ML20207E037
| ML20207E037 | |
| Person / Time | |
|---|---|
| Site: | Seabrook, 05000000, Shoreham |
| Issue date: | 07/21/1988 |
| From: | Grimsley D NRC |
| To: | Belair R KIRKPATRICK & LOCKHART |
| Shared Package | |
| ML20151S553 | List: |
| References | |
| FOIA-88-280 NUDOCS 8808160312 | |
| Download: ML20207E037 (4) | |
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PART 4.-RECOROS RELEASED OR NOT LOCATED (See cAecAed bonest No egency records subsect to the roovest have been located No add.toral agency recoros subrect to the roovest have been located s
Agtecv records m,brect to the request that are conufed e Appendin _
a'e already evadaNe for publ< irspecteon and Copeng m tne NRC PW.c Document Rw-1717 H Street. N W.. Wuhengton. DC k
jaecy records sub,ect to the reovest that are identef.ed m Appendi _
--- are being made asadatde for pubhc especten and ccereg m trw NRC Pubhc Docu-e-oom.1717 H Street. N W. Was egton. DC. m a folder under the FOtA number and requester name s
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The nonpropretary wesen of the proposaksi that you agreed to accept m a te ephone conversaten wth a member of my staff e no* be.ng made avseabie for pubhc escec cr and coymg at the NRC Pw c Document Room.1717 H Street. N W, Washegton. OC. e a fonder vroer the FOt A number and reovester home Enclosed e eformaton on how you may obts.n access to and the cha<ges for copyeg records placed a the NRC Pubhc Document Room.1717 H Street. N W. Washegion. Z Agency records swbrect to the reovest a o encx> sed. Any appi. cane charge for copes of the reco<ds p oveed and pav ent procedures ar9 noted m the comments secten n
Eecords subject to the request have been everted to another Federal agencviest for revww and o, rect respoese to vou in ve* of NRC's response to the roovest, no further acten a being taken on appeal letter dated PART ll. A-INFORMATION WITHHELO FROM PUBLIC DISCLOSURE Certaa informaton m the roovested records e Seing withheid from puNic d sclosure pumant to the FOI A eiemetons described e and for the reasons stated e Part 11. see tens B. C. and O. Any rwased portons of the documents for wmch ody part of the record e being avthheid a e be ng made evadatde for public especten and copyeg e the NRC PutAc Document Room.1717 H Street. N W.. Wash ngton, DC. e a folder under this Foi A number and requester name Comments l
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8808160312 000721 PDR FOIA DELAIROB-200 PDR j
hRC FORM 464 Pei e
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Re:
F0!A-88-280 APPENDIX E Doucments Already Available in the PDR 1.
05/23/88 Memo from F. Congel to Richard Krim, subject:
FEMA Support for NRC Licensing of Shoreham Nuclear Power Station, regarding LILC0 submission of Revision 10 of offsite plan. PDR Accession No. 8805310042 2.
05/19/88 Letter from T. Murley to John Leonard, regarding NRC participation in federally-graded exercise of Shoreham Emergency Plan. PDR Accession No. 8805260249 3.
02/08/88 Memo from F. Congel to R. Krim, subject: FEMA Support for NRC Licensing of Shoreham Nuclear Power Station, enclosing LILC0 letter transmitting Shoreham Prompt Notification Design Report.
PDR Accession No. 8802160246 4
02/08/88 Memo from F. Congel to R. Krimm, subject: FEMA Support for NRC Licensing of Shoreham Nuclear Power Station, enclosing LILCO letter dated 12/18/87 requesting a full-participation exercise.
PDR Accession No. 8802170095 5.
01/26/88 Letter from John Leonard, subject: Submission of the Long Island Lighting Company's Revised Prompt Notification System Design Report.
PDR Accession No. 8802030181
i l
Re:
F01A-88-280 APPENDIX F Documents Being Placed in the PDR i
1.
05/24/88 Letter from J. Leonard, subject: Shoreham Offsite Emergency Plan:
Rev. 10. (14 pages) 2.
05/20/88 Memo from F. Congel to R. Krimm, subject: Objectives for the Shoreham Exercise (2 pages) 3.
05/12/88 Agenda for 5/12/88 FEMA Meeting (1 page) 4.
05/05/88 Draft Discussion Points - FEMA Heeting 5/6/88 (2 pages) 5.
05/05/88 ShorehamPlanReviewandExercise(Litigation) Schedule-PERT l
Chart (3 pages) 6.
05/03/88 Letter from D. Crocker to S. Brown, subject:
Connecticut Exercise Participation (2 pages) 7.
04/29/88 Meeting Attendance Record and related records from 4/19/88 FEMA Meeting (4 pages) 8.
04/22/88 Memo from J. Stohr to R. Krimm, subject: Exercise Schedule for Shoreham - [ deleted portions are outside the scope of request.]
(3pages) 9.
04/07/88 Meeting Attendance Record and related documents from Shoreham i
Scheduling Meeting (9 pages)
- 10. 03/14/88 NRC/ FEMA Meeting (5 pages)
- 11. 02/02/88 Shoreham Status (3 pages)
- 12. 01/28/88 Letter from D. Crocker to FEMA Region 11 Regional Assistance Comittee Members, subject: Transmittal of the Shoreham Nuclear Power Station Local Offsite Emergency Response Plan, i
Revision 9 (1 page)
- 13. 01/27/88 Memo from F. Congel to R, Krimm, subject: FEMA Support for NRC Licensing of Shoreham Nuclear Power Station, regarding Shoreham j
Nuclear Power Station Locci Offsite Radiological Emergency i
Response Plan (2 pages)
- 14. 01/25/88 Memo from F. Congel to R. Krimm, subject: Emergency Plan Review Coordination for Shoreham (2 pages) l 15.
12/07/87 NotesonShoreham(4pages)
- 16. Undated Review of Shoreham public emergency information materials (13 pages) i I
i i
Re: F01A-88-280 APPENDIX F (Con't) 17.
Undated Shoreham - Seabrook Exercise History (3 pages) 18.
Undated Shoreham Status as of 4/11/88(1page) i 19.
Undated ShorehamBackground(5pages) 20.
Undated NRC Shoreham Observer /Vistor Plan (4 pages) 21.
Undated 1988 LILC0 Emergency Preparedness Exercise Scenario (3 pages) j 22.
Undated Chart-Exercise Schedule (1 page)
- 23. Undated RealismContainedintheShorehamPlan(2pages) 24 Undated Scheduled Shoreham Exercise Ever.ts (1 page) 25.
Undated StanbyandReportChart(3pages) 26.
Undated Listing-ShorehamRAC(2pages) 27.
Undated Shoreham Background (5 pages) 28.
Undated Shoreham Exercise: EX-3 Dates (1page) 29.
Undated Status of Open Issues in Shoreham Proceeding (11 pages) 30.
Undated ShorehamLicensingProceeding(8pages) 31.
Undated Testimony on status of emergency planning for the Shoreham Nuclear Power Plant (4 pages) l l
1
9 KIRKPATRICK & LOCKHART SOUTH LOBBY STH FLOcR Exc m o cz II If00 M STREC, N T TASHDvGTcK D c ICOM91 4 n anexe
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82> num u% nten May 23, 1988 SEEDOM 0F iHFORMATI HAND DELIVERED ACT REQUEST p p./ N #0 Directer, Office of Administration Nuclear Regulatory Commission lg $.2 h.h Room 4210 Maryland National Bank Builcing 7735 Old Georgetown Road Bethesda, Maryland 20814 Re:
Freedom of Information Act Request Gentlemen:
On behalf of our client, Suffolk County, Long Island, New York, we request, pursuant to the Freedom of Information Act, as amended, 5 U.S.C. 6 552 ("FOIA"), and the rules of the Nuclear l
Regulatory Commission ("NRC") issued thereunder, 10 C.F.R. Part 9, copies of all correspondence, memoranda, notes, reports, draf ts, or other recorded materials regardless of physical form or characteristic dated November 1, 1987 or dated more recently, in the possession or control of the NRC ("records") relating to:
(1) a Federal Emergency Management ("FEMA")-graded exercise concern.ing the acequacy of radiological emergenc': response planning and preparedness for the Shoreham Nuclear Power Station located in Long Island, New York; (2) Revision 9 of the Long Island Lighting Company's emergency plan for the Shoreham Nuclear Power Station, including any review of that plan by the FEMA Regional Assistance Committee or any members thereof.
Without limiting this request, but merely to assist the NRC in identifying records which are responsive to this request, we direct the NRC's attention to a document entitled "Milestones for Shoreham Exercise Evaluation and Plan Review," copy enclosed.
It is our understanding that this document may depict some of the activities that have been underway concerning such an exercise or any plan review.
We also suggest that records responsive to this request may be in the possession of Edwin Fox, member of the FEMA Region II Regional Assistance Committee, who is with the NRC's regional office in King of Prussia, Pennsylvania.
g %y.2l C*!!!
Sy
KIRKPATRICK & LOCKHART Director, Office of Administration i
May 23, 1988 Page 2 1
In the event that access is denied to any of the records i
responsive to this request, please supply the following information:
a.
Identify the record or withheld portion of the record and specify the statutory basis for the denial, as well as your reason for believing that an exemption applics, as required by i
10 C. F. R. 5 9.10(b).
l b.
Segregate the nonexempt from the allegedly exempt portion of any withheld records and release the former, as required by 10 C.F.R. 5 9.5(b).
c.
Supply a detailed statement of the content of the withheld record or portion thereof, along with the date on which that record or portion thereof was written; its section heading or title; and an identification of any persons or entities whc have received copies of such records or portions thereof, as required by applicable case law.
Vaughn v.
Rosen, 484 F.2d 823, 826-827 (D.C. Cir.1973 ).
d.
Separately state your reasons for not invoking your discretionary power to release the allegedly exempt records or portions thereof.
The undersigned will pay charges for search time and copying fees, as provided by NRC regulations, 10 C. F.R. 5 9.14.
If i
search and copying fees to be incurred by the undersigned will j
exceed $2,000.00, please notify Naima Said at (202) 778-9149 before this sum is exceeded.
Any questions or comments concerning this request may also be directed to Ms. Said.
We expect to receive your response to this FOIA request within ten (10) working days of your receipt of this request, as required by the FOIA, and as set forth at 10 C.F.R. 5 9. 9(a ).
.<t-
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~
Robert R. Belair
WSTONES FOR SHOREHAM EXERCISE EVALUATION AND Pt>J4 REVIEW s
s of: May 11, 1988 No later than Days Prior To Exercise Recuired ActiqD Exercise Plan o Region II RAC Meeting Mar 3 FEMA /NRC guidance to' Region Mar 7 o LILCO submits off-site exercise objectives to Region II for approval Mar 24 o FEMA Region II sands exercise objectives to RAC for review Mar 28 75 Days State and Licensee jointly Mar 31 develop and submit exercise (Mar 24)
- objectives to FEMA and Nuclear Regulatory commission (NRC) Regional offices.
o Region II/RAC provide written cursory review to FEMA MQ Apr 4 RAC submits comments on exercise objectives to Region II Apr 11 60 Days FEMA and NRC Regional offices Apr 15 complete reviews of objectives (Apr 8)*
and extent of play af ter uesting with licensee / state, it,necessary.
o RAC submits capleted plan reviov comments to Region II Apr 18 o LILCO response to 1986 de'fi-ciency,and ARCA charts.
Apr 18 46 Days State and licensee submit exercise Apr 22 scenario to FEMA and NRC Regions for review j
1
m o LILCO submits exercise scenario to Region for approval Apr 19 o Region II consolidates RAC plan review comments Apr 25 o RAC plan review consolidation l
meeting Apr 28 o Region II submits approved LILCO off-site exercise objectives to FEMA HQ May &
o FEMA Region II subm'i,ts to FEMA HQ approval of scenario and recommendations on extent exercise play.
May %
35 Days' FEMA and NRC Regions contact or May 10 meet with State and licensee to discuss modifications and complete the scenario.
Agreed upon changes or modifications should be docu-mented and distributed.
o completed plan review forvarded to FEMA HQ Mayjf o FEMA HQ submits approved LILCO off-site exercise objectives to NRC for determination for
- qual-ifying exercise" under NRC rules May 1$
o NRC provides written determina-tion to FEMA for "qualifying exercise" under NRC rules.
May $4 o NRC/ FEMA approve extent of exer-cise play.
May $$
o Final date for submission of plan revisions by LILCO to FEMA Region II May 10 32 Days Regional Assistance Conunittee May 18 (RAC) Chair calls controller's meeting to develop coordination of exercise, o FEMA HQ forvards plan review to NRC May 1$
2
o D
e 25 Days FEKA and NRC Regions develop May 13 specific post-exercise act-ivity schedule for debrief-ings and meetings with the State.
14 Days The RAC Chair (and NRC team May 24 leader as available) develops evaluator action plan (where stationed, how many from each organization, what to look for).
The product of this will be the exercise evaluator packet which includes the specific evaluation location assignment.
The packet should provide:
o portions of the plan applicable to their assignment; o
A list of all exercise evaluators and their assignments; o
A time-line of events; o
Scenario technical data as required for those assigned; o
Past exercise findings; o
Applicable controller messages; o
Applicable reference materials; o
Logistic information and o
Log forms for taking notes.
i day All Federal evaluators, both Jun 6 onsite and of fsite, meet in thh exercise area to receive orient-ation and final instructions.
o Shoreham Exercise Jun 7-9 3
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t Exercise Day Conduct E:<e rc i s e.
Evaluators hold Jun 7-9 Exit Interviews with participants (at assigned locations).
- Reflects NRC request to change exercise to week of June 6 from Jume 13.
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/gfO LONG ISLAND LIGHTING COMPANY y
SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY ROAD
- WADING RIVER. N.Y.11792 JOHN D. LEON AR D, JR.
VICE PRE 5@ TNT hvCLE AR OPE R Afs0*v$
SNRC-1443 MAY24 568 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.,
20555 Shoreham Offsite Emergency Plan:
Rev. 10 Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 Gentletaen :
Long Island Lighting Company (LILCO) hereby submits Revision 10 to LILCO's Local Of fsite Radiological Emergency Response Plan for the Shoreham Nuclear Power Station.
This letter describes the principle changes set forth in Revision 10 of the LILCO Plan.
LILCO requests that you forward this revision forthwith to FEMA for review by the Regional Assistance Committee (RAC) in accor-dance with the NRC-FEMA Memorandum of Understanding.
Because most of Revision 10 is responsive to preliminary RAC comments on Revision 9, which is still unpublished, LILCO also requests that you request FEMA to consolidate its review of Revision 9 with that of Revision 10.
This request is outlined in more detail below.
As with previous revisions to the Plan, Revision 10 changes are marked in the right hand margin:
vertical bars denote the addition or replacement of material from previous revisions; horizontal bars denote the deletion of material from previous revisions.
Instructions for incorporating Revision 10 changes into the LILCO Plan are included as Attachment I to this letter.
Revision 10 of the LILCO Plan includes changes in four general areas:
changes responding to the RAC Comments on Revision 9 of the Plan; changes responding to the Licensing Bgprd's Partial Initial Decision on the February 1986 exercise;-
refinements in 1/
Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), LBP-88-2, 28 NRC 85 (February 1, 1988).
i nnnias m n a
4 e w w w. w 'r v, l J
SNRC-1443 Page 2 Plan procedures reflecting drill experience; and various minis-terial changes.
These areas of change are described generally below and in some detail in Attachment II to this letter.
The greatest portion of these changes, in both so..ume and signif-icance, consists of responses to the RAC's techaical review of Revision 9, rather than new or original material.
These responses are intended to close "open items" contained in the preliminary region-level RAC review of Revision 9.
The review of Revision 9 has not yet been published in final form by FEMA:
it was communicated to LILCO by the technical assistance process.
Cf. 44 CFR S 350.6(c).
Given the predominantly responsive nature of Revision 10, LILCO believes that merging the review of Revision 9 into a consolidated review of Revisions 9 and 10 would both make more efficient use of institutional resources and present a more accurate picture of the state of the Shoreham of fsite plan than issuing a "final" review of the already super-seded Revision 9.
Accordingly, LILCO requests that the NRC i
I request FEMA to consolidate the review of Revisions 9 and 10 so that the document ultimately issued by FEMA represents an up-to-date picture of the Shoreham plan.
1.
Changes Responding to RAC Comments on Revision 9 of the Plan.
The most significant portion of Revision 10 consists of responses to the preliminary RAC Comments on Revision 9 of the LILCO Plan.
These changes include, among other items, updating leases and contracts with support organizations; I
adding telephone numbers to facilitate contact with State and local governments; clarifying Route Alert Drivers' briefing form for use of potassium iodide; revising procedures to conform protective action recommendations for dairy products with federal guidelines; including additional procedural detail for the dispatch of bus drivers evacuating school children in the EPZ; and providing for the use of potassium
)
iodide and dosimetry by regular EPZ school bus drivers.
These revisions are listed in Attachment II.1 to this letter.
In addition to responding to Plan inadequacies identified by the RAC in its review of Revision 9, Revision 10 also in-cludes va'rious minor changes responding to the RAC's sugges-tions for further improvement of the Plan.
These changes, which are not enumerated in the attached lists, include such modifications as revising the heading on RECS forms to dif ferentiate them from New Yvrk State forms and revising EBS procedures to indicate that activation of the EBS system is not required at the declaration of an Unusual Event emergency classification.
2.
Changes Responding to the Licensing Board's Partial Initial Decision on the 1986 Exercises.
Revision 10 also modifies chose aspects of the Plan which were characterized by the Atomic Safety and Licensing Board in LBP-88-2 as involving "fundamental flaws" in its decision on the 1986 FEMA-graded
SSRC-1443 Page 3 exercise, which was published after issuance of Revision 9.
l These changes include modifications in the content of EBS messages; improvements in the scheme for mobilizing Traffic Guides; and renewed emphasis on LERO training and communica-tions to ensure that decisions are made and actions are implemented in a timely and appropriate manner.
These revisions are listed in Attachment II.2 to this letter.
3.
_R_efinements in Plan Procedures.
Revision 10 includes refine-ments in Plan procedures which are the result of experience i
in practice exercises of the Plan.
These changes involve the addition of procedural' details for shift changes and for ingestion pathway and reentry procedures; the addition of Mid-Island Hospital as a back-up hospital for handling contaminated injured individuals; and the revision of procedures to mobilize Reception Center management personnel at the declaration of an Alert emergency classification.
These revisions are listed in Attachment II.3 to this letter.
4.
M_inisterial Changes.
Revision 10 includes several minis-terial and conforming changes.
These changes include updated school listings and associated evacuation time estimates; clarification of the Bus Coordinator procedure; clarification of the LERO School Bus Driver planning bases; and revisions in the overall organization chart to reflect other changes.
These revisions are listed in Attachment II.4 to this letter.
It also upaates the description of the expected functioning of the CBS following full power licensing.
LILCO requests that you transmit this revision, along with a request for consolidation of the RAC Reviews of Revision 9 and 10, to FEMA.
Very truly yours, j/ '
! N.
/
W
- @ h d v' J' h D.
ednard, Jr.
\\(
o Vic> President, Fuclea Operations
/ck Enclosure cc: W. T. Russell S. Brown F. Crescenzo
p.,
Attachment II.I Page 1 StM4ARY OF REVISION 10 RESPONSES TO FEMA RAC CON 4ENIS ON REVISION _9JOLTHLLERQ. FLAN Resolution and Affected lite _H02 BAC_ Comment EQtt10ns of Pign_And Precedyrci C.4 The leases in Appendix 8 for the Riverhead Transfer Point Obtained updated, executed leases for River-and the Coram Transfer Point have not been executed. The head, Coram Miller Place, Harehouse Doctors' lease for the Miller Place transfer point expired 02/29/88.
Path, Middle Island, Shirley Mall and No lease was found for the Harehouse - Doctors' Path Expressway Plaza. Appendix B Transfer Point. Leases for Middle Island, Shirley Hall and Expressway Plaza expire on 3/31/88.
The Plan states that the LERO posittoa of Traffic Engineer Obtained letter of agreement from KLD.
will be filled by personnel from KLD Associates. Inc.
Appendix 8 (Section 2.2, page 2.2-10).
Appendix B does not contain evidence of a contract with KLD Associates, Inc.
D.4 This procedure raises the possibility that the Director of Procedure OPIP 3.1.1, steps shifted to l
Local Response alght recommend and advise protective indicate R.H.C. is consulted prior to PAR actions to the Suffolk County Executive on the basis of to County. This will apply when personnel information on the Radiological Emergency Data Form and are at EOC.
without consultation with Radiation Health Coordinator as called for in the plan.
Telephone numbers for the Governor of New York and the Put numbers into procedure OPIP 3.1.1, pages Nassau County Executive could not be located.
6, 85 and LERO Phone Directory.
E.4.a-n Provisions have been made for followup messages from LILCO Add required it formation to Part II of RECS to offsite response organizations which contain all the form.
planning information required by NUREG-0654/ FEMA-REP-1, Rev. 1, Supp. 1, except the following:
o "licensee emergency response actions underway" (element E.4.k);
^
s I
Attachment II.1 Page 2 l
Resolution and Affected l
Pottions of P1grLAnd Procedur_e5 Liem_ Hoi RAC_ Comment E.4.a-n o
"request for any needed onsite support by offsite (continued) organizations" (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 Attachment 1 of OPIP 3.3.1.
E.5 The Letter of Agreement from MPLR formalizing an Plan and procedures revised to clearly indi-agreement does not explicitly state that HPLR-FM will act cate that NCBS is the EBS CPCS station. The as the Common Point Control Station. This agreement must The Shoreham local EBS network is a backup be reached to insure coordination of all radio stations system to the NY State system. Plan Secticn designated as transmission sources of emergency broadcast 3.8, OPIP 3.1.1, 3.3.4, 3.8.2.
messages. LERO's EBS system is currently being litigated.
F.1.b Mlthout RECS there is only one communications link with Information will be relayed to New York State New York State. Neither the text nor Figure 3.4.1 iden-and Nassau via RAMAS. Suffolk County and i
tify any backup to commercial telephone for communications DCE-BHO are on the NAMAS circuit and will be i
with Nassau County. This is not in compliance with federal requested to relay necessary messages. Plan guidance (NUREG-0654, FEMA-REP-1, Rev. 1. Supp. 1, page Section 3.4, Figures 3.3.5 and 3.4.1, OPIP 13), which states that a backup system is necessary for 3.1.1.
communications with unparticipating states and local governments.
Telephone numbers for New York, Connecticut, and Nassau Telephone numbers added to procedure County should not be located.
and LERO Emergency Telephone Directory.
G.I.a-e As written, the Plan addresses the requirements of Brochure has been sade available to RAC for NUREG-0654/ FEMA-REP-1, Rev. 1, Supp. 1; however, the review.
public information brochure has not been submitted to FEMA for review. This brochure must be submitted to FEMA for review by the RAC before the rating of the element can be determined.
G.2 Public information materials have not been Brochure has been made available to RAC for submitted to FEMA for review nor have they been dis-
- review, tributed (or made available to the permanent and trans-1ent adult population.
.s s
Attachment II.1 i
Page 3 Resolution and Affected Item _No, RAC_CDement Eortton_5_of Plap_and Procedures G.4.c Insufficient copying capabilities at the ENC resulted in High capacity copters and additional backups delays in the distribution of information during the are now installed in the new ENC location.
February 13, 1986 exercise. Rumor Control personnel were 4
not able to answer questions received from the public because they were not given accurate up-to-date status i
reports.
j The onsite procedure EPIP 4-4 should he submitted to the The LERO Spokesperson in the ENC will desig-RAC for review and specific reference to that function nate a LERO Rumor Control Coordinator for should be included in the offsite plan. The delegation specific responsibilities for interfacing of responsibility for rumor control to the SNPS organt-with the LILCO Rumor Control personnel (OPIP i
zation is not in compliance with NUREG-0654/ FEMA-REP-1, 3.8.1).
In addition EPIP 4-4 is beleg made Rev. 1, Supp. 1, which requires that the offsite response an Attachment to OPIP 3.8.1.
organization shall establish coordinated arrangements for dealing with rumors. Onsite procedure EPIP 4-4 does not provide for managerial responsibilities in rumor control for j
LERO personnel and the responsibilities given LERO personnel j
in Procedure OPIP 3.8.1 do not amount to a coordinating role.
j Also, in light of the NUREG-0654 requirement for the provision of rumor control by offsite emergency response organizations, f
consideration should be given to designating EPIP 4-4 as an I
offsite (OPIP) as well as an onsite (EPIP) procedure or, j
alternatively a separate offsite rumor control procedure should be developed. '
i G.5 As specified in NUREG-0654, Supp. I the media must also be Revised media training to include role of familiarized with the role of offsite response organizations LERO vs. State and County response. Plan i
vs. the State and local organizations ecsing the emergency.
Section 3.8.
J.10.e OPIP 3.3.4, page 16c of 16. Instructs Lead Traffic Briefing form for Lead Traffic Guides to i
Guides to instruct the Traffic Guides to ingest KI prior to Route Alert Drivers has been clarified to leaving the Staging Area or when a General Emergency is indicate that this briefing is for Route i
declared over the E8S station. In this case Traffic Guides Alert Drivers and not all field personnel.
i would be instructed to take KI without an iodine dose OPIP 3.3.4, Attachment 8.
equivalent being determined by LERO. OPIP 3.3.4 should be i
changed to specify that Traffic Guides wculd be instructed to take KI in the fleid or at the Staging Area by their supervisor.
Attachment II.1 Page 4 i
Resolution and Affected Ltem_A BAC_ Comment P_o_r_tions_qf.P_lan_3nd Proced_prei J,10.e In procedure OPIP 3.6.2, page 3 of II, there is a statement Procedures have been revised to include two (continued) that only LERO Emergency Workers who will enter the EPZ KI tablets in each packet to be ingested by should be given KI.
However, KI is not listed as a the LERO and Regular School Bas Drivers if component of the LERO School Bus Driver Assignment Packet they hear that a General Emergency has been which contains personal dostmetry and recordkeeping cards declared. OPIP 3.6.5 Attachment 14, OPIP and (see procedure OPIP 3.6.5, page 63 of 75 Attachment 3.6.2.
l 14). KI is reported in Procedure OPIP 3.6.2, page 2 of 11 to be administered to emergency workers at a different loc 3tlon, the designated staging area which are described in the plan, Section 4.5, page 4.5-1).
LILCO's commitment to provide training and equipment for Copies of letters will be provided to FEMA.
l 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 issue of training has been resolved as LILCO states that It has mailed letters offering training to every non-LILCO organization mentioned in the LERO Plan that does not receive training. These letters however, could not be located in the materials supplied. School bus drivers are listed in OPIP 5.1.1 (Attachment 1, page 23 of 37 and page 27 of 37) for training in personnel dosimetry and exposure 1
control.
j i
J.10.f This element is rated inadequate for the same reason as Lead Traffic Guide briefing form for Route element J.10.e of this review. Traffic Guides would be Alert Drivers has been clarlfled.
Instructed to tako KI without an todine dose equivalent See Item J.10.e.
OPIP 3.3.4, Attachment 8.
being determined by LERO. OPIP 3.3.4 should be changed to specify that Traffic Guldes would be instructed by their supervisors to take KI by their supervisor (i.e.,
after a dose projection has been established).
,e Attachment II.1 i
Page 5 Resolution and Affected Ltem A RAC Comment Portiorts of Plan _and Procedures J.10.g Hith respect to school evacuation, the ASLB has expressed LERO has mailed confirmatory letter to bus concern that there were not enough buses for a "one wave" companies citing the number of first-call evacuation of schools. In OPIP 3.6.5. Attachment 3a, buses available from each. Bus yard con-LILCO identifies the number of buses required for evacua-tracts not specifically detalling the tion of all schools in the EPZ, the number of buses that number of "first call" buses will be revised normally service these schools and the number of supple-upon next issue of contract.
mentary 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 sufficient number of buses are available to trans-port students in "one wave." However. the letters of agreement between LILOO 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. II-20a). (See also comment for element C.4 in this review.) Only 5 bus companies have provided firm commitments to supply their buses oc a "first call" basis. Of these 5 companies, only two are scheduled to provide supplementary buses for schools and these two are only scheduled to provide 25 of the 153 required i
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.
I The plan does not enumerate how many school bus This has been done with a generic statement i
drieers are assigned to which bus yards. This numerical that indicates assignment of 150% primary or assignment should be provided.
supplementary drivers at backup bus companies. Sufficient backup drivers will be assigned to equal the number of regular school bus drivers required at each of the bus companies which normally service EPZ l
schools. Plan Section 2.1.
J.10.k OPIP 3.6.3 contains no specific procedures to be Procedure has been revised to include Traffic I
followed by the traffic engineer. Such procedures need to Engineers procedure. OPIP 3.6.3.
be developed.
s 1
Attachment II.1 Page 6 Resolution and Affected l
LienLHo.a.
RAC_ Comment cor_tions_of PIAD_#nd Procjtdures J.11 The worksheet for slik and Section 5.1.1.3 (page Ib of 50)
Procedure has been revised to indicate that Indicate that preventive pas can be recommended when ingestion pathway emergency actions will only projected concentrations in pasture grass or fresh milk, be implemented if excessive radioactive con-or ground deposition activity levels exceed the preven-tamination is actually found in the food.
tive derived response level. This is inconsistent with OPIP 3.6.6.
federal guidance (47 FR47073) for several preventive pas listed.
Federal guidance (FENA-REP-11) states that written pubile Plan now indicates that LERO will mall a l
Instruction material directed at farmers, food processors, brochure equivalent to New York State's and distributors be disseminated during an emergency in a material within 10 miles. LERO will rely on l
timely manner. Reference to dissemination of written New York and Connecticut to distribute appro-pubitc instruction material to this audience could not be priate material within 50 miles in response i
located.
to an emergency. Plan Section 2.2, 3.8.
OPIP 3.1.1, Attachment 8.
1 K.3.b OPIP 3.6.5, Attachment 14 does not instruct School Bus Revised School Bus Driver procedure to in-Drivers to read their dosimetry approximately every 15 clude instruction to read dosimetry every
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minutes while in the fleid. The Emergency Worker Dose 15 minutes. OPIP 3.6.5, Attachment 14.
Record Form does not do so. School Bus Drivers do not receive briefings from Dosimetry Recordkeepers that Instruct them to do so. Page 3.9-2 of the plan indicates that emergency workers are instructed to read their DRDs at 15 minute intervals; however, we could not locate j
procedures for ensuring that School Bus Drivers read their dosimeters at such frequencies.
K.4 School bus drivers have been' included in the LERO School bus drivers have been included in the i
classroom training matrix (OPIP 5.5.1 ),
drill matrix. OPIP 5.1.1.
but they are not included in the drill matrix for j
dosimetry / exposure (OPIP 5.1.1, Attachment 2).
j Nhile LERO has established a decision chain, they have Phone numbers and contact personnel (by not made adequate provisions for giving training to title) identified in procedure OPIP 3.6.5, 1
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those non-LERO emergency workers and providing them with 4.
knowledge in regard to contacting their supervisory per-i sonnel so that proper authorization gets to them.
i 4
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Attachment II.1 Page 7 Resolution and Affected item __No BAC Comment E0Lllons of Plan and Procedurfi It should be noted that the plan indicates with respect LERO will call out to EPZ school bus yards a to some emergency personnel (local law enforcement, fire, number of LERO School Bus Drivers equivalent i
and snow removal personnel; reference page 2.2-7) that to the number of regular bus drivers. As if no training is provided prior to an emergency event, these bus drivers become available at the LERO will designate LERO personnel trained in radiation yards, they may be used by the bus yard dis-fundamentals and dostmetry to accompany personnel per-patchers to either drive the bus alone or forming their duties within restricted areas. These LERO accompany a regular school bus driver. If personnel will provide dostmetry and ensure that they they accompany a regular school bus driver do not receive doses in excess of the Protective Action they w111 provide her with a TLD and a KI Guides for the general public. The plan does not tablet. OPIP 3.6.5 Attachment 14.
explicitly state that this provision applies to school bus drivers however.
1 i
4/7/88 1
1
,s Attachment II.2 Page 1 StM4ARY OF REVISION 10 RESPONSES 10_ASLBJXERCISE_P. RTLALIMLTJALDECISION A
Affected Portions of Issue Responie Plan and ProcedyrttL 1.
a.
Within the EOC in that the Evacuation Route In addition to responses contained in OPIP 3.6.3, 3.6.4, Coordinator did not inform his superiors or Rev. 7, 8 and 9, the following changes 4.1.1 co-workers of the traffic impediments on have been made:
receipt of the free play message, did not i
include complete information on the Impedi-To expedite fleid to EOC communications j
ments in the messages relayed to the route all Traffic Guides will be in direct spotters, and did not request the prompt radio contact with the EOC instead of dispatch of one route spotter to verify relaying messages through the Staging one impediment; Area.
In addition, the Transfer Point Coor-dinators have been put on a different frequency than t.he Traffic Guides to j
reduce radio traffic.
b.
Among field workers in that the plan does The Traffic Guides receive direction OPIP 3.6.3 not permit such lateral communications; on rerouting from the EOC which has a better overview on the effects and
}i ramifications of departures from the preestablished evacuation routes. The direct radio communications now estab-j lished between the EOC and Traffic Guides allows for expeditious rerouting I
of traffic. The Traffic Guides are 1
able to monitor their radio frequency i
and are aware of EOC communications.
l
Attachment II.2 Page 2 Affected Portions of Plan and ProCidpfr.gi_
151Mt RCSRODie n
y c.
At the ENC in that LERO was unable to fur-Responses to this issue were made in nish timely information on protective previous revisions.
action recommendations in the form of EBS i
messages to the media and to rumor control, j
and was unable to accurately respond to questions concerning the traffic impediments and protective action recommendations at l
news conferences; and d.
In the EBS messages in that they contained The EBS messages have been revised to OPIP 3.8.2 j
some confilcting information concerning correct the aspects identifled by the j
protective action recommendatl3ns and were, ASLB.
In some respects, confusing in their dis-cussion of doses, releases, and emergency 4
classifications.
i 2.
A flaw was demonstrated in that large numbers The Traffic Guides are now dispatched OPIP 3.3.3, 3.6.3, of Traffic Control Posts were noi staffed to their Traffic Control Posts immed-4.5.1 until well after traffic congestion would have lately after receiving dosleetry at i
occurred.
the Staging Area and do not wait untti J
an evacuation order tefore being dis-patched. They are then notified by j
radio from the EOC when to begin i
implementing the traffic control l
strategies.
i In addition, Road Crews will be mobil-ized at the Alert rather than Site Area 4
Emergency classification.
i 3.
Flaws in the training program were demonstrated The LERO training program emphasizes OPIP 5.1.1 in the areas of communications, functions of communications and organizational inter-j Traffic Guides and Bus Drivers, and prompt face to ensure that decisions are made i
response of fleid personnel.
and actions are implemented in a timely i
and appropriate manner.
s ag t.
Attachment II.3 Page 1 REfjNEM MIS _JN E N M [DURES I
Portion of Plan and llem EfMQn Pl0Iedures Affetted I
i 1.
Reception Center management per-Prepare facility prior to arrival of Plan Figures 3.3.3, 3.3.4 sonnel report at Alert.
monitoring and decon personnel.
OPIPs 4.2.3, 3.3.3 2.
Addition of Mid-Island Hospital.
Backup hospital to Brunswick General for Plan Sections 2.1, 2.2 handling contaminated, injured people.
OPIPs 4.2.2, 3.6.5 3.
Additional procedural detall on Support of recovery phase of emergency OPIPs 3.1.1, 3.3.3, 3.5.2, shift change, ingestion pathway
, operations.
3.6.6, 3.8.2, 3.10.1 i
and reentry including sample EBS messages.
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1 4
4 I
4 Attachment II,4 Page I Ministerial Changes o Update of school listings associated 1
estimates. evacuation time and o
Clarify 8u procedure. s Coordinator 8
Clarify LERO Sch Appendix A, OPIPs 3 6 o
planning basis. ool a ' "
5, 3.6.4 o Revisions in OPEP 3.6,4 to reflect otherorganization changes. chart o
List of Effective Pages OPIPs 3.6,4, 3.6 5. Appendix A, Plan Section 2.1 Plan Sections 2.1 OPIP 2.1.1
, 2.2 4
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UNITED STATES i
NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 g
j May 20,1988 l
l MEMORANDllM FOR: Richard W. Krimm f
Assistant Associate Director Office of Natural and Technological
{
Hazards Programs Federal Emergency Management Agency FROM:
Frank J. Congel, Director
)
Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
SUBJECT:
OBJECTIVES FOR THE SHOREHAM EXERCISE This responds to your Hay 13, 1988 memo requesting guidance concerning the proposed objectives for the upcoming Shoreham emergency preparedness exercisa.
We agree that the proposed objectives are sufficient to demonstrate the capa-bilities of the Long Island Lighting Company Local Emergency Response Organiza-tion (LER0) in a full-participation exercise. Specifically, we believe that these objectives are sufficient to constitute a "qualifying" exercise under 10 CFR Part 50, Appendix E, Section IV.F.1 in that it shculd test as much of the emergency plans as is reasonably achievable without mandatory pubife participation.
Regarding the deletion of Objective 22 (FEMA Guidance Memorandum EX-3) because of the non-participation of the American Red Cross, we believe that this is appropriate.
In a May 11, 1988 letter from Edwin Reis, Deputy Assistant General Counsel, NRC to William R. Cumming, Esq., Office of General Counsel, FEMA, we stated that the Comission had previously found that the American Red Cross charter from Congress and its national policy require it to provide aid in "any l
radiological or natural disaster," whether or not there are letters of agreement in connection with a particular emergency plan. We will support the position that the American Red Cross responds to natural and technological disasters as a routine and that it is not necessary to demonstrate this capability in a radiological emergency preparedness exercise if they decline to participate.
In this case we believe it is not reasonably achievable to gain their participa-tion in the Shoreham exercise.
i CONTACT:
Edward M. Podolak, Jr., NRR i
492-3167
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l Richard W. Krimm If you have any questions or comments, please call me at 492-1088. We appreciate the intensive efforts of FEMA Region II, the Regional Assistanc6 Connittee, and FEMA Headquarters in preparing for the Shoreham exercise.
Original signed by frank J. Congel Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation DISTRIBUTION:
JScinto, OGC WTRussell, RI GEJohnson, 0GC RRBellarqy, RI EJReis, OGC WJLazarus, RI TEMurley, NRR EFFox, RI JHSniezek, NRR FJCongel, NRR FJMiraglia, NRR WDTravers, NRR FPGillespie, NRR RJBarrett, NRR RTNogan, NCR LJCunningham, NRR SWBrown, NRR CRYan NIel, NRR Central Files FXantor, NRR EDO R/F CWingo, FEMA PDR R/F MLawless, FEMA EMPodolak, NRR PEPB R/F j
BY PHONE TO Ed Podolak C/ SI()/
f D/DREP/NRR/'/*
PEPk/NRR SC/ PEP 8/NRR
/DRR OGC FJCongel
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EMPod61ak:lr CRVa'nliel WD diers EJReis
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