View source for SNRC-1420, Forwards Rev 9 to Util Local Offsite Radiological Emergency Response Plan,Reflecting 10CFR50.47(c) Best Efforts Regulations.Instructions for Inserting & Summary of Rev 9 Also Encl

{{Adams
| number = ML20148M789
| issue date = 01/22/1988
| title = Forwards Rev 9 to Util Local Offsite Radiological Emergency Response Plan,Reflecting 10CFR50.47(c) Best Efforts Regulations.Instructions for Inserting & Summary of Rev 9 Also Encl
| author name = Leonard J
| author affiliation = LONG ISLAND LIGHTING CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000322
| license number = 
| contact person = 
| document report number = SNRC-1420, NUDOCS 8801280365
| package number = ML20148M794
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 31
}}

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I f          /gj"O                LONG ISLAND LIGHTING COMPANY SHOREHAM NUCLEAR POWER STATION P.O. BOX 618 NORTH COUNTRY RO AD . WADING RIVER. N.Y.11792 JOHN O. LEONARO, JR.
VICE PRE $notNT.NUCttAR OPERATK)N$
SNRC-1420 JAN 221988 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk washington, DC 20555 Shoreham Offsite Emergency Plan: Rev. 9 Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 Gentlemen:
Long Island Lighting Company hereby submits Revision                      9 to LILCO's Local Offsite Radiological Emergency Response Plan for the Shoreham Nuclear Power Station.                This letter describes the principal changes set forth in Revision 9 of the LILCO Plan.
As with previous revisions to the Plan, Revision 9 changes are marked in the right hand margin: vertical bars denote the addition or replacement of material in Revision          LILCO has 9; horizontal reproduced all bars denote its deletion in Revision 9.
pages of the Plan and Implementing Procedures, not just Revision 9 pages.          This alleviates the tedious process of replacing             each and insures outdated page in the document with Revision 9Because          pages, there are so that each plan holder has an updated Plan.
few of them, only replacement pages for Appendix A have been included. Thus, while the Revision 9 package sent you includes all pages of the Plan and Implementing Procedures, plus Revision 9 pages for Appendix A, only pages marked "Rev. 9" in the bottom right corner with revision bars in the right margin have been changed. Instructions for handling the Revision 9 package are included as Attachment I to this letter.
i The principal areas of change         1 andin Revision the "best9efforts" respondregulation; to NUREG-0654, Rev. 1, Supp.
l the Licensing Board's emergency planning decisions; the RAC comments on Revisions 7 and 8 of the Plan; FEMA Guidance Memorandum MS-1; and various ministerial                 updates to the Plan that These areas of change are are required from time to time.                                                       to described generally below and in some detail in Attachment II                                     '/ ?
J this letter.
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SNRC-14 20 Page 2
: 1. NUKEG 0654, Rev. 1, Supp. 1 (Nov. 1987) and "Best Efforts" Regulation, 10 C.F.R. paragraph 50.47(c), 52 Fed. Reg. 42078 (Nov. 3, 1987). Revision 9 reflects the regulatory               The requirements of the new NRC "best efforts" regulations.
legal authority sections of the plan have been revised to take into account the regulation; two Emergency Preparedness Advisors have been added at the EOC to liaison with State and County government representatives during an emergency, as required by NUREG 0654, Rev. 1, Supp. 1 (Nov. 1987); and implementing procedures for coordination between LERO and government representatives during an emergency have been revised. Because certain governmental facilities have not agreed to participate in planning, LILCO has relied upon governmental support in the Plan by naming certain        entities that would provide support during an emergency. These entities are identified in sections 1.4 and 2.2 of the Plan as being relied upon pursuant to the "best efforts" regulation. They include such facilities as, for example ,
the Nassau County Coliseum and Nassau County Community College, which are identified Letters in being are the Plan astoschool sent    each non-LILCO relocation centers.
entity named in the Plan reminding them of the existence of the Plan and their role in it, and offering to plan with them and to train them. Attachment II.1 lists the revised 1, and describes the response criteria in NUREG-0654, Supp.
for each included in Revision 9.
Issues previousiv litigated.      Revision 9 identifies special 2.
facility reception centers; evacuation time estimates, buses, drivers, and reception centers for school children; evacuation time estimates for hospitals; and an EBS station, as required by the Licensing Board's Partial Initial Decision and Concluding Partial Initial Decision on emergency planning. Lona Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), LBP-85-12, 21 NRC 644 (1985); id.
LBP-85-31, 22 NRC 410 (1985). These issues and the Plan revisions responding to them are listed in Attachment II.2.
: 3. Regional Assistance Committee (RAC) Comments. The December 15, 1987 FEMA RAC comments on Revisions 7 and 8 of      thethese All    LILCO
(
Plan identified inadequacies in the LILCOThe  Plan.
inadequacies items have been resolved in Revision 9.
identified by the RAC, and the LILCO responses in the Plan, are listed in Attachment II.3.
: 4. Hospitals for Contaminated Injured Public. FEMA Guidance Memorandum MS-1 requires identification of a primary and backup hospital for treatment of contaminated injured members of the public. Revision 9 contains a letter of agreement between LILCO and Brunswick Hospital in Amityville      for use In addition,       as LILCO j
the primary hospital during an emergency.
i has identified Nassau County Medical Center and Northport l
Veterans Administration Medical Center as backup hospitals.
l L                                                                                       -

  .2     .
e SNRC-1420 Page 3 The Nasseu County Medical Center, a government-operated facility, would be available during an emergency     pursuant to the "best efforts" rule and NUREG-0654, Rev. 1, Supp. 1 (Nov.  (is 1987). Northport Veterans Administration Medical Center available under the Federal Padiological Emergency    Response All three hc'spitals Plan (FRERP)     and other Federal policies.
have Nuclear Medicine / Radiology,Departmenta and are therefore The qualified to treat contaminated injured individuals.
identification of these three hospitals in Revision 9 satisfies the MS-1 requirements. This revision is listed in Attachment II.4 to this letter.
: 5. Ministerial u'adates. The remaining    Revision 9 changes update facilities, or equipment, information aoout personnel, including such items as updated farm listings. These revisions are listed in Attachment II.4 to this letter.
Very truly yours,
             ,/)?          /    _
           /
A    d h+ '
JohnD. Leonard,Jr.A Vice President - Nuclear Operations KEBM:ck Attachment cc: R. Lo/S. Brown W. T. Russell F. Crescenzo Service List
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     . L ATTACHMENT 1 INSTRUCTIONS FOR INSERTING REVISION 9 PAGES INTO PLAN, PROCEDURES, AND APPENDIX A Pla A)   Discard original pages in the plan, retaining tabs and the manila pocket.
B)   Insert new pages 'nto binder.
C)   Place tabs at yellow pages.
D)   Insert Original Figure 3.5.1 (Map in manila pocket) at yellow page.
PROCEDURES New procedures are totally reproduced with tabs. Remove and discard original pages and replace with new pages and tabs in Volumes I, II and III.
APPENDIX A Reglace_Pagsti:
List of effective pages 1-4, iii, II-10, II-10a, Figure 4, II-12, II-12a, Figure 5, II-18, II-20.
Insert Pages:
II-20a, II-20b Reolace Paaes:
II-28, Figure 7.2, IV-3, IV-53, IV-69, IV-69a, IV-72a, IV-72b, IV-72c, IV-72d, IV-72e, IV-74c, IV-74e, IV-74h, IV-74r, IV-74ra, IV-74rb, Figure 16.1, IV-132, Figure 20.1, Figure 26.1, Figure 27.2, IV-166a, IV-166b, IV-167, IV-168.
Insert Paaes:
IV-168a Reolace Pages:
IV-169, IV-170, IV-171, IV-172 IV-173, IV-175, IV-175, IV-177, IV-178.
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4 1
ATTACHMENT 1 INSTRUCTIONS FOR INSERTING REVISION 9 PAGES INTO PLAN, PROCEDURES, AND APPENDIX A (continued)
Insert Paaes:
IV-179, IV-180, IV-181, IV-182, IV-183, IV-184, IV-185, IV-186, IV-187, IV-188, IV-189, IV-190, IV-191, IV-192, IV-193.
Reolace Paaes:
V-7 Insert Paae:
V-7a Reolace Paae:
Table XV l
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ATTACHMENT II - St# MARY OF REVISION 9 0F LERO PUUt                                    ..
(Including Plan, Procedures, and Appendix A)
II.1   MOREG 0654/ FEMA-REP-1 Rev. 1 Supplement 1 NUREG 0654   I ITEM (S)          SUPP. 1. SEC. I.G. ISSUES                     PLAN RESPONSE            SECTIONS AFFECTED
: a.                   A.2.a also     Identification of the functions        The Plan details which emergency   Plan Sec. 1.4, 2.1, A.l.b          which require State and Local
                                                                                       ~
response functions require gov'tal            2.2 A.1.c          authorization before implementing,    authorization before LERO may            Figure 2.1.2 implement.                         OPIP 3.1.1 Att. 1, 10
: b.                   C.5 also       Provision for additional personnel    LERO has added two Emergency        Plan Sec. 2.1, 4.1 C.2.c          to advise and assist State and        Preparedness Advisors (EPA) to the OPIP 2.1.1 Local officials in an emergency.      organization, to advise and assist  OPIP 3.1.1 the Suffolk and Nassau County            Att. 1,  2, 3, Executives. In addition, LILC0's               4, 10 Albany Representative would proceed OPIP 3.6.3 to the State EOC to act as a             Att. 15 liaison until replaced by an off-   OPIP 4.1.1 shift Director or Manager of Local Response.
At the LER0 EOC, desks and phones have been allocated for various government officials as well as l                                                                                                       several specific LER0 interfaces l                                                                                                       identified.
In addition to the EPAs identified above, a Traffic Control Point i
Coordinator proceeds to the Suffolk l                                                                                                      County Police Headquarters to assist with dispatch of police to traffic control posts and key LERO positions are directed to interface with their County and State counterparts.
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ATTACHMENT II - SINMARY OF REVISION 9 0F LERO PLAN                                          .
(Including Plan, Procedures, and Appendix A)
II.1 NUREG 0654/ FEMA-REP-1 Rev.1 SUDDieWent 1 (Continued)
NUREG 0654 ITEM (S)       SUPP. 1. SEC. I.G. ISSUES                     PLAN RESPONSE            SECTIONS AFFECTED
: c. D.4          Provision for advising State and       LERO Director of Local Response    See C.5 above' J.10.f also  Local officials of emergency           contacts the Suffolk County        also:
;                    C.5          actions to be taken.                   Executive prior to initiating      Plan Sec. 3.6 any actions and advises him on the OPIP 3.6.3 emergency situation.
i               d. E.8          Provision for coordinating             The Director of Local-Response     Plan Sec. 3.3, 3.4 emergency messages with State and      obtains authorization from the     OPIP 3.8.2 Local governments.                    Suffolk County Executive or Governor prior to issuing an EBS message. This coordination is reflected in the content of the
!                                                                        EBS message.
;               e. F.1         Provision for communications with      RECS (Radiological Emergency        Plan Sec. 3.3, 3.4 non-participating State and Local      Communication System) dedicated     OPIP 3.3.4, 4.1.1 emergency response facilities,         phone lines are installed ir, i
'                                                                       several State and Local Offices.
New York State has indicated that the RECS phone locations in the State offices have either been disconnected or the offices have I                                                                       moved. LERO maintains commercial i
24-hour emergency phone numbers for both the State and County and would use these phone numbers if the RECS was not answered during an emergency.
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ATTACHMENT II - SUM 4ARY OF REVISION 9 0F LERO PLAN                                                 -
(Including Plan, Procedures, and Appendix A)
II.1 NUREG 0654/ FEMA-REP-1               Rev.1 Supplement 1 (coittinued)
NUREG 0654                                                                                                                      1 ITEM (S)            SUPP. 1. SEC. I.G. ISSUES                                PLAN RESPONSE             SECTIONS AFFECTED
: f. G.I.e              Provision for public information                  The following language has been    The Public Infor-describing the role of offsite                    added to the LERO Public           mation Brochure is a response organization.                            Information Brochure: "At the      separate document present time, New York State and   from the Plan. It Suffolk County are not              will be distributed participating in planning for an    prior to the FEMA emergency at Shoreham. So LILOO     REP-10 test.
has created, equipped, and trained the Local Emergency Response Organization (LER0) to respond to an accident at Shoreham in order to protect the public. LERO ir made up mostly of LILCO employees and contractors, working with people from Federal Government agencies like the Department of Energy and the U.S. Coast Guard and people from private organiza-tions like bus and ambulance companies. LERO has enough resources and trained emergency workers to respond to an emergency even if Suffolk County and New York State could not. Although LERO could protect the public all by itself, it would never have to in a real emergency because New York State and Suffolk County would help. The Federal Government recognizes that the State and County will use their best (continued on next page)

ATTACHMENT II - SUMARY OF REVISION 9 0F LERO PUUI                                        ..   '
(Including Plan, Procedures, and Appendix A)
II.1 NUREG 0654/ FEMA-REP-1 Rev. 1 Supplement 1 (continued)
NUREG 0654 ITEHCS)          SUPP. 1. SEC. I.G. ISSUES                    PLAN RESPONSE            SECTIONS AFFECTED efforts to protect the public if an accident at Shoreham happens.
Since Suffolk County does not have its own plan to respond to a Shoreham accident, it would generally follow LILCO's plan, which must be tested and approved by the Federal Government agencies that are responsible for the safety of nuclear power plants.
LERO officials would stay in contact with officials from New York State and Suffolk County throughout any emergency, and would use the advice and resources of LERO, in cooperation with Federal, State, and County officials to help protect the public's health and safety."
: g.       H.3          Establishment of an emergency          LER0 had already established an     Plan Sec. 4.1 operations center for use in           EOC in the LILC0 Brentwood          OPIP 4.1.1 directing and controlling offsite      facility prior to Revision 9.
response functions.
: h.       E.6          Offsite response organization shall The sirens in the Shoreham EPZ are Plan Sec. 3.3, 3.4, J.9          have the administration and            activated from LILC0 facilities                3.8 physical means (even though they       in Brentwood, Shoreham and an       OPIP 3.3.4. 3.8.2 may not have the responsibility)       electrical substation near for activating the alert and           Shoreham. This system was in notification system.-                  place prior to Revision 9. The (continued on next page)
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ATTACHMENT II - SlDMARY OF REVISION 9 0F LERO P1AN                                         ..
(Including Plan, Procedures, and Appendix A)
II.1   NUREG 0654/ FEMA-REP-1 Rev.1 Supplement I (continued)
NUREG 0654 ITEM (S)          SUPP. 1. SEC. I.G. ISSUES                   PLAN RESPONSE             SECTIONS AFFECTED EBS network is activated via a dedicated line from the Brentwood EOC to HPLR in Connecticut or via commercial phone line. In Revision 9 NPLR has been designated as the Common Point Control Station.
: 1.      J.10.f       Recommendation of the use of           It continues to be New York State   Plan Sec. 3.6, 3.9 potassium iodide (KI) for the          policy not to issue KI to the       OPIP 3.6.2 general public.                        general public. (New York State Radiological Emergency Preparedness Plan Part I, Section III, page III-44). LERO will, however, notify New York State when KI is recommended for use by emergency workers who have been trained in dosimetry and exposure control.
: j.      N.2.a        Provision for encouraging              LERO will formally request the      Plan Sec. 5.1, 5.2 N.6          participation in exercises and         participation of County and State   OPIP 5.1.1 drills by State and Local              personnel in exercises and drills.
governments but not requiring it.
: k.      0.4.k        Provision for training people in       LERO has previously maintained      Plan 5.1 the utility's offsite response         and continues to maintain a         OPIP 5.1.1 organization who will be               comprehensive training program responders.                            for LILO0 employees and support organizations.
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ATTACHMENT II - SUDMARY OF REVISION 9 OF LERO PLAN                                 ..
(Including Plan, Procedures, and Appendix A)
II.1 NUREG 0654/ FEMA-REP-1   Rev. 1 Supplement 1 (continued)
NUREG 0654 ITEM (S)           SUPP. 1. SEC. I.G. ISSUES                   PLAN RESPONSE           SECTIONS AFFECTED
: 1.        0.6           Provision for offering training        LER0's policy has been and        Plan Sec. 5.1, 5.4 to non-participating State and        continues to be that training is  OPIP 5.1.1, 5.4.1 Local governments and c'her.           offered to all emergency response organizations.                         support organizations.
: m.         P.11          Provision for providing copies of      LERO has in the past provided     Plan Sec. 5.4 the offsite plan and its revisions    controlled copies of the plan and to non-participating State and         revisions to both New York State local government entitles with        and Suffolk County, and continues which the offsite response             to do so. Nassau County will organization identifies interfaces     receive a controlled copy of in its offsite plan.                  Revision 9 of the Plan and will be sent future revisions.
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ATTACHMENT II - SENSIARY OF REVISION 9 0F LERO PLAN                                  ..,
(Including Plan, Procedures, and Appendix A)
II.2          ASLB-03 PARTIAL AND CONCLUDING PARTIAL INITIAL DECISION: APPEAL RULINGS ISSUE                          DECISION                             PLAN RESPONSE          SECTIONS AFFECTED
: a.         Evacuation           "The Board's ultimate finding on       The planning basis contemplated    Plan Sec. 1.4, 2.1, Shadow               this contention strongly depends       by the NUREG 0654 Supplement            2.2, 3.8 Phenomenon          on their being clear non-conflic-       provides for a best effort        OPIP 3.1.1 Att. 1, 10 23                   ting notice and instructions to        response by the State and County. OPIP 3.8.2 the public at the time of the          This includes the coordination of accident...The lack of assurance        EBS messages and other public of integrated action on the part        information during the emergency.
of the state and local governments constitutes a substantive deft-ciency in the Board's confidence that the public health and safety could be protected by LILC0 acting alone as by actions that were fully integrated with state and local governments."
Lona Island Liahting Comoany (Shoreham Nuclear Power Station, i                                                   Unit 1), LBP-85-12, 21 NRC 644, l                                                   670 (1985) (hereinafter "PID").
: b.          Special             "He agree with Staff that agree-       The LERO Plan identifies a relo-   Plan Sec. 3.6
!                               Facility-           ments do not necessarily have to       cation center for all EPZ special  OPIP 3.6.5 Att. 2, 3 l
Relocation          be between LILO0 and reception          facilities. In those cases where  App. A: IV-166b, i
Centers 24.N.       centers. Agreements between            the evacuating facility has not             IV-173 l                               72.C, 72.D          health care facilities and             identified a reception center,              Table XIIIA i                                                   reception centers themselves           LILO0 has designated its own would provide the requisite            facilities. These facilities are assurance that health and safety       wheelchair capable where needed.
of residents will be protected.
(continued on next page)
_ . , _ _ _  ,     ~    +s                                      ve                                             r
                                                                                                                                                      ''O

ATTACHNENT II - SUM 4ARY OF REVISION 9 0F LERO PLAN                                  -
(Including Plan, Procedures, and Appendix A)
II.2    ASLB-03 PARTIAL AND CONCLUDING PARTIAL INITIAL DECISION: APPEAL RULINGS (continued)
ISSUE                  DECISION                             PLAN RESPONSE        SECTIONS AFFECTED However, at this time relocation centers have not been designated and this constitutes a deficiency in the Plan "
PID, 21 NRC at 840.
: c. School       "[T]he fact remains that reception Revision 9 of the Plan designates   Plan Sec. 3.6, 4.2 Reception    centers have not yet been identi-     the Nassau Coliseum and Nassau   OPIP 3.6.5, 4.2.1 Centers 24.N fled. He therefore find for the       Community College as a School    App. A: II-19-21 Intervenors on the issue of the       Relocation Center for the public identity of reception centers for     and private schools in the EPZ.
school children. He note that the The combined capacity of these record has been reopened on the       facilities is adequate to hold matter of relocation centers for      all the students until they can the public. However, the conten- be reunited with their parents.
tions concerning relocation centers for the public are separate from those concerning relocation centers for school chlidren."
t PID, 21 NRC at 860.
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ATTACHMENT II - SLM4ARY OF REVISION 9 OF LERO PUUI                                         .
(Including Plan, Procedures, and Appendix A)
II.2                                          ASLB-03 PARTIAL AND CONCLUDING PARTIAL INITIAL DECISION: APPEAL RULINGS (continued)
ISSUE                       DECISION                           PLAN RESPONSE            SECTIONS AFFECTED
: d.      Time Estimates      "He find here that it is not          Time estimates for the evacuation Plan Sec. 1.4, 2.2 for Evacuation      possible to calculate how long        of the schools have been included             3.6, 4.2 71.B.1              an evacuation might take without      in Revision 9. LERO will provide App. A: IV-179-180 knowing the location of reception     supplementary buses to the regular          Table XIII C centers. LILCO has admitted that      buses that transport the school    OPIP 3.6.4, 3.6.5, the delay in evacuation may be        children so that there is suffi-        4.2.1 extensive but claims that this        cient capacity for "one wave" will not endanger the children        transportation of the children.
because they can shelter in the       The Nassau Coliseum and Nassau school buildings while awaiting       Community College have been the return of buses for               designated as the School Reloca-evacuation. Cordaro et al, ff.        tions Centers.
Tr. 9154. Vol. II, at 63. He do not find this acceptable.
He find that the lack of a reasonable estimate of the time to evacuate is a defect in the LILCO Plan."
PID, 21NRC at 872.
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ATTAONIENT II - SIDMutY OF REVISION 9 0F LERO PLAN                                         .
(Including Plan, Procedures, and Appendix A)
II.2 ASL8-03 PARTIAL AND CONCLUDING PARTIAL INITIAL DECISION: APPEAL RULINGS (continued)
ISSUE                     DECISION                             PLAN RESPONSE          SECTIONS AFFECTED
: e. Buses for      "LILOO has presented no evidence       LILOO has obtained additional bus  Plan Sec. 3.6 Evacuation     that buses committed to other uses     contracts for "first call" buses   App. A:   II-20-21 71.B.2         will be released to LILOO in the       without prior commitments to other OPIP 3.6.4, 3.6.5, event of an~ emergency at Shoreham. school districts. These buses are       5.3.1 LILOO witnesses testified that         available at all times for evacua-they are "confident" that buses        ting EPZ school children. These would be released. LILOO has           "first call" buses with LERO failed to provide an adequate          School Bus Drivers will be used basis for a Board finding that an      to supplement the regular buses evacuation of school children          contracted by the EPZ school could be accomplished within           districts, so that there is suffi-approximately the same time as a        cient capacity to allow a "one general public evacuation. We           wave" evacuation of the schools.
find that the subordination of LILOO's agreements for buses for use in an emergency to preexisting contracts for normal daily use by schools outside the EPZ constitutes a flaw in the LILO0 Plan. This deficiency could be corrected by showing that multiple bus runs will accomplish evacuation of school children in approximately the same time as a general popu-lation or that LILO0 has received commitments for release of buses from schools outside the EPZ, thus eliminating the need for multiple bus runs. However, on the record before us, we find that the LILOO Plan does not (continued on next page)

ATTACHMENT II - 

==SUMMARY==
OF REVISION 9 0F LERO PLAN                                    -.
(Including Plan, Procedures, and Appendix A)
II.2                                               ASLB-03 PARTIAL AND CONCLUDING PARTIAL INITIAL DECISION: APPEAL RULINGS (continued)
ISSUE                          DECISION                            PLAN RESPONSE            SECTIONS AFFECTED provide reasonable assurance that adequate protective measures will be taken in the event of an evacuation of school children from the Shoreham EPZ."
PID, 21 NRC at 874.
: f. School Bus     "On the record now before us we             In addition to the LERO School     App. A: II-20-21 Drivers        cannot make a finding that a                Bus Drivers driving the LERO       OPIP 3.6.5 24.H           sufficient number of school bus             supplied supplementary buses, 25.C          drivers can be relied upon to                LILOO has provided sufficient perform their duties if an                   LER0 School Bus Drivers to back accident occurred at Shoreham.               up regular school bus drivers.
Therefore, we are remanding this             These LERO personnel will report matter to the Licensing Board for            directly to the school bus yards further exploration,"                       and make themselves available to Lono Island Lightina Company,                drive the buses as needed.
ALAB-832, 23 NRC 135,154 (1986).
: g. Hospital       "The Licensing Board should have             Evacuation time estimates have     OPIP 3.6.1, Att. 2A l                                                                               Evacuation     required the applicant to fulfill            been calculated for the evacuation App. A: II-28,
!                                                                               72.0, E        the same planning obligations with of the hospitals. These time                          IV-178, V-7A
!                                                                                              regard to possible hospital evacu- estimates are included in the                         Table XIIIA, j                                                                                              ation as the Board imposed in                plan.                                             XV connection with the nursing / adult homes. He therefore remand and direct the Board to rectify this error."
Id. 23 NRC at 157.
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ATTACHMENT II - SU M ARY OF REVISION 9 0F LERO PLAN                                      -
(Including Plan, Procedures, and Appendix A)
II.2 ASLB-03 PARTIAL AND CONCLUDING PARTIAL INITIAL DECISION: APPEAL RULINGS (continued)
ISSUE                   DECISION                           PLAN RESPONSE           SECTIONS AFFECTED
: h. Legal         "The Board finds that the Applicant The "realism" planning basis is      Plan Sec. 1.4, 2.1, Authority     cannot prevail because its pre-        provided in Supplement 1 to                  2.2 1-10          emption, realism, and immateriality NUREG 0654. This planning basis      OPIP 3.1.1 arguments are without merit and        has been incorporated into the cannot overcome the conclusion         plan and procedures.
that the activities it seeks to perform as specified in Contentions 1-10 are unlawful."
PID, 21 NRC at 919.
: 1. Emergency     "He grant the request to reopen        HALK as the Common Point Control  Plan Sec. 2.2, 3.3, Broadcast     on this matter [of the withdrawal      Station has been replaced with               3.8 System        of HALK radio]."                       HPLR. This station in Connecticut OPIP 3.3.4, 3.8.2
                                    .Lona Island Liahting Company          provides full 24-hour coverage (Shoreham Nuclear Power Station,       of the EPZ.
Unit 1), CLI-87-05, 24 NRC (June 11, 1987).
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ATTACHMENT II - SUW44RY OF REVISION 9 0F LERO PLAN                                        -
(Including Plan, Procedures, and Appendix A)
II.3                     REGIONAL ASSISTANCE C0*lITTEE COMtENTS RAC ITEM (RATING)                      ISSUE                              PLAN RESPONSt           SECTIONS AFFECTED
: a.       A.2.b           Lack of legal authority.                The issue of legal authority is    Plan 1.4, 2.1, 2.2 (I)                                                    resolved by the planning basis for non-participating governments contained in NUREG 0654/ FEMA REP. 1 Rev. 1 Sup. 1.
: b.       A.3            The following Letters of Agreement The following letters have been A.4            were either needed or in need of        added to Appendix B:
(I)           update and/or clarification:
also F.1.c          FAA - Need letter detailing direct A letter of understanding with contact by LERO.                        the FAA has been added along with direct contact by LERO.
LIRR - Need letter detailing           A letter of understanding direct contact by LERO.                detailing LER0's contact has been included.
J.10.h         American Red Cross Letter does not     By {{letter dated|date=November 2, 1987|text=letter dated November 2, 1987}},    Plan Sec. 2.2, 3.7, provide adequate assurance of          the Nassau County Chapter of the               4.8 Congregate Care availability.          American Red Cross asked that        OPIP 3.7.1, 4.2.3 specific .eferences to it be deleted from the LERO Plan, and reiterated that, "in the event of a nuclear accident and evacuation, j                                                                                               the Red Cross will provide mass care services to the extent of its l
abilities and will cooperate with public and private organizations l                                                                                               to meet the needs. The American (continued on next page)
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ATTACHMENT II - SLBMARY OF REVISION 9 0F LERO PLAN                                             -
(Including Plan, Procedures, and Appendix A)
II.3   REGIONAL ASSISTANCE COWIITTEE COMIENTS (continued) l                  RAC ITEM (RATING)                           ISSUE                                 PLAN RESPONSE           SECTIONS AFFECTED Red Cross will open and operate Congregate Care Centers for long-term sheltering. The Red Cross maintains agreements with numerous facilities to provide congregate care, including LILCO facilities.
A Letter of Agreement for the use of LILOO facilities is contained in Appendix B.
t Teledyne Isotope - Contract does              Revised and updated contracts have not detail availability of                    been included in Appendix B with analysis services during an                    specific references to emergency emergency.                                    services.
: c.      E.6              Recommendation to include "good               The recommended language has been   OPIP 3.8.2 (A)              neighbor" language in EBS message             included in both the brochure and and brochure.                                 EBS message.
i
: d.      F.I.c            See A3-FAA (I)
: e.      G.I.a-d          Recommendation to include in the              The recommended language has been (A)              brochure radio channel information added to the public information to boaters.                                   brochure.
: f.      G.4b             The RAC expressed continued concern The ENC has been moved to the LILC0 Plan Sec. 3.8 G.4c             about lack of hard copy capability Training Center in Hauppauge.                  OPIP 3.8.1 (I)              at the ENC.                                   Additional copying capability has been provided to ensure machines are not overloaded and to also provide backup capacity.

ATTACHMENT II - SUMARY OF REVISION 9 0F LERO PUWI                                       ..
(Including Plan, Procedures, and Appendix A)
II.3 REGIONAL ASSISTANCE COMITTEE COMENTS (continued)
RAC ITEM (RATING)                    ISSUE                            PLAN RESPONSE             SECTIONS AFFECTED
: g.       J.9                   Delays in issuing dosimetry caused At all three staging areas the         OPIP 3.9.1, 4.5.1, J.109                 subsequent delays in dispatch of      issue of dosimetry has been              4.7.1, 2.1.1, (I)                  bus drivers.                          expedited by the following means:        5.3.1 Additional Dosimetry Record keepers (DRKs) have been added to assist with dosimetry issue.
The location of dosimetry issue has been moved to a larger room so that more field workers can be accommodated simultaneously.
: h.       J.10.e                Non-LERO workers (specifically       LILCO has mailed letters to every    Plan Sec. 5.1 K.3                   school bus drivers) need to be       non-LILCO organization mentioned     OPIP 5.1.1 K.4                   informed that they need to initiate in the LERO Plan that does not (I)                   a request for dosimetry training.- receive training. The role of the organization has been explained and the offer of training has been specifically made.
: 1.      J.10.h                 See A.3 (1)                   American Red Cross ATTACHMENT II - St# MARY OF REVISION 9 0F LERO PUUI                                     ..
(Including Plan, Procedures, and Appendix A)
II.3 REGIONAL ASSISTANCE COMITTEE COMENTS (continued)
RAC ITEM (RATING)                     ISSUE                              PLAN RESPONSE          SECTIONS AFFECTED
: j.       J.10.k       Snow Removal resources may be         In accordance with the planning    Plan Sec. 1.4, 2.2 (I)          unavailable,                          basis detailed in NUREG-0654       OPIP 3.6.3 Att. 16 REP. 1 Sup. 1, "State and local officials that have declined to participate in emergency planning will:
(a) Exercise their best efforts to protect the health and safety of the public; (b) Cooperate with the utility and follow the utility plan; and (c) Have the resources sufficient to implement those portions of the utility offsite plan where State and local response is necessary."
Accordingly, snow removal has been identified in the Plan as a resource provided by Suffolk County and details of interfacing with the County to obtain this assistance are included.
ATTACHMENT II - StMIARY OF REVISION 9 0F LERO PLAN                                    .,,
(Including Plan, Procedures, and Appendix A)
< II.3                                                           REG 10NAL ASSISTANCE COW (ITTEE COMfENTS (continued)
RAC ITEM (RATING)                                         ISSUE                             PLAN RESPONSE            SECTIONS AFFECTED
: k. J.12                              The monitoring of general             The monitoring procedure at the     Plan Sec. 3.6, 3.9 (I)                               population evacuees at the            Evacuee Reception Centers have      OPIP 3.6.5, 3.9.1, reception cer.ters is inadequate      been modified so that all                3.9.2, 4.3.1, since only the vehicle driver is      evacuees arriving at the Reception       5.3.1 regularly checked for                 Centers will be monitored within 12 contamination.                        hours. In order to accomplish this, additional monitoring personnel have been added to the reception centers.
Reception centers have not been       Reception centers have been designated, therefore, it is not     designated for all health care possible to evaluate the adequacy     facilities in the EPZ. Evacuees of staffing to monitor these         would be brought to a LILOO people.                               facility for monitoring prior to proceeding to these reception centers. Sufficient personnel are available to monitor these evacuees, at approximately the same rate at which they arrive.
: 1. K.3.a                            See Item J.10.e K.3.b K.4 (I)
ATTACHMENT II - SumWWtY OF REVISION 9 0F LERO PLAN                              ..
(Including Plan, Procedures, and Appendix A)
II.3                                           REGIONAL ASSISTANCE 00MilTTEE 00WtENTS (continued)
RAC ITEM (RATING)                                            ISSUE                            PLAN RESPONSE      SECTIONS AFFECTED
: m.      0.4                              Training in handling of                   The training program has been OPIP 5.1.1 (A)                             contaminated injured people should revised to provide the training be provided to additional personnel to the recommended personnel.
in the LERO organization.
l

ATTACHMENT II - SUM 44RY OF REVISION s OF LERO PLAN                                      ,.
(Including Plan, Procedures, and Appendix A)
II.4   OTHER CHANGES ISSUE                                     LERO RESPONSE                       SECTIONS AFFECTED
: a.         FEMA Guidance Memorandum          LILOO has obtained a letter of agreement with            Plan Sec. 2.2, 3.7 MS-1; This guidance details       Brunswick Hospital in Amityville to be the primary       OPIP 3.1.1, 4.2.2 the need to have a primary       hospital to satisfy the MS-1 requirement. In addition, and backup hospital for the       Revision 9 of the Plan identifies the Nassau County treatment of contaminated        Medical Center and Northport VA Medical Center to be injured members of the           backup facilities. The Nassau County Medical Center is general public.                   County operated, and would therefore be available during an emergency under the planning basis provided in NUREG 0654, Rev. 1, Sup. 1. The Northport VA Medical Center is available through the FRERP. All these factities have Nuclear Medicine and/or Radiology Departments and are therefore qualified to treat contaminated injured individuals.
: b.        LERO Pager Activation             In order to further expedite the mobilization of LERO    Plan Sec. 3.3 emergency workers, the pager activation portion of the   OPIP 3.3.5 Plan has been revised. In Revision 9 the LERO pagers have been reoriented so that they activate simulta-neously with the onsite SNPS pagers which are activated by the Control Room. Previously, the LERO pagers were activated by the SSO after the RECS message was received from the Control Room.
: c.        Updates due to personnel,         The following ministerial changes were made in facility or equipment             Revision 9:
changes.
l Updated farmstand and farm listings.                     OPIP 3.6.6 l                                                                                Changed Transfer Point from Brookhaven Multiplex         OPIP 3.6.4 l                                                                                Cinema to King Kullen Shopping Center.                   Appendix A i

ATTACHMENT II - St20ERY OF REVISION 9 OF LERO PUUI (Including Plan, Procedures, and Appendix A)                                           . * '
II.4   DTHER CHANGES (continued)
ISSUE                                 LERO RESPONSE                 SECTIONS AFFECTED Moved LERO Relocation Center, for families of      OPIP 4.6.1 emergency workers, from Hicksville to Brentwood.
Added and deleted personnel as necessary to ensure Plan Sec. 2.1 effective implementation of procedures.            OPIP 2.1.1 Modified dose assessments and protective action    OPIP 3.5.2, 3.6.1 computer program to reflect SNPS radiation monitor changes and new Radiological Emergency Data Form.
_ _ . _ _ _ _ _ _ _ ._     __J

Y-
                                                                        '}
IMPORTANT This plan is control copy number   N Please enter this number on the front of the following sections:
Volume I Volume II Volume III Plan Appendix A

~
l
                                                                                                                                                      ,4
                                                                                                                   ***' ERRATA ***
During the final quality control check of the enclosed plan / procedures, the attached two pages were discovered missing from the document.
Please insert these two pages into their respective procedures:
OPIP 3.6.1 - Plume Exposure Pathway                 Page 42a Proctective Action Recommendations OPIP 5.3.1 - Emergency Equipment                    Page 43 Inventory

(~}                                                                                    OPIP 3.6.1 s.-                                                                                  Page 42a of 44 Attachment 2 NON-TRAFFIC CONTROLLED EVACUATION TL'4ES*             Page 8 of 8 (continued)
WINTER (ADVERSE CONDITIONS)
                                                                                      ~
WIND                                                               j FROM (Deirees)            ZONES     TIME        ZONES   TIME      -
ZC .iES     TIMES N      349 to            ABCDE        3.33     ABCDEGHI   5.08        adCDEFGH       6.92 11                                                            IJKLMNOR NNE     12 to            ABCDE       3.33      ABCDEGH   5.33         A3CDEFGH       6.92 33                                                             IJKLMNOR NE     34 to             ABCDE        3.33     ABCDEFGH  6.00         ABCDEFGH       7.08 56                                                             IJKLMNQR l
ENE    57 to             ABCDE       3.33      ABCDEFG   5.83        ABCDEFGH        7.08 78                                                             IJKLMQR E      79 to             ABCDE       3.33      ABCDEFG   5.83         A8CDEFGH       7.08 101                                                            IJKLQR 1
ESE    102 to            ABCDE       3.33      A3CDEFG   5.83        A3CDEFGH        7.08 124                                                            IJKQ
      ,-                          l           1 SE     125 to            ABCDE       3.33      ABCDEF    5.42        ABCDEFGH        7.08 146                                                            IJKQ SSE    147 to            ABCDE       3.33      ABCDE     3.33        ABCDEFGH        6.00 168         ,
IJ S      169 to            ABCDE       3.33      ABCDE     3.33        ABCDEFGH        6.00 191                                                           IJ s
SSW    192 to            ABCDE       3.33      ABCDE     3.33        ASCDEFGH        6.00 213                                                           IJ l
SW     214 to            ABCDE       3.33      ABCDEJ    3.33        A8CDEFGH        6.00 236                                                            IJP WSW    237 to         lABCDE         3.33      ABCDEJ    3.33        ASCDEFGH        6.00 258                                                           IJ0PS l
W      259 to            ABCDE       3.33      ABCDEIJ   3.42        ABCDEFGH        6.00 281                                                           IJ0PS WNW    282 to            ADCDE       3.33     ABCDEHIJ   4.00        ABCDEFGH        6.00 303                                                           IJ0PS 304 to            ABCDE       3.33      ABCDEHIJ  4.00        ABCDEFGH        6.00 C-r)NW       326                                                           IJNOPS
                             \                                              l NNW    327 to        lABCDE          3.33     ABCDEGHI   5.08       ABCDEFGH         6.92 348                                    J                      IJLMNOS
         *All times include 0.33 nours tor mobilization.                                        Rev. 5

                                                                                                                 . .S O                                                  O                                            O            -  .
OPIP 5.3.1
               **** Emergency Equipment Inventory System - Version: D.15 Date: 87/06/08 **** Page 43 of 90 Attachment 11 Page 4 of 7 General Equipment Master Listing For RIVERHEAD STAGING AREA Date:                                                                                                Page: 4
=====================================r================_========================================
Latest           Number           Number  Discrepency         Inventory Item                              Revision         Required          Found      Number             Date
==================================================-================= =========================
DRK 3.9.2- 2                         9                    5 DRK 3.9.2- 7                         9                    5 DRK 3.9.2- 8                         9                    5 EASEL                                 9                   2 ERASER                                 9                  2 EXTENSION CORD                         9                  2 FILE FOLDER                            9              240 FIRST AID KIT                          9                  2 FLARE - 30 MIN                         9                72 FLASHLIGHT                             9              125 GLOVE - RUBBER                         9                10 GIDVE LINER                            9                10 GT-ADAPTER                             9                  2 GT-RC ADAPTER                          9                  2 HAGSTROM SC                            9              250 KEY - BARRICADE                        9                  2 KI                                     9              240 KI SIMULATE                            9              240 LOG BOOK                               9                  2 MAP F SIREN                            9                  1 MAP F TCP                              9                  1 MAP F TRANS PT                         9                  1 MAP UF SIREN                           9                  5                                                          ,
MAP UF TCP                            9                  5 MAP UF TRANS PT                       9                  5 MARKER                                9                  6 MARKER DRY                            9                  2 CPIP RVHD 216                         9                   1 PA SYSTEM                             9                   1 PACK-BUS DRIVER                       9               115 PACK-EV RT SPOT                        9                  2 PACK-LTG                               9                  4 PACK-PECONIC                           9               50 PACK-ROAD CREW                         9                14 PACK-RT ALERT                          9               20 PACK-TPC-DIST                          9                  5 Rev. 9

                                                                                                                                                                           ~
OPIP 5.4.1 Page 11 of 18 Attachment 4 Page 1 of 1 REVISION SIGNOFF FORM To:                     Holder, Manual No.                42 Local Offsite Emergency Plans and Implemtatation Procedures From:                   Emergency Planning Coordinator

==Subject:==
REVISION TRANSMITTAL Attached is Revision No.                                 9   to the Local Offsite Radiological Emergency Response Plan and Implementation Procedures for insertion into your Controlled Copy. Two copies of this memorandum have been arovided. Once you have complied with the instructions presented aelow, sign one copy and place .it in front of your controlled copy of the Manual. Sign the second copy of the memorandum and return it withinseven(7)workingdaysgo:
Emergency Preparednes's Coordinator i                                     LILCO                             i i
175 East Old Country' Road
,                                     Hicksville, New York' 11801 The undersigned acknowledges completion of the following actions:                                                                                             l
: 1. The receipt and incorporation of this revision into my copy of                                                                                         l the Local Offsite Radiological Emergency Response Plan and Implementation Procedures.
: 2. Destruction of all pages which have been superceded by this                                                                                     -
,                 revision.
4 I
i                                                                                                                                                      .             I Signature                                                                                           Date           '
4 i
l 6
Rev. 5
(
           .-         , _ _ _ , _ . _       ____ _    -___.-_ , _ _ .                       _ _ -                                                                          3

t, OPIP 5.4.1 Page 11 of 18 Attachment 4 Page 1 of 1 REVISION SIGNOFF FORM To:        Holder, Manual No. bl Local Offsite Emergency Plans and Implementation Procedures From:      Emergency Planning Coordinator

==Subject:==
REVISION TRANSMITTAL Attached is Revision No. 9        to the Local Offsite Radiological Emergency Response Plan and Implementation Procedures for insertion inte your Controlled Copy. Two copies of this memorandum have been provided. Once you have complied with the instructions presented below, sign one copy and place it in front of your controlled copy of the Manual. Sign the second copy of the memorandum and return it within seven (7) working days tlo:
Emergency Preparedness Coordinator LILCO                  I 175 East Old Country Road Hicksville, New York     11801 The undersigned acknowledges completion of the following actions:            f
: 1. The receipt and incorporation of this revision into my copy of           l the Local Offsite Radiological Emergency Response Plan and Implementation Procedures.
: 2. Destruction of all pages which have been superceded by this revision.
                                                                    .              I Signature                           Date          '
l l
Rev. 5
       .}}