ML20236E119
| ML20236E119 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/17/1989 |
| From: | Kwiatkowski D Federal Emergency Management Agency |
| To: | Congel F Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8903230451 | |
| Download: ML20236E119 (22) | |
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4 g Federal Emergency Management Agency Washington, D.C. 20472 March 17, 1989 MEMORANDUM FOR: Frank J. Congel Director, Division of Radiation Protection and Emergency Preparedness ffice of Nuclear Reactor Regulation uclear R lat ry Commis ion FROM: H. Kwi kowski Assistant Ass ciate Director Office of Natural and Technological Hazards
SUBJECT:
FEMA Support for the Nuclear. Regulatory Commission Licensing Process for the Shoreham Nuclear Power Station This is in response to your memoranda of November 7,1988, and December 5, 1988, to Richard W. Krimm, requesting that the Federal Emergency Management Agecy (FEMA) review the following documents and provide comments. The documents are:
The Long Island Lighting Company (LILCO) draft' proposed brochure for fanners, food processors and food distributors for the Shoreham Nuclear Power Station; LILCO's schedule for correcting Areas Requiring Corrective Action (ARCA) identified in FEMA's Post-Exercise Assessment for the June 7 - 9,1988, Shoreham exercise; and LILC0's responses to FEMA's Review of Revision 10 of the LILCO Offsite Emergency Response Plan for Shoreham and LILCO's proposed changes to be incorporated in the next revision of that plan.
The reviews have been prepared by FEMA Region II and include input from the Regional Assistance Committee (RAC). We realize that LILC0's responses
( to the FEMA September 9,1988, Review of Revision 10 do not constitute actual plan revisions. Thus, although in most cases, the responses appear adequate, We must await the submittal of the next plan revision to evaluate N
the actual changes as they are executed in the plan. The same is true rM where plan changes constitute part or all of the proposed corrective 58Q- action for an exercise issue.
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$$ In addition, we have reiterated, as a reminder, several items listed in y the FEMA review of Revision 10 that LILC0 did not specifically address, pg Finally, as promised on page 6 of the review of Revision 10, we have o ca provided an update of the FEMA review of the LILC0 gener31 public information ,
l QC brochure to be distributed in the 10-mile Emergency Planning Zone. I
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i FEMA continues to support its overall finding of reasonable assurance transmitted to the Nuclear Regulatory Commission (NRC) on September 9, 1988. ,
l Although. not specifically addressed in the above mentioned documents, LILC0 should take note of the requirement for an Annual Letter of ' Certification prescribed by FEMA Guidance Memorandum (GM) PR-1, in order to facilitate i the monitoring of radiological emergency preparedness (REP) planning and' l preparedness requirements under NUREG-0654/ FEMA-REP-1, Rev. 1, Supp. 1.
The Annual Letter of Certification should be submitted to FEMA through the NRC. It is nonnally due by January 31 of each year and should address compliance with periodic requirements for the preceding year. However, given the impact that the' Atomic Safety and Licensing Board (ASLB) proceedings have had on the submittal of information from LILCO, it would be acceptable if the first Annual Letter of Certification were submitted with their next plan revision. Specific items to be addressed are indicated in GM PR-1. That list has been modified as shown on the attached FEMA Region II memorandum to include requirements relating to non-participating organizations, 1 as' defined in NUREG-0654/ FEMA-REP-1, Rev.1, Supp. 1. j 1
As you will recall, on December 20, 1988, Richard W. Krimm transmitted to you FEMA's preliminary technical review of the Shoreham alert and a notification system (ANS) design. I have included a copy of the transmittal memorandum for your information. As stated in that report, the preliminary technical analysis indicates that the Shoreham ANS is adequate to allow its activation for the telephone survey. The report is now under review in FEMA Region II. We have received approval from the Office of Management ;
and Budget to conduct the remaining four telephone surveys, one of which !
is for Shoreham. We are now in a position to schedule a date for the survey. However, we understand that LILC0 intends to distribute the general public information brochure before the survey takes place. The issuance of that brochure is affected by the following discussion.
Further, it is FEMA's position that while the use, and the representation !
of this use in the public information materials, of LILCO's Bellmore facility W
as a reception center has been prohibited without the prior approval of the Town of Hempstead, the use of the facility and the representation of use may be permissible under the assumptions and provisions of NUREG-0654/
FEMA-REP-1, Rev. 1, Supp.1. However, the FEMA 'Of fice of General Counsel has identified both matters as a legal issue. FEMA defers to the NRC on whether LILC0 has adequately accommodated the concerns expressed by the Atomic Safety and Licensing Appeal Board in' ALAB-905 on this matter. We note that the most current version of draft reception center maps for the brochure for each of the 19 emergency response ^ planning areas (ERPA) contains the followirg language directly below the map title, "A New York State court has ruled that, because of local zoning laws,-this Reception Center may not be used without prior approval of the Town of Hempstead.
If this Reception Center is needed during an emergency at the Shoreham Nuclear Power Station, LERO will request the permission of the appropriate official (s) of the Town of Hempstead, Nassau County, or New York State
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before-it is used." On adviceLof counsel,1 FEMA continues to believe that -
the language of the brochure gives adequate-advice to the public, and reflects the correct analysis of the New York Supreme Court. decision as ,
applied in the emergency planning context. EFEMA's,0ffice of: General = -1 Counsel bases its. advice on continuous; tracking:of emergency response-related l court decisions. FEMA knows of no' actual case where zoning = restrictions- '
prevented or delayed an emergency response,-. even by authorized private entities. -
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As a tangential ~ issue. the above quotation now appears evenLon reception ~
l center maps for ERPA's whose population would be directedito the Roslyn and Hicksville facilities. -This was' probably a printing error, since:
the language addresses only zoning restrictions for the Bellmore facility.
However, as ' indicated in the attached review of the brochure,-if the. . )
language is acceptable to permit Bellmore to be. mentioned-as a reception center, it should be . retained only on maps ,for Bellmore and deleted from-the maps for the other'two facilities.
We have als'o included an attachment listing clarifications / corrections-to the FEMA Post-Exercise Assessment on the June 1988 Shoreham exercise.-
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These were compiled in the process of doing preparatory work for the now cancelled OL-5R hearing on :the exercise.
We hope that the above information is helpful.- If we-can be of further l assistance, please feel free to contact-me.at 646-2871.
Attachments As Stated
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Federal Emergency Management Agency Region 11 26 Federal Plaza New York, New' York 10278 March 13, 1989 MEMORANDUM FOR: Dennis H. Kwiatkowski Assistant Associate Director OfficeofNaturalandTechnolo,g4calHazards FROM: Ihor W. Husar, Chief # '
Natural and Technological Hazards Division
SUBJECT:
FEMA Support for NRC Licensing of the Shoreham Nuclear Power Station In response to the request of December 9, 1988, from Richard W.
Krimm, attached please find our review comments for the following materials:
LILCO Schedule for Correcting ARCAs Identified at the June 1988 Exercise, Proposed Plan Review Changes in Response to RAC Review comments for Rev. 10 of the LERO Plan for Shoreham, and
- LILCO's draft brochure entitled- " Radiological Emergency Information for Farmers, Food Processors and Food Distributors", 1989.
It should be noted that these reviews include input from the Regional Assistance Committee (RAC). We realize that LILCO's responses to the FEMA September 9, 1988, Review of Revision 10 do not constitute actual plan revisions. Thus, although in most cases, the responses appear adequate, we must await the submittal of the next plan revision to evaluate the actual changes as they are executed in the plan. The same is true where changes constitute part or all of the proposed corrective action for an exercise issue.
In addition, we have reiterated several items listed in the review of Revision 10 which LILCO did not specifically address. Finally, as we promised on page G of the review of Revision 10, we have provided an update of the review of the LILCO public information brochure. Nothing in the attached reviews causes FEMA to modify its overall finding of reasonable assurance transmitted to the Nuclear Regulatory Commission on September 9, 1988.
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l In addition to the attached comments, the following items should be requested from LILCO:
(a) Scheduled dates of the public information ' and ' the PAR /z Accident' Management = tabletop training drills mentioned-in the ARCA responses.
(b) Letters of Agreement that will expire by the date of1 the j next plan revision and renegotiated bus yard' contracts which were to be finalized by' December 31, 1988' .
(c) The. Annual Letter of Certification as prescribed in'GM PR-1, in order to facilitate the monitoring of ' REP planning and. preparedness requirements as indicated in NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1. The ' Annual Letter of Certification-should be submitted to FEMA through the NRC.
It.is normally due by. January 31 of each year and should address compliance with periodic requirements for the preceding year. However, given the impact that the Atomic Safety and Licensing Board (ASLB) proceedings have had on the submittal of information from LILCO, it would be 3
acceptable if the first Annual Letter of Certification were j submitted with 'their plan revision. This letter shall .i include assurances that the requisite activities have been undertaken or. completed, as appropriate, by-LILCO for'the following functions: !
- 1. Public Education and Information (G): Means of dissemination of information, dates, participants, sponsoring organizations and description of any programs conducted to increase public and media' radiological emergency planning and response awareness. f l
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- 2. Emercency Facilities and Eauioment (H): Type of equipment / instrument, quantity and dates of check / test. i I
- 3. Exercise (N): Testing of all major elements, conducting l exercises under various time and seasonal conditions, i unannounced exercises and testing of offsite plans for !
implementing ingestion pathway measures.
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- 4. Drills (N): Types, dates held and participating organizations.
- 5. Radiological Emeroency Resoonse Trainina (O) : Offers of training made to non-participating governmental organizations as defined in Supp. 1. Scope and purpose of training given, dates held, number of participants, emergency assignment categories of participants, agencies represented (if appropriate), and sponsors of training.
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- 6. Uodate' of Plans and Letters of Aareement (P):
Verification that plans and letters of agreement have been reviewed and appropriate changes made. Updates of plans should include telephone numbers, call-down lists and maps.
Verification that copies of the offsite plan' and its revisions have been provided to non-participating State and local' governmental entities, as prescribed under Element P.
11 of NUREG-0654/ FEMA-REP-1, Rev. 1, Supp. 1.
- 7. Alert and Notification (Annendix 31: Type of. tests conducted in accordance with established schedule, dates held, and operability percentage achieved based on periodic testing.
The attachments to this memorandum contain our review ccmments as referenced above.
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corrections to the FEMA Post-Exercise Assessment on the June 1988 Shoreham exercise. These were compiled in the process of doing preparatory work for the now cancelled OL-5R hearing on the exercise.
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Attachments '
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V March 13, 1989 Attachment 1 Page 1 of 6 Review of the LILCO Schedule for Correcting Exercise ARCAs and Proposed Plan Review Changes in Response to RAC Review Comments for Rev. 10 of the Plan NUREG-0654 Item No. Suno. 1 Ref. Evaluation of LERO Responses REVIEW OF LTLCQ_ SCHEDULE FOR CORRECTING ARCAS LERO EOC
- 1. E.1 Proposed response should be adequate.
- 2. E.5, I.8 Proposed response should be adequate when combined with the response to FEMA's evaluation of E.5 aspectts of Revision 10. See item C of plan comments. Also, the scheduled date of the Public Information Tabletop training drill should be included.
- 3. J.11 Proposed response should be adequate.
Also, scheduled dates of the PAR / Accident Management tabletop training drills should be included.
. 4. K.3.b Proposed response should be adequate when combined with the response to FEMA's evaluation of K.3.b aspects of Rev. 10. Also, LILCO was aware prior to the excrcise that the exercise evaluation methodology did not include any statistical treatment of either scope or expected response. It is not appropriate at this point to attempt to discuss responses on a statistical basis.
- 5. K.4 LILCO was aware prior to the exercise that the exercise evaluation methodology did not include any statistical treatment of either scope or expected response. It is not appropriate at this point to attempt to discuss response on a statistical basis. See item y of plan review comments -
this is generic for all emergency workers not just bus drivers.
March 13, 1989 Attachment 1 Page 2 of 6 Review of the LILCO Schedule for Correcting Exercise ARCAs and Proposed Plan Review Changes in Response to RAC Review Comments for Rev. 10 of the Plan NUREG-0654 Item No. Suno. 1 Ref. Evaluation of LERO Responses
- 6. J.10.e Proposed response should be adequate.
- 7. Sect. 2.13. 3 Proposed response should be adequate.
1988 PEA
- 8. J.10.g Proposed response should be adequate.
- 9. J.10.g The proposed response does not consider how the school bus drivers will be made aware of traffic conditions. The traffic management 3
plan which results in the ETE used in the planning efforts is not based on the bus drivers making. their own decisions on the appropriate routes.
- 10. Sect. 2.13. 4 Proposed response should be adequate.
1988 PEA
- 11. J.12 LILCO was aware prior to the exercise that the exercise evaluation methodology did not include any statistical treatment of either scope or expected response. It is not appropriate at this point to attempt to discuss responses on a statistical basis. Otherwise, the response should be adequate.
- 12. K.4 Proposed response should be adequate.
RIVERHEAD STAGING AREA
- 1. J.10.K Proposed response should be adequate.
- 2. J.10.K LILCO was aware prior to the exercise
't at the exercise evaluation methodology did not include any statistical treatment of either scope or expected response. It is not appropriate at this point to attempt to discuss responses on a statistical
S March 13, 1989 Attachment 1 Page 3 of 6 Review of the LILCO Schedule for Correcting Exercise ARCAs and Proposed Plan Review Changes in Response to RAC Review Comments for Rev. 10 of the Plan NUREG-0654 Item No. Supp. 1 Ref. Evaluation of LERO Responses basis. Proposed response should be adequate.
- 3. K.3.b See EOC #4 RECEPTION CENTERS
- 1. J.12 Proposed response should be adequate.
MEDICAL DRILL
- 1. L.1 Proposed response should be adequate.
- 2. L.1 Proposed response should be adequate, assuming that new LOAs, if appropriate,are received from-hospitals where there is an increase in monitoring personnel.
- 3. L.1 Proposed response should be adequate.
REVIEW _OF LERO RESEQHSE_TO RAC/ FEMA REVlEW OF REV.10 OF THE PLAN
- a. A.2.a Proposed response should be adequate.
- b. C.3, I.9 Proposed response should be adequate.
However, if the helicopter contractor is other than " Island Helicopter", a new LOA would also be required.
C.4 As noted in FEMA's review of Rev. 10, a final determination of the adequacy of ambulance resources is to be based on FEMA's review of the computerized Homebound Evacuation listing. This comment was not addresced. Also, see other responses which may require new or modified LOAs. As an additional i reminder, LILCO should note that l several LOAs expire before the proposed date of their next plan revision.
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- M a r c h' 1 3 ,,f19891 1
. Attachment-'1
- Page:4 of 6 Review of the-LILCO. Schedule.for:CorrectingcExercise.ARCAs
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and' Proposed Plan.-Review' Changes.in Response to RAC Review Comments.for Rev.10 of the Plan
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' Item No. S. goo . 1 Ref. Evaluation of LERO Resoonses
- c. E. 5' ;It 'is 'not clear that the - proposed -
response-will"-necessarily yield'more -
concise'. EBS . messages. ?In addition,,
Attachment'S of OPIP 3.8.2 should be reviewed' to make< sure the ' landmark
-descriptions are present for, all
- combinations of :ERPAs_ under LILCO's
. PAR strategy, i.e. , sheltering as well :
as. evacuation.
- d. F.1.b Proposed response should be adequate. 1
" Dept. of. Emergency" should^be Dept. i of Energy. I F .1. b. Submission of LERO directory to' FEMA.
for review 31s addressed in response to changes - for element H. 4. This must-be.
submitted at time of the .next plan 1
revision.
- e. F.1.e Proposed response should be adequate,
- f. G.4.a Proposed response should be adequate.
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- g. G.4.c The adequacy of the numbers cannot be 1 determined until we' examine the-information~ mentioned. This must be:
submitted at the time of the next plan submission.
- h. H.4 Proposed response.should be adequate. I
- 1. I.9 See comments to C.3. .,
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-J.10.a The proposed response'related to-the -i radiological sampling should be.
adequate. :
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March 13, 1989 Attachment 1-Page 5 of 6 Review of the LILCO Schedule for Correcting Exercise ARCAs and-Proposed Plan Review Changes in Response to 1 RAC Review Comments for Rev. 10 of the~ Plan NUREG-0654 Item No. Suco. 1 Ref. Evaluation of LERO Responses
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k+1. J.10.e, The proposed procedural modification j J.10.f should be adequate.. The notification '
of route alert and school bus drivers' by pager is acceptable.
- m. J.10.g Proposed response should be adequate.
J.10.g LILCO should submit the' renegotiated bus yard contracts, mentioned in I FEMA's review of Revision 10 under element J.10.g, which verify the !
numbers of vehicles.
n+o. J.10.g Proposed response should be adequate i
provided that information is submitted with the next plan revision . and it corrects the issues raised in FEMA's review.
- p. J.10.h Proposed response should be adequate. !
As an additional ' note, the list in OPIP 3.6.5, Attachment 5 should be cross-referenced to Section'3.7.1, or OPIP 4.2.3 or OPIP 4.2.2.
- q. J.10.j Proposed response should be adequate.
- r. J.10.j Proposed response should be adequate,
- s. J.10.k Proposed response should be adequate.
- t. J.10.m It is not clear that the proposed revisions adequately address the FEMA comment. Therefore, procedures will j be reviewed when submitted . l
- u. J.11 Proposed response should be adequate.
- v. J.12 Proposed response should be adequate.
W. J.12 Proposed response should be adequate.
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1 March 13, 1989 Attachment 1 j Page 6 of 6 I Review of the LILCO Schedule'for Correcting Exercise ARCAs and Proposed Plan Review Changes in Response.to RAC Review Comments for Rev. 10 of the Plan NUREG-0654 Item No. Suco. 1 Ref. Evaluation of LERO Responses J.12 Also see comments 'concerning the Bellmore reception Center .under {
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- x. K.3.b Proposed response should be adequate.
- y. K.4 This issue was identified for school bus drivers. However, it is a generic issue with all emergency workers and the proposed revisions should address all female emergency workers. See EOC -l ARCA #5. l l
l Z. K.4 While a plan change is important for consistency, during an incident the responders follow procedures. This i clarification should also be included l in the appropriate procedures (OPIPs) . l aa. K.5.b Proposed response should be adequate.
ab. L.1 While a plan change is important for consistency, during an incident the responders follow procedures. This clarification should also be included in the appropriate procedures (OPIPs) .
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' March 13, 1989-Attachment 2 Page 1 of 3 Review of the - LILCO Public 'Information Brochure for the' i General Public in the 10-Mile EPZ.
~A black and white copy'of'the July 28, 1988 version of the public information brochure referenced on page 6 of FEMA's-review of Revision 10 of'the'LILCO plan was reviewed by. FEMA.
FEMA has also recently informally obtained color copies of the:
. cover and pages 1 and 2 of the brochure. These will be sent to FEMA's contractor for review .of the color scheme. In addition, FEMA has also recently informally received a. copy _
of the '1989 ' version of the brochure for Zone A and a complete set of the map inserts to be contained in the brochure for
! Zones ' B-S. FEMA Region- II staff has reviewed the Zone A-brochure .for differences with . the 1988 version and for consistency with Revision-10.of.the plan.
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As 'an initial comment, be' fore finalizing the- public information brochure, LILCO must review its contents against plan changes resulting from' the . revisions .i t p r o p o s e s in response to FEMA's September 9, "1988 review of Revision 10 and the Post-Exercise Assessment of the June 1988 exercise. More specific comments are.below:
- 1. The .information regarding Protective Actions' ( i .' e . ,
sheltering, evacuation, early dismissal of schools, and assistance for persons needing special assistance) are consistent with provisions contained in the plan. While the brochure does not contain specific instructions for handicapped individuals who had not'previously informed' LILCO of their needs via the special mail-in card, the plan, in OPIP 3.8.2, contains- provisions for the announcement of an emergency number in EBS messages so-that these individuals may request assistance at the time of an emergency.
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The brochure describes school relocation' centers and lists the pre-assigned relocation center-for each school in the.
table on.pages 7 and 8. This table lists the Emergency Planning Zone in which the school is located and indicates l those schools that are outside the 10-mile EPZ which serve children who live inside the EPZ. However, to remain consistent with Revision 10 of the plan, a
the Terryville School located in Zone K (see ;
i OPIP 3.6.5, Attachment 3a, page 3 of 6) must be added to the list of schools identified for the Comsewoque Union Free School District. This school was listed in the 1988 version of the brochure.
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Attachment 2
.Page 2 of23.
- 3. FEMA recommends that references on'page~14 of thel'LILCO brochura to' differences between-a nuclear-reactor and a
. bomb'should-specify that it 'is a " nuclear. bomb.". Also,
.the phrase "like a nuclear bomb", should be added to the end of. the - sentence, "A . nuclear . power plant- cannot 4 explode." .
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- 4. The: maps on pages 9-l'2 are legible and clearly marked. .i They are marked "FOR. POSITION ONLY." Assuming-that the- I maps presented in the final version'of the brochure.are of equal or better quality, they are adequate. . These maps are zone-specific and illustrate the following:
Landmarks which delineate the Emergency Planning Zone;~ i a
Evacuation . routes. with arrows Land . detailed l directions that should be followed.to leave the - i area; Location of'the reception center to which the zone is assigned and the . school relocation centers at Nassau .. County Coliseum and' Nassau ;
County Community College; and '
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Bus routes along which ambulatory transit dependent evacuees vill be picked up. for transportation to their reception center. .;
- 5. The LILCO Plan provides for separate public information l brochures to be published and distributed for each of the 19 emergency planning zones in the 10-mile EPZ. They vary with respect to information specifically tail'ored to individuals in each zone, e.g. reception center locations, etc. The brochures for several zones direct the public to the Bellmore reception center. . Recently updated maps to be used on page 11 of each brochure. state that "A New York State court has ruled that, because of local zoning laws, this Reception Center may not be;used without prior ,
approval of the Town of Hempstead. If this. Reception j' Center is needed during an emergency - at the Shoreham Nuclear Power Station, LERO will request the permission of the appropriate official (s) of the Town of Hempstead, -]
Nassau County, or New York State before it is used." Such '
a comment, while addressing the Town of Hempstead's current zoning restrictions on the Bellmore reception- a center, also appears, inappropriately, on the maps for H zones whose population might be directed to the Roslyn and I l
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March 13, 1989 Attachment 2 i Page 3 of 3 Hicksville reception centers._ It should be limited to the maps for zones whose population might be directed to the Bellmore reception center.
Further, it is FEMA's position that while the use, and the representation of this use in public information j materials, of the Bellmore facility has been prohibited j without the prior approval of the Town of Hempstead, the use of the facility and the representation of use may be permissible under the assumptions and provisions of NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1. However, FEMA has ;
identified, on advice of counsel, both items as legal I issues. FEMA defers to the Nuclear Regulatory Commission )
on whether LILCO has adequately accommodated the concerns '
expressed by the Atomic Safety and Licensing Appeal Board in ALAB-905 on this matter.
- 6. A more specific effective date (month and year) should be added to the brochure so that the recipients know whether i they have a current version.
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March 13, 1989 Attachment 3 Page 1 of 2 Review of the LILCO Information Brochure entitled
" Radiological Emeroency Information for- Farmers. Food Processors and Food Distributors." 1989.
As an initial comment, pages 14 and 15 of the September 9, 1988, FEMA review of Revision 10 of the LILCO plan, state that LILCO is not required to submit its agricultural brochure to meet the annual . distribution requirements of . Guidance J Memorandum (GM) IN-1 until 60 days after the final publication '
of the USDA generic agricultural brochure. The deadline for meeting this requirement was extended, for all sites, to 120 ..
days in the attached October 14, 1988 letter.frem Richard W. i Krimm to the Government Affairs Representative for the Maine Yankee Nuclear Power Plant. The USDA generic agricultural.
brochure has not yet been finalized.
I Specific comments are as follows:
- 1. There is a statement under the LILCO logo on the back of )
l the brochure which indicates that the agricultural 1 j brochure will be updated and distributed on an annual l
' basis. The first paragraph of the brochure also explains that the pamphlet has been prepared for appropriate individuals within 50 miles of the plant. If annual distribution is contemplated with the 50-mile EPZ, page 3.8-1 of the plan should be revised to reflect this.
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- 2. In the section entitled "What is Radiation?," cosmic rays are identified incorrectly as being an example of non-lonizing radiation. In addition, it would be helpful to identify " radioactive materials" as a source of ionizing radiation and as contamination. The definition of
" contamination" which is contained in section entitled "What Should be Done If My Fruits and Vegetables are contaminated?", should be included in the "What is Radiation?" section.
- 3. In the section entitled "What Actions Might be Recommended?", the first sentence of the second paragraph should be modified to include " farm products" in the categories for which actions will be recommended within 10 miles of the plant.
- 4. The second paragraph in the introductory section mentions that, " emergency plans have been prepared by the Long Island Lighting Company, as well as Connecticut and New York State, . . . " FEMA has no knowledge that New York State has prepared an ingestion pathway plan for Shoreham.
- 5. A color proof-print copy of the agricultural information brochure should be provided to FEMA in order to determine the final quality of this brochure and to provide
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technical- assistance to LILCO if improvements are needed.
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- 6. A statement should'be included on the. cover encouraging the recipients of the brochure to retain it.
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- 7. A more specific effective date (month and year) should be I added to the brochure so that. recipients will know if they have a current version.
- 8. ~ The. average readability ' of the document is 11th-12th grade, although for some passages the-reading level is y lower. Readability was assessed using the Dale-Chall I formula, with adjustments.made.to_ consider the vocabulary '
familiar to the agricultural community and the repetitious l use of terms such as " contamination" which were defined. l in the booklet. Information about the education level and reading ability of the target population are necessary to determine if the reading level. of the document is appropriate. .
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5 BHOREHAM POST-EXERCISE ASSESSMENT REPORT CLARIFICATION SHEET The following constitute additions and/or corrections to the FEMA Post-Exercise Assessment (PEA) of the June 7-9, 1988 Exercise of the Local Emergency Response Organization (LERO) as specified in the Long Island Lighting Company's (LILCO) Local Off-Site Radiological Emergency Response Plan for Shoreham Nuclear Power
}g Station, dated September 2, 1988.
Page 4 For the homebound ambulance /ambulette patients, six vehicles (ambulances /ambulettes) were deployed and evaluated by FEMA observers; one in Zone A, two in Zone B, two in Zone C and one in Zone E. Please note a typographical error in the chart on page 4, FEMA PEA, regarding MOBILITY IMPAIRED. Zone E listed for evaluator Rhude was actually Zone C, and Zone A listed for evaluator Wang was actually Zone E.
Page 7 FEMA evaluator L. Testa listed on page 7 actually used her maiden name on her evaluator forms and, therefore, should be listed as L. Biliski.
i Page 9 Add Controller M. DiGregory from FEMA as the Control Cell i Liaison at the EOC.
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Page 35 Third line: change " Reception' Centers" to " Relocation Centers".
Page 52 Add the following language after' numbered paragraph 4:
It should be noted, as discussed on page 31, that at the beginning of the exercise on Day 2 (June 8, 1988),
exercise time was restarted from the suspension of the exercise at 1800 on Day 1'(June 7, 1988). Therefore, EBS message #8 discussed above was actually an exercise Day 1 mossage.
Page 98 Second paragraph, line 4 should read: " Activity on Day 2 of the exercise involved simulated transport ...
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.' . i.j 3% Federal Emergency Management Agency
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Y .$ Washington, D.C. 20472 x -
Ms. Ioann Diehl OCT I a 1983 l
Government Affairs Representative Maine Yankee Edison Drive Augusta, ibino 04330
Dear Ms. Diehl:
This responds to your letter of September 2,1988, requesting confirmation of the policy of the Federal Ehergency ibnagement Agency (FEMA) on the public infonnation provisions of Guidance 11emoranda (G1) Itb1 (he Ingestion Exposure Pathway) . Your inquiry regarding the use of the Federal generic ingestion brochure to satisfy the provisions of G1 Itb1 is addressed below.
- Were are three major public information provisions in G1 Itbl in the l' section 6-10: on NUREG-0654/ FEMA-REP-1, Rev.1 planning standard G on pages (1) Distribution of generic, pre-emergency information, .
I (2) distribution of site-specific emergency information and instructions 1 and (3) prescripted to ingestion measures. Emergency Broadcast System instructions pertaining W e third provision is not addressed in this l letter as it is not directly impacted by the issue of the Federally-
. developed generic ingestion brochure.
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- 1. Generic, Pre-Eheraency Infonnation. The Federally-developed ingestion brochure can be used by State and local governments and utilities to meet the GM Ibbl provision for tue annual distribution of generic, ingestion-related information to the public. Bis i distribution should be made within the 10-mile plume exposure pathway emergency planning zone (EPZ) through brochures or other similar materials.
- 2. _ Site-Soecific, nnemency Infomation and Instructions. 'Iko options are provided in G1 Irb1 for meeting the intent of this provision: (1)
- he Federally-developed brochure may be amended by the addition of site-specific information and instructions or (2) separate materials (e.a.,
fact sheets) may be developed for distribution of site-specific ~
information and instructions to designated persons and organizations involved in the fcod chain netwrk during a radiological emergency.
De revision of State and local government and utility offsite plans 1
to incorporate the provisions of G:1 Irb1 should be completed by whicheveror 12/31/88, is 120 days after issuance of the generic ingestion brochure, later. %is time frame will permit sufficient time for distribution of the generic brochure and for development of site-specific informational and instructional materials. Until such time that the generic, Federally-developed brochure is available, w encourage organizations with responsibilities for ingestion measures to proceed with needs.identifying their site-specific emergency information and instruction l
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Any concerns or questions about this. letter should be referred to Bill McIlutt at 202-646-2857.
Sincerely _,
1/]h b'$ k,YY4I jn Richard W. Krimm Assistant Associate Director Office of flatural' and Technological Hazards Programs t
.cc: Mr. George Bickerton,'USDA FEMA ONTH Chiefs g
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EDISON DRIVE . AUGUSTA. MAINE 04330. COD 623 3521
'{l September 2, . 1988 Mr. Vern Wingert
' Emergency Management Specialist ,
Federal Emergency Management Agency l Room 630- .
, ' : j 500 "C" Street, S.W. -
.t Washington, D.C. 20472 i
Dear Mr. Wingert:
n a Maine Yankee is very interested id using the USDA Ingestion ~
Pathway Brochure as its own brochure (to meet. federal guidelines).
We unders'tand Planning at USDA, from George Bickerton, Director of Emergency that the USDA brochure is-now undergoing revisions. When completed, FEMA as meeting the GM.IN-1 requirements.it is expected to be fully approved by- ;
l DecemberWe also 31, understand 1988, that if the USDA brochure is not completed by .
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which nuclear pathway brochure.power plants must have completed their own ingestionFE {
i Could you please send me a letter which confirms this information? ,
l Thank you. -
- Sincerely, 1
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Leann Diehl "
Government Affairs Representative LRD/k1g !
i cc: George Bickerton l
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b MEMORANDUM.FOR: Frank J. Congel Director. d Division of Radiological Protection and Emergency Preparedness-Office of Nuclear Reactor Regulations
,U. S.~. Nuclear Regulatory Commission
.t F,RO lNr Ilmm. ,-
Assistant NdS6dfdde-Director, 1 Office of Natural and. Technological Hazards 1
SUBJECT:
Preliminary Review'of the Shoreham Nuclear' Power
~ Station Alert and Notification System The Federal Emergency Management Agency (FEMA)',has completed the
. preliminary technical review of the Shoreham Nuclear Power Station alert and notification's' stem y (ANS). A' preliminary draft report assessing the adequacy.of the siren coverage provided by
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the Shoreham ANS has been completed and-forwarded-to FEMA Region 1 II for. review. . A' copy'of this preliminary report is enclosed for ;
your information.
J Preparation of'a preliminar l FEMA's ANS review process. . Ify the ANSANS-alerting report is the.first coverage stepis- in determined to be adequate in:the preliminary technical analysis, a telephone survey of households in the_ emergency planning zone is conducted following a~ full' activation of'the ANS-to determine ,
l the percentage of the. population directly' alerted by the system.
After the telephone survey a. final draft report incorporating the results of the survey is prepared for Regional review. Once all FEMA REP-10 requirements.are satisfied, a final report is issued to NRC along with a finding on the adequacy of the ANS. . Since our preliminary technical analysis indicates'that the alerting i coverage provided by the Shoreham ANS is adequate, the telephone survey can now be scheduled. i We are currently waiting for approval from the Office of Management and Budget (OMB) to conduct the four remaining telephone surveys in our alert and notification system review program; however, we expect,OMB approval in the near future and would'like to begin preparing for the Shoreham survey. To assist us in the preparations we would appreciate it if the NRC Li could coordinate with the Long Island Lighting Company to establish a survey.date with the understanding, of course, that any date chosen must be acceptable to FEMA and our technical contractors. Approximately six weeks will be required to draw the sample; therefore, most dates after late January 1989 could be> accommodated for conducting the survey. -
If you need any additional information to assist you in this coordination effort, please call me at 646-2871.
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