ML20237G761

Intervenor Exhibit I-SC-105,consisting of 860319 Comments on Draft Shoreham Rept

ML20237G761
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/11/1987
From:	Keller J IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	Kowieski R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
JHK-17-86, OL-5-I-SC-105, NUDOCS 8709020398
Download: ML20237G761 (7)

Text

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TEMA-REGION II INEh,^ ~ D & sans nati:nat enoineertar Labeoete9 L / {7 JHK-17-86 P March 19, 1985 88-322-0& 5 h'f//fVY I ,] d d ' ! Roger B. Kowiecki, Chairman Regional Assistance Comittee Rsgion II Federal Emergency Manngement Agency 26 Federal Plaza New York, NY 10278 l

Subject:

Coments On The Draft Shoreham Report i. The INEL evaluators have reviewed the subject report and would all like to commend the.ANL report writers for an excellent job. Drawing together inputs from the many evaluators and preparing a report which reads as well as this draft is indeed difficult and often a thankless task. He have paid particular attention to our own areas of evaluation and I have reviewed the entire draft. Our collective coments fo11cw. My major concern is one of consistency. It appears that in several cases tha evaluator has rated an issue as a less serious problem than has been rated in other exercises in New York. This is not fair or correct. Clearly the report writars have taken what was presented and this issue is with individual evaluators not with the report writers. If you have any questions, please contact me. Sincerely, /0 . H. Keller, Fellow Scientist Special Programs cc: M. Lawless - FEMA

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i Roger B. Kowieski Page 2 JHK-17-86 March 19, 1986 i pm gopent o ix, parag 4 The statement that the objectives were partly met does The only negative statement concerns the dosenot s } projection status board (next page). Thu body of the partly met and gives the reason for not nosting th i objective. detail to support the partly met statement.It would appea xiii, lins 8 I do not understand the basis for the cornnent i concerning the need for additional train ng. previous sentence says that both drivers were well The i briefed and the Table on page 24 says that only two bus routes were to be evaluated. xiii, last lins the readability.I think the last sentence.could be reworded to imp i. xv, line 2 The sentence is not clear. I am not suru that the What'they need to know is how to use their d of supervision and who would authorize exces xviii, line 9 While it is true that the monitoring of the RAC chairman took more time than that called for in the plan, the evaluators at the reception center did not see fit to coment on this fact in their report (see page 115). I believe the body of the report takes the ^ correct approach. If the approximately 100 people who '{ were processed at the reception center were mon i the one exception I This statement should be deleted { from the summary.. If the deci this statement in the summary,sion is made to leave additional material is required in the body of the report to support this issue. 6 This figure is very difficult to read. Also there are several errors in the figure. According to t account of assignments en the previous pages,he written l McIntire should be added to the FEMA Comand Post. T P. assignments of P. Becherman and W. Gasper should be reviewed and corrected or the previous page sho g bg corrected. 3 4

). Roger B. Kowieski Page 3 JHK-17-86 March 19, 1986 i page Coment t, 23, line 7 The statement should be modified to clearly indicate that these two ter.ms were DOE-RAP teams operating in i support of LERO. I 29, The entry under the BHO for the time of facility i l declared operational should be 0745. I believe this was my error during the time line meeting. I thought ! l corrected the entry at that time, sorry. 40, lines 15-22 This whole discussion should be reviewed very e and k carefully. My review of the scenario and Attachment 5 45, #6 to OpIP 3.6.1 indicates that some rewording is needed. 4 d I is intended for General Emergency ECL use and contains the terms core failure, which is defined 1 in thu footnote as releass of fission products into i t containment and containment failure, defined as release L ' ~ of fission products into the atmosphere. In the exercise scenario there was never a release into '{.{ containment as such. The release pathway was by way of a broken steam line outside containment and the failure to be able is isolate the steam line. This condition was the cause of the Site Area ECL which was reported to the LERO EOC at 0824. One could conclude that the 2 inability to isolate the steam line and hence the leak is a loss of containment and in fact a small low levet leak to the environment was occurring and was reported 3 to the LER0 EOC at 0830. The General Emergency ECL was i declared and reported to ths LERO EOC at 0946. This declaration was caused by the continued loss of water from the primary system due to the steam leak and tho' loss of several water supply sources due to the loss of an electrical supply bus. The core f.ad at this time not failed to a degree to necessitate the declaration of a General Energency ECL due to dose rates offsite i but clearly the potential existed for core failure. The ~ EOF noted the major relekse at 1130 which indicated core failure although the time the LER0 EOC was notified was not reported. I have no problem with the concept of the issue reported here however, I believe-some rewording is essential. 42, lines 14-16 How can this be rated met? The discussion and the Table 2.1 clearly show that the siren may have been N sounded within the 15 minute standard but the i instructional message (EBS) was not given to the publi I within the 15 minute standard in all cases. 731h03 l $

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Roger B. Kowieski i Page 4 JHK-17-86 March 19, 1986 i

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coment 53, # 4 This appears to be the same as the Deficiency shown on page 51. k'hy give two hits on the same issue? i 56, #12 This issue should be rated as a Deficiency. I tha failure to supplII analysis of this issue in other exercises ha public (ESS message)y the instructional message to the i then called a category A).within the 15 minute standa Deficiency of the same(failure should be consistently rated. The evaluation i the decision is made to change this rating, additional If wording changes are required in the body of ths report. 58, 4th issue It would seem to me that this is an area requiring corrective action not an area recommended for ivo reveme'tt. were activated based on the discussion on page 44I However, since tone alert radios are often used in areas where siren coverage is not adequate, I would think that there should be no possible confusion and that corrective action is required. 59, line 12 There is confusion between the statement concerning school evacuation and the Table on page 24. 66, line 5 improve readability by bringing similar issuesI thin together. Specifically I recomend moving three sentences starting with "Afte ending with... timely manner"r receiving.......and in the first itne. to after the word basis 68, line 1 Change the first word in the first full sentence from "The" to "Two" computer... 71, Corrective The evaluator rated this issue as being an area Action recomended for improvement. The better than adequate performance. issue would improve a Additional equipm3nt was available in the event that some equipment was . contaminated. This rating should be changed. 71, line 20 Make " reading" plural. 74, lines 2-3 The times listed do not correspond to the data in Tabla 1.7.2 on page 30, 731804 i c - _ - -__

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Roger B. Kowieski page 5 JHK-17-86 March 19, 1986 g Comment 74, line 23 The evacuation zones should read A to M not A, M. 9 the rumor control information actually said A and M and If not A to M, this is another issue which should be discussed and rated. I 81, #1 The issue of the time required to alert the public in 93, #1 the event of a siren failure is an proper issue '[ 106, #1 however, in my opinion the rating should be a Deficiency. As I rsad NUREG 0654 Appendix 3, Section B.2.c, the acceptance criteria calls for a design objective cf a 45 minute notification of the pcpulation who may not have received the initial notification. also think that a siren failure would result in some I l parts of the population not receiving the initini notification. I understand that a design objective is not necessari1y'a performance standard however, if one considers the time necessary to identify Mich siren has failed, notify the staging area, dispatch r3ute l alerting drivers, and complete the. route, it would appear that the 45 minute desigr. objactive cannot be met. The exercise svaluation did not include the longer that the design objective. initial step in the process a 111, line 12 The statement is true but does not give much detail. Based on discussions with ths evaluator I suggest deleting the current sentence and replacing it with: "The generation of liquid waste was minimized by not using flooding methods. As an alternate to flooding, decontamination of vehicle surfaces was accomplished by paper towels, swipes', and damp cloths which were includsd in the solid waste." 115, Sect 2.10 In my opinion some nention must be made of the fact that the two congrelate care centers demonstrated are not in the plan. through the NRC just prior to the exercise and noRevision 6 mention was made of these centers. says on page App-B-10 in the letter of agreement withThe plan cu the Red Cross; "In addition, there exist agreements between the Nassau County Chapter of the /merican Red allowing the Red Cross to usCross and the facilities named on th shelter during an emergsney."e the facilities for (emphasis added). 731800r-

1 6~. 03/19 15:24 P06 c W lNC- -!CPP 637 5 2J - 3 4 9 9 1 1 i { Roger B. Xowieski Page 6 JHX-17-86 March 19, 1986 i i paje coment 115, Sect 2.10 Neither of the facilities demonstrated appear on the (Con't) attached list. that an exercise is a demonstration of theIt has always been ij i. implementation of a i.i actions can be taken, plan not just that acceptable letters of agreemer.t are required.At the very least, additional s i, } 731806 - - -}}