ML20086M868

Motion for Summary Disposition of Phase II Emergency Planning Contention 33 Re DOE-RAP Monitoring Team Communications.No Genuine Issue of Matl Fact Exists

ML20086M868
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/13/1984
From:	Sisk K HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20086M832	List: ML20086M830 ML20086M846 ML20086M868 ML20086M882 ML20086M896 ML20086M915 ML20086M924 ML20086M936 ML20086M958 ML20086M981 ML20086M989 ML20086N008 ML20086N023 ML20086N035 ML20086N121
References
ISSUANCES-OL-3, NUDOCS 8402170125
Download: ML20086M868 (6)

Text

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a LILCO, February 13, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

) .

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

, ) (Emergency Planning

.; (Shoreham Nuclear Power Station, ) Proceeding)

Unit 1) )

LILCO'S MOTION FOR

SUMMARY

DISPOSITION OF CONTENTION 33

, JDOE-RAP MONITORING TEAMS COMMUNICATION)

LILCO hereby moves, pursuant to 10 C.F.R. $ 2.749, for summary disposition of the Phase II emergency planning conten-tion having to do with DOE-RAP Monitoring Teams Communications.

I. Contention and Legal Standards The contention reads as follows:

Contention 33. The LILCO Plan fails to demonstrate that there will be ade-quate means of communication between the Shoreham facility, the EOC.and the DOE-RAP field monitoring teams, as re-quired by NUREG 0654,Section II.F.1.d.

(See FEMA Report, at 5.) The Plan does not provide for any radio communications between the DOE-RAP field monitoring teams and the EOC or the Shoreham facili-ty. Instead, LILCO has advised Suffolk .

County that persennel in the EOC will be able to communicate only with the I

Brookhaven Area Office (via a dedicated telephone line). Apparently, the Brookhaven Area' Office will separately communicate with the field monitoring teams via BNL radio frequencies. Thus, if the Brookhaven Area Office had to be evacuated, there would be no means of I

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communicating with field monitoring teams. Because, communications between j the field monitoring teams and the EOC 1 must be relayed via separate means of l communications through the Brookhaven Area Office, there is no assurance that necessary and appropriate offsite acci-dent and dose assessment actions, including those necescary to determine the appropriate protective action recom-mendations, can or will be taken prompt-ly, as required by 10 CFR Sections 50.47(b)(9) and 50.47(b)(10).

The legal standards cited in Contention 33 are:

l Adequate methods, systems, and equip-ment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

10 C.F.R. 5 50.47(b)(9).

A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of-protective ^ actions during an emergency, consistent with Federal guidance are de-veloped and in place, and protective ac-tions for the ingestion exposure pathway ,

EPZ appropriate to the locale have been i developed.

10 C.F.R. $ 50.47(b)(10).

Each plan shall include:

d. provision for communications be-tween the nuclear facility and the li-censee's near-site Emergency Operations Facility, State and local emergency op-erations centers, and radiological moni-toring teams.

NUREG-0654, II.F.1.d.

II. Basic The basis for this motion for summary disposition is that the Contention is predicated upon an erroneous interpreta-tion of NUREG-0654, 9 II.F.1.d. The material facts needed to decide this contention are simple and undisputed.

NUREG-0654, 9 II.F.1.d., does not require communications between the Shoreham facility and DOE-RAP field monitoring teams; instead, it requires communications between the Shoreham facility and the licensee's, i.e., LILCO's radiological moni-toring teams. These communications are provided by radio as set forth in the onsite plan and procedures which were the sub-ject of Phase I of this proceeding. The DOE-RAP field moni-toring teams, by design, operate independently of the LILCO monitoring teams. Information from the LILCO monitoring teams and information from the DOE-RAP teams will be assimilated at the EOC, where protective action recommendations may be made or revised.

The LILCO Transition Plan in Revision 3, at 3.4-3 and

3. 4-4 Figures 3. 4.1, 4.1.3 (Attachments 1, 2, 3, and 4) and At-tachment 5 to this motion, page 7, show that the DOE-RAP teams are to be equipped with radios with a frequency capable of com-municating with the Brookhaven Area Office. The Brookhaven Area Office, in turn, has a dedicated line to the EOC, to transmit DOE-RAP monitoring team and dose assessment informa-tion. This answers the comment in the FEMA Report at 5, cited in the Contention, which found the plan adequate and simply asked how these communications would-take place.

If the DOE Brookhaven Area Office were evacuated during an emergency, there are provisions at the EOC for the DOE-Brookhaven Area Office personnel. These personnel could also move to another location outside the EPZ. DOE's communi-cations apparatus, inluding communications to DOE-RAP field survey teams, is mobile, since the same equipment and personnel would be available to respond to an emergency at any nuclear power plant in the Northeast region. -

III. Conclusion Contention 33 is predicated upon an erroneous interpre-tation of NUREG-0654, 9 II.F.1.d., and is refuted by the Plan sections cited. Provisions are made for communications between the EOC and the DOE Brookhaven Area Office and the DOE-RAP teams. Provisions are also made for these communications, even if the Brookhaven Area Office were evacuated. These provisions more than satisfy the requirements of 10 C.F.R. 50.47(b)(9),

(b)(lO) and NUREG-0654, 5 II.F.1.d.

Respectfully submitted, LONG ISLAND LIGHTING COMPANY By ,1 #

Jaitfes N. CEfistmdn K. Dennis Sisk Hunton & Williams P.O. Box 1535 707 East Main Street Richmond, VA 23212 DATED: February 13, 1984

LILCO, February 13, 1984 Annex STATEMENT OF THE MATERIAL FACTS AS TO WHICH LILCO CONTENDS THAT THERE IS NO GENUINE ISSUE TO BE HEARD ON CONTENTION 33 (DOE-RAP MONITORING TEAMS COMMUNICATION) 1 The following are thejmaterial facts as to which LILCO contends that there is no genuine issue to be heard under Con-tention 33:

1. DOE-RAP field monitoring teams have a radio system I

• and equipment assigned to the Brookhaven Area Office RAP which provides communications between those field monitoring teams and the Brookhaven Area Office.

2. A dedicated telephone line has been installed to provide direct communications between the EOC dose assessment area and the Brookhaven Area Office.

3. Commercial telephone serves as an additional means of communication between the EOC dose assessment area and the Brookhaven Area Office.

4. Communications between LILCO monitoring teams and j the Shoreham facility are provided by radio.

5. Communications between the Shoreham facility and the EOC will be provided by RECS line, commercial telephone and the ESO frequency.

6. If the DOE Brookhaven Area-Office were evacuated during an emergency, there are provisions at the EOC for the DOE-Brookhaven Area Office personnel.

7. These personnel could also move to another location I

outside the EPZ.

8. DOE's communicat.fons apparatus, including communi-I cations to field survey teams, is mobile, since the same equip-ment and personnel would be available to respond to an emerge.n-cy at any nuclear power plant in the Northeast region. l l

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