offsite substantial additional medical heensees are ultimately responsible, the ladividuals being exposed to dangerous personnel. lust to deal with nuclear requirements of the backfit rule.20 CFR levels of radiation (a presumption plant accidents."17 NRC at 533.Rather.
50.109 (1986), for a cost-benefit analysis concurred in by the Federal Emcrgency the Commission believes that and a finding that the costs of the Afanagement Agency). After satisfactory arreryments should modifications are justified by a reconsideration of this matter following include (1) a list os local or regional substantialincrease in safety are not the CUARD decision. the Commission medical treatment facilities and applicable. sloce these modafications fall has decided to re.affinn this prior transportstion providers appropriately under the backfit rule's exception for -
interpretation of planning standard annotated to show their capacities, modifications necessary to bring (b)(12).
special capabilities or other unique facilities into compliance with a rule of However, the Commisalon has come characteristics. (2) a good faith the Commission.See 10 CFR 50.109 to a different result with respect to the reasonable effort bylicensees orlocalor (a)(2) and (a)(4)(1986).The analysis minimum arrangements necessary foe state governments to facilitate or obtain whach the backfat rule requires be done individuals who might be seriously written agreements with thelistad to justify the application of any of its exposed, but not otherwise injured. in a. medical facilities and transportation exception provisions constitutes the radiologic emergency. In originally providers. (3) provision for maktag core of this Statement of Policy.See /d
)
resolving the scope of arrangements available necessary training for DI. Interim Guidamos issue, the Commission focused on the emergency response personnel to particular needs of offsite exposed identify transport,andprovide In its prior statement of policy.the individuals for emergency medical emergency first aid to severely exposed Commission identified three factors I
treatment of their redistfon injury.in individuals, and (4) a good faith which justified an interim policy of this fashion. the Commissen made a reasonable effor*. by licensees or state or rranting applicants for full-power J
local gesernments to see that ficense an equitable exception to the distinction between the need for e
1 immediate or near-term medical care, appropriate drifh and exercises are requirements of planning standard which was in its view the goal of conducted which include simulated (b)(12) under 10 CFR 50.47(c)(1) where planning standard (b)(12), and the need severely exposed individuals. lf good the applicant satisfied the requirements for long term medical care. As to faith efforts are wi successfulin a of planning standard (b)(12) as exposed individuals, the Commission particular case the F:ensee shall interpreted by the Commission prior to found that:
provide or arrange for adequat:
the GUARD decision and committed the special haurd le posed by the reestion compensatory measures consistant with itself to full compliance with any exposure to the patient.The nature of the Commission's intent to limit the additional requirements imposed by the ta&ation infury is that, while me& cal need for extraordar.ry maasures noted Commission in response to the GUARD treatment may be eventually required in above.The compensatory measurve remand. Ststement of policy on cases of extreme exposure. the petients are must be approved by NRC.This level of Emergency Planning Standard to CFR untaely to need emergency me& cal care planning would help (1) provide 50.47(b)(12). 50 FR 20891 (May 21.1985).
t (footnote omittedl.The non tame &acy of the additional assurance of the cooperation The three factors were:(1) the treatment required for todietioneupueed of medical facilities. (2) ensure proper possibility that the scope of planning indaiduale provides onsite and offata training. (3) ensure the availlability of standard (b)(12) would be limited; (2) transportation, and (4) demonstrate a the possibility that delay in comptia=
g, g
i (17 NRC 53k38.)
Capability to provide necessary services with the post GUARD requirements through drills and exerciaea.
could be found to be insignificant due to From this, the Cosiminalon reasoned The Commission has directed the staff the low probability of accidents durms that the long-term treatment needs of to develop. consistent with this the interim period, and (3) the possibibty exposed individuals could be interpretation of the planning standard, of **other compelling reasons" justifung adequately met on odhoc basis.
detailed and spectile guidance on the a briaf exception where applicants had t
After reconsideration la light of the nature of the medical services to be relied in good faith upon prior CUARD decision. the Commission has available to exposed individuals and on Commission interpretation of planning sancluded that some additional planned the application of planning standard standard (b)(12).
arrangements beyond the development (b)(12) to NRC !!censees and applicanta In this Statement of policy interpreting of a list of treatment facilities are for licenses to operate commercial planning standard (b)(12) the necenary to provide additional nuclear power reactors. 'Ihe Commission directs the NRC sta!! to assurance of effective management of Comminion has also directed the staff develop (in consultation with TEMA) emergency medical servlees in the hours to constder whether and under what and issue by 11/17/8e appropriate or days following a severe accident.
criterie it is necessary or appropriate for detailed guidance on the exact contours However, the Commluton continues to the etalT to verify the appropriateness of of the necessary arrangements believe that the long term treatment training. and drills or exercises consistent with the Coconission's needs of exposed individuale can be associated with de handling of severely determination that planning standard adequately met on adhoc basta.
exposed persons.
(b)(12) require arrangements for medical
- --- - -- - A
32906 Federal Reglster / Vol. 51 No.100 / Wednesday. September 17, 1986 / Rules and Regulations services (beyond the maintenance of a list of pre-existing treatment facilities) for offsite exposed individuals.The Commission believes that the last two factors discussed in detailin its May 21 1985 Statement of Policy, continue to
~
justify reliance on the interim guidance for the period necessary for the h1C staff to issue and licensees, applicante, and state and local governments to implement the detailed guidance.
Therefore, until appropriate detailed guidance consistent with this policy statement is issued and implemented.
the Ucensing Boards may continue to reasonably find that any hearing l
regarding compliance with to CFR 50.U(b)(12) shall be limited to issues which could have been heard before the l
Court's decision in CUARD v.NRC.
Dated at Washington, DC, this 12th day of,
September.tese.
[
For the Nuclear Regulatory Comunission.
SamuelI. Chilk.
Socistory of the Commission.
[FR Doc. 46-21054 Filed D-16-elk 8.45 am]
saama cosa reso43.es l
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s Federal Emergency Management Agency g
Washington, D.C. 20472 e
Attachment C November 13, 1986 OPERATIVE GUIDANCE MDORANDA Number
_Date Title 4
4/1/80 Radio Transmission Frequencies and Coverage 5
4/1/80 Agreements Among Governmental Agencies and Private (Revised-Parties 10/19/83) 8 4/2/80 Regional Advisory Cmunittee Coordination with Utilities (Revised-10/19/83) 16 8/7/80 Standard Regional Reviewing and Reporting Procedures for I
State and Iocal Radiological Dnergency Response Plans 17 1 /8/ 81 Joint Exercise Procedures 18 5/21 /81 FDtA Action to Qualify Alert and Notification Systems (Revised-Against NUREG-0654/ FEMA-REP-1, Rev. I 10/19/83) 20 10/19/83 Foreign Language Translation of Public Education Brochures
'1 and Safety Messages 21 2/27/84 Acceptance Criteria for Evacuation Plans 22 10/19/83 Recordkeeping Requirements for Public Meetings 24 4/5/84 Radiological Emergency Preparedness for Handicapped Persons EX-1 7/15/85 Remedial Exercises EX-2 7/15/85 Staff Support in Evaluating REP Exercises 1
PR-1 10/1/85 Policy on NUREG-0654/FDiA-REP-1 and 44 CFR 350 Periodic Requirements 1
2 IT-1 10/1/85 A Guide to Documents Related to the REP Program FEMA Action to Pilot Test Guidance on Public Information PI-l 10/2/85 Materials and Provide Technical Assistance on Its Use FR-1 12/3/85 Federal Response Center i
MS-1 11/13/86 Medical Services W -2*
11/13/86 Protective Actions for School Children
- GM-21 will be retitled as GM W-1 when it is revised.
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gg@?,giFederal Emergency Management Agency Q;
Washington, D.C. 20472 NOV i 3 !953
?!E!*ORAllDU!l FOR:
All. Regional Directors, Acting Regional Directors FRO!!:
Dave ficLoughlin Ity Associate Director (e and Local Programs and. Support SUDJECT:
Guidance Memorandum (Git) EV-2, Protective Actions for School Children.
I am attaching Gt! EV-2, f or your use in reviewing radiological emergency preparedness (REP) plans and exercises.
This guidance provides clarification and interpretation of applicable 11UREG-0654/PE!!A-REP-1 criteria and, as such, has been concurred in by 11uclear Regulatory Commission staff.
I appreciate the assistance of your Regional Office REP staff who provided comments on the draf t edition of this document.
If you have any questions on use or implementation of the G!!,
please get in touch with Bill !!c!!utt, 202-646-2657, of my staff.
t.ttachment As Stated
k Federal Emergency Management Agency
- '.5 Washington, D.C. 20472 NOV 1316 -
GUIDANCE MEMORANDUM EV-2 PROTECTIVE ACTIONS FOR SCHOOL CHILDREN PurDose This Guidance Memorandum (GM) is intended for Federal officials to aid them in evaluating emergency plans and preparedness for school children during a radiological emergency.
This guidance is also intended for State and local government officials and administrators of public and private schools, including licensed and government supported pre-schools and day-care centers, for developing emergency response plans and preparedness for protecting the health and safety of students.
Backaround The joint Federal Emergency Management Agency (FEMA) and Nuclear Regulatory Commission (NRC) guidance document, NUREG-0654/ FEMA-REP-1, provides criteria for protective actions for persons, including school children, within the plume exposure pathway emergency planning zone (EPZ) in the event such protective actions are needed in response to a radiological emergency at a commercial nuclear power plant.
The need to address the issue of protective actions for school children stems from both the lack of detailed guidance on this issue and the expressed interest for such guidance from public interest groups, State and local government officials and Federal Regional officials.
ScoDe Guidance is provided in this GM on school evacuation in two I
contexts:
for developing emergency response plans and for conducting and. evaluating exercises.
The primary method for protecting school children examined is evacuation to relocation centers.
This GM is a companion of the guidance on evacuation contained in GM 21, Acceptance criteria for Evacuation Plans.
This specific guidance related to school children is appropriate because of the interest and concern expressed about protecting the health and safety of school children during a radiological emergency at a commercial nuclear power plant.
2
School Evacuation Considerations Evacuation is Relocation Centers.
The evacuation of school children under the continuous supervision of teachers and administrators from a school to a relocation center is a viable and reasonable approach when conf ronted with a radiological emergency.
The decision to implement a protective action recommendation to evacuate to a relocation cente'r should be tied to the -nuclear power plant's emergency action level classification.
Some emergency response plans include the protective action strategies of early evacuation and early dismissal.
If State 4
and local governments select one of these strategies, then they ought to address it in their emergency response plan.
If a State or local government elects to employ early evacuation or early' dismissal, this guidance is sufficiently flexible to cover both strategies.
All of the general guidance for evacuation would apply with the addition of the special considerations for early protective actions at the end of this GM.
The recommendation to school officials to evacuate the school children to relocation centers should specify the area (s) to be included in the evacuation.
For example, the evacuation could include schools within the two-mile radius of the plant and within three downwind sectors beyond the two-mile radius.
Prompt evacuation is not advisable during exceptional situations such as having to drive through a radioactive plume or into a severe blizzard.
Under these circumstances, the special population including school children, handicapped and/or immobile persons should be temporarily sheltered and subsequently evacuated, if need be, as soon as conditions permit.
School children and other special population evacuees (see also GM 26, REP for Handicapped Persons) should be. relocated outside the ten-mile EPZ in predesignated facilities to ensure that the accountability, safety and security of the evacuees can be maintained and to minimize vehicular traffic and telephone use within the EPZ.
General Considerations.
For whatever protective action options are contained in emergency plans, the plans should include provision for notifying parents and guardians (e.g.,
through the Emergency Broadcast System (EBS)) of the status and location of their children during a radiological emergency.
Also, the plans should document the decision making process and criteria used for developing emergency procedures for implementing protective action measures for school children.
Acceptance criteria for developing and evaluating emergency planning and preparedness for school children are provided below.
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Plannino Standa'rd add Evaluation Criteria
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J..
Protective ResDonse Plannino Standard A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public.
Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
(NUREG-0654/ FEMA-REP-1,
- p. 59)
Evaluation Criteria 2222 Each State and local organization shall establish a capability for implementing protective actions based upon protective action guides and other criteria.
This shall be consistent with the recommendations of EPA regarding exposure resulting from passage of radioactive airborne plumes (EPA-520/1-75-001), and with those of DUEW (DHHS)/FDA regarding radioactive contamination of human food and animal feeds as published in the Federal Reaister of Becember 157 19987 f43 PR 58990t October '22,1982111 IE 47073).*
J.10.
The organization's plans to implement protective measures for the plume exposure pathway shall include:
J.10.a.
Maps showing evacuation routes, evacuation areas, preselected radiological sampling and monitoring points, relocation centers in host areas and shelter areas (identification of radiological samplir.g and monitoring points shall include the designators in Table J-l or an equivalent uniform system described in the plan);
J.10.b.
Maps showing population distribution around the nuclear facility.
This shall be by evacuation areas (licensees shall also present the information in a sector format);
J'.10. c.
Means for notifying all segments of the transient and resident population; J.10.d.
Means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement;
- For your information and reference, the 12/15/78, DHHS guidance has been superseded by the 10/22/82, guidance.
3 i
J.10.o.
Means of relocation; i-J.10.h.
Relocation centers in host areas which are at least five miles, and preferably ten miles, bevond the boundaries-of the plume exposure EPZ (See K.8);
J.10.1.
Time estimates for evacuation of various sectors and distances based on a dynamic analysis (time-motion study under various conditions) for the plume exposure pathway EPZ (See Appendix 4);
ADoendix ft Evacuation Ilmg Estimates Within thg Plume i
Excosure Pathway Emeroency Plannino 12D2 Accendix 4.II.C. Soecial Facility Population An estimate for this special population group shall usually be done on an institution-by-institution basis.
The means of transportation are also highly individualized and shall be described.
Schools shall be included in this segment (p.
4-3).
Areas gf Review These evaluation criteria address the key planning requirements concerning the evacuation of students from i
schools.
The review under these criteria is intended to ensure that adequate planning and preparedness capabilities exist to enable school officials to evacuate students in the event such a protective action is necessary durin.g a radiological emergency.
This guidance covers those actions from the initial notification to school officials of the need to evacuate the students to their arrival at relocation centers or other protective actions.
In addition to these actions, the guidance also addresses time frames for accomplishing the protective actions.
For purposes of definition and reference to NUREG-0654/ FEMA-REP-1, we are including " schools" among the types of institutions, the mobility of whose population may be impaired during a radiological emergency, because most students are dependent on school officials for transportation,, - -
to and from their residences.
(See evaluation criterion 4,
J.10.d. )
Also, " schools" are explicitly referenced in Appendix 4 on pages 4-2 and 4-3 as a type of "Special Facility Population" for which evacuation time frames are needed on an institution-by-institution basis.
The term,
" schools," as used in this GM refers to public and private schools, and licensed or government supported pre-schools and day-care centers.
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AcceDtance Criteria An emergency plan will typically be acceptable under these evaluation criteria if it fully addresses the following emergency functions for the evacuation of, or other appropriate protective measures for, school children.
Local governments should take the initiative to identify and contact all public and orivate school systems within the designated plume exposure pathway EPZ to assure that both public and private school officials address appropriate planning for protecting the health and safety of their students f rom a commercial nuclear power plant accident.
The planning of both the public and private school officials should be closely coordinated with that of the local government.
Local governments should ensure that appropriate organizational officials assume responsibility for the emergency planning and preparedness for all of the identified schools.
Local governments should also ensure that the emergency planning undertaken by these organizations is integrated within the larger offsite emergency management framework for the particular nuclear power plant site.
In accordance with the guidance contained in GM 21, the evacuation planning undertaken may be developed in three contexts:
(1)
Part of the existing radiological emergency preparedness plans, (2)
A separate annex of.an existing integrated emergency plan for many types of disasters and emergencies or (3) A separate evacuation plan for all of the schools in each school system.
1 School officials should document in the plan the basis for determining the proper protective action (e.g.,
evacuation, early preparatory measures, early evacuation, sheltering, early dismissal or combination) including:
Identification of the organization and officials responsible for both planning and effecting the protective action.
Institution-specific information:
- Name and location of school;
- Type of school and age grouping (e.g.,
public elementary school, grades kindergarten through sixth);
5
- Total population (students, faculty and other employees);
- Means for effecting protective actions;
- Specific resources allocated for transportation and supporting letters of agreement if resources are provided from external sources and
- Name and location of. relocation. center (s), and transport route (s), if applicable.
If parts of the institution-specific information apply to many or all schools,.then the information may be presented generically.
Time frames for effecting the protective actions.
Heans for alerting and notifying appropriate persons and groups associated with the schools and the students including:
- Identification of the organization responsible for providing emergency information to the schools;
- The method (e. g., siren and ' telephone calls) for contacting and providing emergency information on recommended protective actions to school officials;
- The method (e. g., siren, tone alert radios and telephone calls) for contacting and activating designated dispatchers and school bus drivers; and
- The method (e.g.,
EBS messages) for notifying parents and guardians of the status and location of their children.
Plannino Standard and Evaluation Criteria 4
i N.
Exercise add DI. illa Plannina Standard p"
Periodic exercises are (will be) conducted to evaluate major 4
portions of emergency response capabilities.
Periodic drills are (will be) conducted to develop and maintain key skills.
Inadequacies identified as a result of exercises or drills are (will be) corrected.
(NUREG-0654/PE MA-REP-1,
- p. 71) 6
Evaluation Criteria N.l.a.
An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and
+
organizations.
The emergency preparedness exercise shall simulate an emergency that results in offsite radiological releases which would require prompt response by offsite authorities.
Exercises shall be conducted as set forth in NRC and FEMA rules.
N.l.b.
An exercise shall. include mobilization of State and local personnel resources adequate to verify the capability to respond to an accident scenario requiring response.
The organization shall provide for a critique of the biennial exercise by Federal and State observers / evaluators.
The scenario should be varied from exercise to exercise such that all major elements of the plans and preparedness organizations are tested within a six-year period.
Each organization should make provisions to start an 4
exercise between 6:00 p.m. and 4:00 a.m.
once every six years.
Exercises should be conducted during different seasons of the year within a six-year period in order to provide for exercising under various weatger conditions.
Some exercises should be unannounced H232 Official observers from Federal, State or local governments will observe, critique and evaluate the required exercises.
A critique shall be scheduled at the conclusion of the exercise to evaluate the ability of organizations to respond as called for in the plan.
The critique shall be conducted as soon as practicable after the exercise, and a formal evaluation should result from the critique.
l Areas 21 Review These evaluation criteria address exercise-related requirements and their evaluation by Regional Assistance Committee (RAC) staff.
In addition to identifying l
capabilities for evacuating students or effecting early dismissal as a " major element" of an organization's emergency response plan, suggestions are provided for conducting interviews with officials from schools during an exercise.
l
- These provisions conform to the revision of evaluation criterion N.l.b. of NUREG-0654/ FEMA-REP-1 promulgated in GM PR-1, Policy on NUREG-0654/ FEMA-REP-1 and 44 CFR 350 Periodic Requirements.
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- -. -. - -.,,,. - - - - - - -. - - - _ -. - - _. -. - - - ~. - -,,.. - - - - - - - - -
Acceptance Criteria Requirements are set forth in FEMA (44 CFR 350.9) and NRC (10 CFR 50, Appendix E.IV.F.1-5.) rules for conducting periodic exercises and drills.
Under these requirements, 3
organizations with assigned responsibilities for protecting students are required to demonstrate through exercises their ability to implement emergency procedures contained in their emergency response plans.
However, the public (e.g.,
school children) are not required to participate in exercises.
Further, the actual use of school vehicles is optional.
The demonstration of each organization's capability to implement these measures in exercises will be evaluated by FEMA and other Federal officials.
The following functions should be demonstrated and evaluated in exercises in which the evacuation of students is necessitated by events in the exercise scenario:
1.
Alerting and notification of appropriate school officials by local emergency officials with respect to status of radiological emergency and need to implement protective actions, including evacuation; 2.
The contacting and notification of dispatchers and school bus drivers,.as appropriate, to inform them of any potential or actual need for them to transport students a,nd 3.
The provision of information to the parents and guardians, as appropriate, concerning the status and intended location or destination of the students.
With respect to simulating the evacuation of school children in an exercise, the following guidelines are provided.
1.
At the discretion of school officials, the bus driver may proceed to drive a school bus to a relocation center, as necessitated by the' simulated exercise events.
2.
An exercise evaluator will interview the relevant personnel at the EOC's, thg_ School Superintendent's office, the School PJakncipal's office, and the Dispatcher's office,, as well as the bus driver to determine their awareness of and preparedness for the evacuation of the school children.
Pertinent questions for the exercise evaluator pertaining to the dispatcher and bus driver include:
Emeraency Ocerttions Center (s) - (EOC)
One or more EOC's may be involved in decisionmaking to effect the evacuation of schools.
For example, in some States, local school evacuation must be coordinated with 8
i
. - ~ - _... - -, - - -,, - _ -. _ - - - - - - -
. - - - - ~ - - - - -
9 State officials.
In such cases, observers may need to concurrently evaluate ~ evacuation or other protective action decisionmaking in both State and local EOC's.
1.
Who made the decision for evacuation or other protective action of schools and when?
a 2.
What specific actions (evacuation, early dismissal or shelter) are incorporated in the decision and what specific sectors / schools are impacted by this decision?
3.
When and f rom whom did the EOC receive information about this decision?
4.
When and whom did the EOC staff contact to implement this decision?
5.
Did EOC staff undertake actions to assist school evacuation or other protective action such as securing guides, buses and assistance in traffic control?
School Suoerintendent's Office 1.
When and f rom' whom did the superintendent receive protective action instructions or recommendations?
What specific instructions or recommendations did the superintendent receive?
2.
What actions did the superintendent take to implement these instructions or recommendations?
Whom did the superintendent contact and when?
School Principal's Office 1.
When and f rom whom did the principal receive protective action instructions?
Uhat specific instructicas did the principal receive?
4 2.
What means of communications (e.g.,
telephone, tone alert) were used to provide chese instructions?
Did this means of communication function adequately to provide accurate and timely information?
3.
What actions did the principal take to implement these instructions?
Whom did the principal contact and when?
Dispatcher 4
1.
When and f rom whom did the dispatcher receive the instructions?
What specific instructions were received?
9
2.
What means of communica'tions were used? Here the
~
~
communications between the dispatcher. and his/her supervisor and the dispatcher and the bus driver adequate to convey appropriate and timely a
information?
4.
When did the dispatcher initiate notification'to bus drivers and guides to implement the evacuation _ or other protective action plan?
What specific instructions were provided by the dispatcher?
How long did it take to contact the bus driver to give the order to evacuate?
Dy2 Drivers /Gu' des 1.
When and from whom did the bus drivers and guides receive instructions?
Nhat instructions were re:eived?.
2.
Uhen did the driver arrive at the school?
3.
Did the driver have an adequate map or knowledge of the route?
l 4.
Was the driver aware of any agreement between the i
drivers and local authorities for them to provide their service' -in the event of a radiological s
emergency?
5.
What means of communications were.used? Were communications with the dispatcher adequate to convey appropriate and timely information?
6.
Did the exercise play necessitate a change in instructions to bus drivers and guides?
If so, what were these new instructions?
What means of communications were used to contact the bus drivers and guides? Was this means of communication adequate?
Padiation Monitorina and Protection igI Dyg Drivers and Guides dafdesionated enernency workers) 1.
Were bus drivers and guides provided with specific means for radiation monitoring (e.g.,
dosimeters and i
film badges) and exposure control (e.g.,
potassium iodide, respiratory protection)?
2.
Were bus drivers and guides trained in the proper use of these instruments and materials?
i t
3.
Were instructions provided to the bus drivers and i
guides for the authorization and use of potassium iodide?
l I
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- - =
4.
During the exercise, were instructions given to alter evacuation /early dismissal routes in order to avert.
radiation exposure by bus drivers and guides?
b Relocation Centers /Neichborhoods lf2I early dismissal)
~
1.
When did the buses arrive at the relocation center (s)/ neighborhood (s) ?
2.
According to the exercise scenario events, did the bus drivers go to the appropriate relocation centers / neighborhoods?
Did they arrive in a timely manner to avert radiation exposure?
Provision 21 Emercency Instructions is Parents And Guardians 1.
Was information provided to parents and guardians on the location of students, e.g.,
relocation centers, early dismissal to residences or sheltering?
When was this information provided?
2.
What means (e. g., EBS messages and telephones) were used to provide this information?
3.
Was this information provided in a timely and accurate manner according to the exercise scenario events?
In some cases, answers to the above questions will be secured from direct observation of the simulated evacuation, thus obviating the interviews.
Special Considerations igI Imolementino Protective Actions In addition to the guidance above on school evacuation, the following special considerations are provided for use when implementing other protective actions.
Early Precaratory Heasures.
In order to facilitate the implementation of protective actions, the following measures should be considered:
a.
Inventory resources for mobilization; e.g.,
school buses and drivers, b.
Curtail extramural or extra curricular activities so that school children are available for prompt evacuation, if it becomes necessary.
I 11 i
c.
Select the method (e.g.,
EBS) and the draft message to notify parents and guardians of the status or destination of their children if it becomes necessary
=
to take protective actions.
't d
d.
Assure that the relocation center is available in the event evacuation is necessary.
Early Evacuation.
Early evacuation is accelerating the implementation of protective actions for school children prior to the activation of protective actions for the general public.
For example, if a plan calls for an evacuation of the public at the " General Emergency" level, then protective actions for school children would be initiated at the " Site Area Emergency" level.
In the event of a rapidly
)
deteriorating situation, school children would be evacuated simultaneously with the general public.
Early Dismissal. While early dismissal of school children is not addressed as an evacuation option per se in NUREG-0654 /FE!!A-REP-1, it is incorporated in this Gli as a method for accomplishing the intent of evaluation criteria under planning standard J because of its use for other types of emergencies such as imminent natural hazards (e. g.,
snowstorms).
Hazards such as a school fire or boiler failure have a limited hazardous area, unlike an extended 4
- radiological plume; therefore, the early dismissal of students to their parents and guardians may be prudent.
The greater area affected by severe weather, such as a blizzard, usually does not jeopardize the health and safety of the school children if they are dismissed early before the storm or remain sheltered in the school.
In contrast, the radiological plume may make both the school and home undesirable shelters if both are in the plume exposure pathway, or if a fast moving event could escalate to while the children were in transit.
Further, in the presence of i
unstable meteorological conditions it is difficult to project the movement of radiological releases.
Therefore, the unique characteristics of a radiological emergency place limits on the use of early dismissal as a viable protective action, particularly in heavily populated areas.
1
"'~~
Evacuation Combined With Early Dismissal.
Early dismissal used in conjunction with evacuation as described above provides another option.
The school children who reside in a sector of the ten-mile EPZ not effected by the potential danger or outside the ten-mile EPZ could be dismissed early to their parents, guardians or other supervision while those students whose homes are potentially in the path of a radioactive plume would be evacuated to designated relocation centers.
l 12 i
l i
I
Shelterina.
Under certain circumstances sheltering may be the preferred protective action (e.g., when there are hazardous road conditions or the possibility exists that evacuation may result in transporting students through the plume).
Sheltering may be used as a primary or temporary protective action depending upon the characteristics of the I
radiological release and the status of weather and road conditions.
GM EV-2 is issued subsequent to review and concurrence by URC staff who have determined that it provides clarification and interpretation of existing NUREG-0654/ FEMA-REP-1 criteria applicable to protective actions for "special populations."
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{
13
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
=
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of " NOTICE OF FEMA GUIDANCE OF POTENTIAL APPLICABILITY TO SHOREHAM PLAN,AND EXERCISE PROCEEDINGS" in the above-captioned proceedings have been served on the following by deposit in the United States mail, first class, this 29th day of December, 1986i John H. Frye, III, Fabian G. Palomino, Esq.
Administrative Judge Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission Sta.te Capitol Washington, D.C.
20555 Albany, NY 12224 Oscar H. Paris W. Taylor Reveley III, Esq.
Administrative Judge Hunton & Williams Atomic Safety and Licensing Board 707 East Main Street U.S. Nuclear Regulatory Commission P.O. Box 1535 Washington, D.C.
20555 Richmond, VA 23212 Frederick J. Shon Jonathan D. Feinberg, Esq.
Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. huclear Regulatory Commission Three Empire State Plaza Washington, D.C.
20555 Albany, NY 12223 Morton B. Margulles Jerry R. Kline Atomic Safety and Licensing Board Atomic Safety and Licensing Board o
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East-West Towers, Rm. 430 East-West Towers, Rm. 430 4350 East-West Hwy.
4350 East-West Hwy Bethesda, Maryland 20814 Bethesda, MD 20814 Stephen 8. Latham, Esq.
' John F. Shea, III, Esq.
Herbert H.. Brown, E.4q.**
Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.
Attorneys at Law Karla J. Letsche, Esq.
P.O. Box 398 Kirkpatrick & Lockhart 33 West Second Street 1800 M Street, N.W.
Riverhead, NY 11901 9th Floor Washington, D.C.
20036 Atomic Safety and Licensing Board Panel Joel Blun, Esq.
U.S. Nuclear Regulatory Commission Director, Utility Intervention Washington, D.C.
20555 NY State Consumer Protection Board Suite 1020 Atomic Safety and Licensing 99 Washington Avenue Appeal Board Panel Albany, NY 12210 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Monroe Schneider North Shore Committee P.O. Box 231 Docketing and Service Section Wading River, NY 11792 Office of the Secretary U.S. Nuclear Regulatory Commission Philip H. McIntire Washington, D.C.
20555 Federal Emergency Management Agency 26 Federal Plaza Spence Perry, Esq.**
New York, New York 10278 General Counsel, Rm. 840 Federal Emergency Management Agency 500 C Street, S.W.
Washington, D.C.
20472 Robert Abrams, Esq.
Attorney General of the State Gerald C. Crotty, Esq.
of New York Ben Wiles, Esq.
Attn:
Peter Bienstock, Esq.
Counsel to the Governor Department of Law Executive Chamber State of New York State Capitol Two World Trade Center Albany, NY 12224 Room 46-14 New York, NY 10047 Anthony F. Earley, Jr., Esq.
MHB Technical Associates General Counsel 1723 Haqilton Avenue Long Island Lighting Company Suite K 250 Old County Road San Jose, CA 95125 Mineola, NY 11501 i
f Hon. Peter Cohalan Martin Bradley Ashare, Esq.
Suffolk County Executive Suffolk County Attorney o
County Executive / Legislative Bldg.
H. Lee Dennison Building Veteran's Memorial Highway Veteran's Memorial Highway Hauppauge, NY 11788 Hauppauge, NY 11788 e
Mr. Jay Dunkleberger Ms. Nora Bredes New York State Energy Office Shoreham Opponents Coalition Agency Building 2 195 East Main Street Empire State Plaza Smithtown, NY 11787 Albany, New York 12223 Ellen Blackler Mr.. Robert Hoffmnan New York State Assembly Ms. Susan Rosenfeld Energy Committee Ms. Sharlene Sherwin 626 Legislative Office Building P.O. Box 1355 Albany, NY 12248 Massapequa, NY 11758 Brookhaven Town Attorney Bernard M. Bordenick, Esq.
475 E. Main Street U.S Nuclear Regulatory Agency Patchogue,,NY 11772 7735 Old Georgetown Road Bethe,sda, MD 20814 k.
s - *>
Hilliam R. Cumming
/
Federal Emergency Management Agency l
i
_.