ML20155H230
| ML20155H230 | |
| Person / Time | |
|---|---|
| Issue date: | 04/12/1987 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Axelrod D NEW YORK, STATE OF |
| Shared Package | |
| ML20155H227 | List: |
| References | |
| FOIA-88-63, FOIA-88-A-34, RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8810190004 | |
| Download: ML20155H230 (27) | |
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UMTED STATE 8 NUCLEAR REGULATORY COMMISSIO*d
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- 1S87 David Axelrod, M.D. , Chairsan New York State Disaster Preparedness Ccomission Corning Tower, Empire State Plaza Albarty, New York 12237
Dear Dr. Axelrod:
This follows ry December 8,1986 letter to you regarding your November 10, 1986 letter to Chairman Zech recomending that NRC require stren veritication systems as part of prompt public notification in energency planning. As stated in my Cecember 8 letter, we consulted with the Federal Emergency Management Agency including (FEMA) public which has the lead Federal role in offsite emergency planning, notificatien.
FEFA has concluded that the recorrendation for ccquterized feedback verifics-tion systems as part of the alert and notification systems at nuclear power stations has merit. They noted that the verification systems offer the strong advantage of providing offsite officials and the licensee with the capability to instantaneously identify mal func tioning sirens not emitting the proper warning signal, thus enabling the dispatch of backup route alerting personnel in a real emergency to alert the public in the area served by the failed stren.
FEPA believes however, that adequate reliability also can be achieved by systems grams, utilizing rigorous monthly full-cycle testing and verification pro-in their view, a program of monthly full-cycle testing with 100%
verification shouldsystems.
computer verification be sufficient to preclude the necessity of . installing Basically, FEMA receu. ends that the NRC consider either of two approaches for tht testing of alert and notification systems:
implementation of full-cycle alert and notification system tests monthly, with the opcrability of the er.tf re system checked for each test; or d
- i installation of a co@uteriz d verification system as a complerent to the existing stren system, but continuing with the testing program already
{K e 1mplemented.
6.c 7 They further noted that, if these suggested procedures are adopted, appropriate 8g@ revisions to NUREG-0654/FEVA REP-1, Rev.
o u.cr 1. Appendix 3, will be necessary. ;
8Q NRC and FtK4 plan to consider those two options in the presently ongoing review i
l ggd of NUREG-0654/FDM REP 1, Rev.1. This will entail a regulatory analysis, in-m a.m cluding a cost-benefit analysis, cceparing any proposed new guidance to the existing guidance in NUMG-0654 Any proposed revisions to NUREG-0654 and the attendant regulatory analysis will then be subject to public cormnt.
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David Axelrod, M.D. :
If you have any questions, please call Edward Podolak (telephone: 301/492-7290) a of my staf f.
r Sincer?ly, cg ' T -d Sh J.r. '. I3NT James M. Taylor. Director Office of Inspection and Enforcement D I STRI BUTIO*,':
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- l. Issues in OL-3 Remand Proceeding on _ Realism issues (CLI-86-13)
A. Questions posed by Memorandum 6 Order denying Summary Disposition of Legal Authority Contentions 1-2, 4-10 (3 mect), September 17. 1987
. Contention 5 A p gho4 0
- 1. Sirens:
- a. Whether strens will be sounded?
- b. When will sirens be sounded (criteria for protective action decisions)?
- c. By whom would strens be activated?
- 2. EBS Messages:
- a. What system will be used?
- b. How will it be activated?
( c. At whose direction will it be activated'
- d. What messages will be broadcasted?
Contention 6 (Command & Control) , g ds N'
- a. Y.ho will assume charge?
- b. Who will decide when protective actions are required?
- c. What criteria will be used to decide appropriate protective actions?
_C_ontentiens 1 & 2 (Traffic Control) g ,, s/t d# ghe/O
- a. How will traffic be guided?
- b. By Whom will traffic be guided?
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Contention II (Road ImpedimentM $'
- a. How would obstructions be removed?
- b. By whom would they be removed? ,
- c. How will removal coordinate with guiding traffic and selection of alternate evacuation routes?
- d. Who will be in overall charge of "well-planned response?
Contention 7 (incestion Pathway) 3 r.d els.* tb8 M
- a. %culd governrient actions comply with NRC regulations?
- b. Would government actions work at cross purposes with LILCO actions?
Contention,8 (Recovery and Peentry) gh[s b #*
- a. Who will decide proper reentry and recovery procedures?
- b. What standards will be used to evolve proper procedures?
gntention 9 (Dispensing Fuell (not required by regulations] gf,M M
- a. How will this feature function?
- b. Would this feature function?
[how is either question relevant if not required?]
Contention 10 ( Access Co_ntrol) 3 v.M M
- a. What standards would be used to decide exclusion over how wide an areat
- b. What would occur if LILCO was advising different than
, authorities?
< c. How would organizations interact, to what end?
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B. Other Issues from CLI-86-13 Remand on Realism 1 Familiarity of State and County officials with local plan?
- 2. How much delay can be expected in alerting public and making decisions and recommendations on protective actions?
- 3. How about making decisions and recorrmendations on recovery and reentry?
- 4. How about achieving effective access controls?
II. Er orgency Planning Contentions Remanded ([ rther hearing A. Contention 20 (WALK Radio): Remanded by Commission in CLI-87-05 (June 11,1987):
L8LCO intends that ERS messages will be broadcast simultane-
- 7 ously by Y!ALK-AM and FM. (Plan at 3.3-6). Hewever, d / YiALK-AM does not operate at night. Therefore, those persons without FM radios (especially people in cars) will be unable to
( " [g receive adequate information in the event a radiological accident occurs at night, contrary to the requirements of 10 .C.F.R.
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\b i 50.47(b)(5).
This contention was remtved favorably by the Licensing Board in 21 NRC 644, 763-764 (1985). However, WALK radio withdrew from partic-Ipation in the ERS in October 1986. The Commission granted a reopening of the record on this issue, but stated the admission of contentions should await LILCO's providing updated Information on pub!!c notification procedu res. CLl-87-05 at 4. The Commission also directed that the Board condition adr61ssion of new contentions on the extent they assisted in focusing the litigation of earlier admitted issues. Id. at 10.
Subsequently, LILCO filed for Summary Disposition on this conten-tion by providing a new flag station (WPLR-FM in New Haven, Connectl-cut) and substituting two other Connecticut stati.ons for the Long Island
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stations that also withdrew from the EBS. In denying Summary 1
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Disposition on tlyls issue, the Board stated that any new contentions must address the earlier admitted issues, that is , the adequacy of the Plan provisions for radio transmission of ERS messages and activation of tone alert r cc'ios . Memorandum and Order (Ruling on Applicant's Motion of t'ovember 6, 1987 for Summery Disposition of the WALK Radio issue),
December 21. 1987.
P. Centention 25.C (Role Conflict of School Bus Drivers): Remanded by Appeal Board in 23 NRC 135,'T52-154 (1986).
5 The LILCO Plan falls to take into account the role confilet that will be experienced by school bus drivers. in fact, a MIgd i substantial number of school bus drivers are likely to attend to the safety of their own families bofore they report (if they report at all) to perform the bus driving duties which LILCO assumes will be performed. Role confilet of school bus drivers will mean that neither school buses ror school bus drivers will be available to iraplement the LILCO Plan. Without an adequate
( number of buses or bus drivers, LILCO will be Incapable of impferenting the following protective actins:
- 1. early diemissal of schools (necessary under the LILCO Plan to permit school children to be sheltered or to evacuate with their parents);
- 2. evacuation of schools;
- 3. evacuation of persons without access to cars; and, 4 evacuation of persons in special facilltles, in rejecting Summary Disposition of this remanded contention, the Licensing Board ' stated the arrangements made by LlLCO for providing auxillarv bus delvers recruited from its own employees does not require the submission of new conte. tions, but the Intervenors must have an opportunity to confront this new plan. Memorandum and Order (Ruling
. on Applicant's Mollon of October 22, 1987 for Summary Disposition of Contention 25.C Role Conflict of School Bus Drivers), December 30, 1987.
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An additional matter is the issue of the evallability of buses, an issue the Licensing Board found as a deficiency in the PID (21 NRC at 874). LILCO's arrangements for securing an adequate number of buses to evacuate school children in one wave may also be heard in the centext of the proceeding regarding bus drivers. Board Order of December 30, 1987 at 6.
C. Contention 72 (Evacuation of Hospitals): Remanded by Appeal Board in A' LAB-832, 23 NRC'U5,154-157 (1986), affirmed by Commission in CLl-87-12 (November 5,1987).
P g' y ,A 'dW The LlLCO Plan proposes to evacuate all hospitals, nursing k,l homes and other special health care facilities in the EPZ, using buses, ambulances, and ambulettes. leites to Plan omitted).
(" , This aspect of the Plan cannot be implemented; accordingly, g
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people in special facilities will not be adequately protected in the event of an emergency and the LILCO Plan falls to comply with 10 C.F.R. 5 50.47(a)(1),(b)(3, 8 r,10) for the following
( reasons: ,
72.A. Assuming the necessary~ vehicles were available to '
LILCO and were mobilized, the time necessary, following mobilization, to accortplish the proposed evacuation of special facilities will be too long to provide adequate l protection frem health threatening radiation doses.
' Evacuation will take too long as a result of: the large number of trips necessary to transport persons individually to relocation centers;the other mobilization of evacuation traffic congestien which the evacuation vehicles will encounter; and the time necessary to load and unload passengers from ambulances. [ cites omitted]
72.C. The Plan falls to identify any relocation or recep-tion. centers for persons evacuated from any hospitals, r,ursing homes, or other special health care facilities other >
, than the United Cerebral Palsy of Greater Suffolk inc.
The LILCO Plans recognizes that under certain
- 72. D. i circumstances the evacuation of John T. Mather Memorial, St. Charles and Central Suffolk Hospitals might be necessary, and that LILCO may recommend such an evacuation. (cites to Plan omitted.) flowever, the Plan falls to specify adequately or accurately the circumstances that would necessitate an evacuation of the hospitals, and does not Irelude adequate procedures to permit the person i
( in command and control to make an accurate determination
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as to whether or not such an evacuation is needed. [ cites omitted. ]
72 E. Instead of planning to provide adequate protection to hospital patients in the event of such an ev" . ation, the LILCO Plan simply provides that "LERO w'o evacuate these facilities using an ad hoc expansion of in nsportation resources that are presently committed to other aspects of evacuation." (cites to plan omitted.] Apparent y, this ad hoc plan will not be developed until an emerger ey actually occurs. [ cites to plan omitted. ) The ad he plan will ,
utilize vehicles assigned to implement the evacuation of I other segments of the population, but such vehicles will be supplied for the purpose of evacuating hospitals patients only "on an as available basis," and only "as the rest of the affected population evacuation nears completion. [ cites i to plan omitted. ) Thus, there is no assurance that adequate protective measures could or would be taken for ,
hospital patients and LILCO has thus falled to satisfy the requirements of 10 C.F.R. 55 50.47(a)(1) and 50.47 ( b) (10) .
LILCO has filed for Summary Disposition on this matter, (Lilco's Motion 'or Summary Disposition of the Hospital Evacuation issue,- '
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Decemtser 18, 1967) and it is currently pending before the Licensing Rot rd.
Ill. Emergency Planning Exercise Contentions (pending Licensing Board _
decision) t
, A. Groupings of Contentions:
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g 1. Scope / sampling contentions: FX 15,16, 21 N 2. Field Worker Contentions: EX 34, 40.a,b, 41
- 3. Rad Health / Monitoring Contentions: EX 22.a. 36, 47, 49 (except c) '
4 Public Information Contentions: EX 38, 39, 40.c, a9.c
- 5. Training Contention: EX 50 i
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B. Specifically:
Contentions 15 & 16 allege exerciso didn't include evaluation or demonstration of major portions of plan or of capabilities of many persons and entitles relled upon for implementation. ,
Contention 19 alleges FEMA's inability to make reasonable assurance finding reveals a fundamental flaw in plan. (Admit ted for legal argument i
only)
Contention 21 alleges FEMA used insufficient data to conclude exercise objectives were met (size of sample Insufficient).
Contention 22.a alleges Nassau Coliseum not available (moot issue).
C ntention 34 alleges response of route-alerting personnel (in event l of stren failure) was slow.
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Contention 36 alleges performance error, in conduct of exercise.-
1 (inappropriate protective action recommendations were made in response to wind shift of plume in exercise scenarlo)
Contention 38 alleges incompetent performance regarding emergency i news center operations (public information issue).
Contention 39 alteces incompetent performance regarding rumor
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cor: trol at ENC. l Contentien 40 alleges errors by field workers in exercise of plan.
1 (Mobillration of Traffic Culdes)
Contention 41 deals with traffic impediments and errors in j responding to same by fletd workers.
Contention 47 deals with decontamination of special populations.
(Registration and monitoring of evacuees from special facilities) .
] g Contention 49 alleges LILCO is incapable of performing registration and monitoring of evacuees with 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
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( Contention 50 alleges mistakes evident during exercise demonstrate !
an inadequate training prograri which is fundamental flaw in plan. ,
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DRQT Task Action Plan for Evaluation of Long Island lighting Company's Recuest to Operate the Shoreham Nuclear Power Station at 25% Power Lead Organization: Division of Reactor Projects I/II. NRR [
Task Manager: Ronnie lo kz' '
Project Completion Date: July 8, 1987
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ACTION PLAN I. INTRODUCTION The Long Island Lichtira Company (LILCO) has filed a Motion before the Comission on April 14, 1987, reovesting authorization to operate the Shoreham Station at pcwer levels above 5% and up to 25% of full power. In anticipation of a Comission request for a staff review of the Motion and its associated bases, we have prepared this action plan for accomplishing an expeditious review.
l The three major elements of this action plan are a description of the relevant l l background infemation, a description of the review program and a sumary of the required staff resources with the corresponding schedules and milestones.
The section on background infomation will include surraries on plant status, hearings status and licensing status. The section on our review program will describe the scope of the staff's review of the propotal. It will identify the nature of the various elements of the staff's review effort. The final sectier of this action plan will provide estimates for the(resource requirements in each of the techr' cal review branches that will be participating in this review effort, along with the corresponding schedules and milestones es indicated i in a bar-chart. The chart will also identify'the interfaces between the various reviewing organizations.
A. PLANT STATUS The Shoreham Station is currectly in cold shutdown. All the start-up tests i that can be accomplished with a 5% power license, including synchronization of the main generatnr with the off-site grid, have been completed. LILCO has taken advantage of the protracted period of plant shutdown and has ,
accomplished a nurber of plant enhancements, including those called for l in the ATWS rule. The plant is ready for operations at power lev 31s above 5% of full power.
B. HEARINF$
i STATUS
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Public hearings on all issues but those dealing with selected areas of the emergency plan have been completed with decisions rendered in favor of LILCO.
There are currently two licensing Boards scheduled to hold hearings during mueb of 1987 on the remainino issues relating to the emergency plan. These hearings are not likely to be completed for at least several months.
C. LICENSING STATUS LILCO has an application for a full power license which is currently pending before the Comission. Under authority delegated to it by the Comission, The Office of Nuclear Reactor Regulation has issued first a license author-izing fuel leading and criticality testing (.001% power) and later a license authorizing operations up to a power level of 5% of full power. The 5%
license is currently in effect.
l The staff's licensino reviews have been completed for all issues that require resolution prior to authorizing operations above 5% of full power, except for a selected number of issues dealing with the emergency plan, which are currently under litigation before two licensing Boards. In addition, a finding by the Regional Administrator, that the Shoreham Station is ready for operations above Si of full power is also pending.
II. Description of Problem The LILCO request to operate Shorehan at 25% power is based on the provisions of 10 CFR 50.47(c)(1) which states that if the emergency planning standards ,
set forth in 10 CFR 50.47(b) are not met, the applicant would still have an opportunity to demonstrate to the satisfaction of the Comission that:
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- 1) deficiencies in the [ emergency] plans are not significant 'or the Shoreham i Station; .
?) adequate interim corpensating measures have been or will be taken promptly; or ,
- 3) there are other compelling reasons to permit plant operation. .
LILCO clains that all three eierents of 10 CFR 47(c)(1) are satisfactorily demonstrated by the analysis contained in its request.
in order for the Comission to consider the LILCO request, an evaluation by < l the staff is necessar under 10 CFP 50.47(c)y (1). to examine The probebilities, the technical merits ofand the severities LILCO's assertiens the durations ,
of accident development for 25% power are significantly different from those associated with accidents that could occur during full power operation. The ,
staff's evaluation should show if the conditions for operating Shoreham at .
25 power are such that in the event of an accident involving offsite releases. l the demands on the EP are significartly reduced in comparison with operation {, !
at 100% power. The evaluation should determine if offsite protective measures, . '
when recessary, can be implenented with levels of adequacy equal to or exceeding i I those at operating reactors with an approved EP to cope with accidents for operation at 100% power. The staff evaluation and recomendation for Comission l action will be sumarized in a report to the Commission. '
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l t, !!!. Scope of Review Program f The staff actions to evaluate the LILCO request are divided into five subtasks
- as follows
A. Subtask 1 - Accident Assessment for Shoreham Operating at 25% Power l%
An accident assessment will be performed to evaluate the following: s; I
(i) The proba'bilities', relative to the Shoreham PRA analyzed for ,'
J full power operation, of accident sequerces that would require .
offsite protective measures to be taken.
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i (ii) For each o' those accidant secuences evaluated in (i), evaluate the dose (wtnle4cdy, thyroid) prcfiles as a furction of distance.
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3-Compare the dose profiles against NUPEG-0396 ose-probability vs.
distance calculations for the entrespondingfaccident sequences, i.e.
DBA, most core-melt sequences and the worsef core-melt sequences.
(11 0 The NUREG-0396 probabilistic dose consequence vs distance calcu-lations provide for the guidance to establish the general 10-mile EPZ for full power operation. Based on the evaluation in (i) and (ii) teove, evaluate the corresponding offsite distances within which protective measures should still be necessary in the event of an accident during 25% power operation.
(vi) Evaluate the tire element in accident development and release scenarios. Correspondire to each release category, evaluate the probabilities for the need of quick offsite response (less than 2 hrs.), extendad response (5-10 hrs.1 and delayed response (preater than 24 hrs.).
The staff has perfomed a review of the Shorehan PRA for 100% power.
This subtask corsists of applying the peraneters unique to the LILCO request in the accident evaluation. Some of the key input considera-tions are: (1) Those effects arising from the 25% power linitation in comparison with 100f power: 1.e. ,; reduced fission product inventory; reduced demands on the safety systems; increased time 1
available for actions to miticate the accident; and the availability of main condenser as heat sink with full turbine bypass for ATWS events; and (2) Those factors related to physical and procedural changes that were not considered in the 100% power PRA; e.g.,
additional on site AC power which significantly precludes station black-out acciderts; improved Standby Liquid Control s which is equivalent to about 700% of the 10 CFR 50.62(ystem capability c)(4) require-ment for mitigation of ATWS events; Autenatic Depressurization System improvement for accident control; alternate HPCI water source,(.from Condensate Storage Tank) to provide redurdant water sources; procedural change to lower reactor water level setpoint for MSIV closure ~ to i reduce challenges to the SRV and demands on suppression' pool.
B. Subtask 2 - Assesseert of Offsite Protective Feasures Necessary for Shoreham Operating at 25% Power.
4 An assessment will be perfonned to evaluate the scope of offsite protective measures still required and the adequacy of LlLCO's plan. The assessment will censist of the following elements: ,, ,
(1) A preliminary'revie6 of the inadequacies of the LILCO's plan as identified by FEMA for full power operation.
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(ii) Assess the significance of those FEMA identified inadequacies in the event of an accident during 25% that would require offsite protective measures. Key elenents for censideration are the results of Subtask
! I assessment pertatrino to: (a) Selection of accident sequences i i
that would result in offsite doses recuiring protective ressures j (i.e. above PAG dose levels); (b) The size of ares and repulation j i
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involved; (c) The evacuation distances to travel to reach areas where PAG dose levels will not be exceeded; (d) The Comission in CLI-86-13 has determined that an ad hoc participetion of State and i Local governments will occur in the event of an accident at Shoreham. ;
The tire elements in accident development and release scenarios evaluated in Subtask (1)(iv) is en important consideration in evalu-ating the adequacies of preparation fer those ad hoc responses.
C. Subt::;k 3 - Safety Implications of Prolonged Operation at 25% Power A review will be perforr:ed to examine the equipment and operational characteristics of protracted off-normal operation of the Shoreham
. plant at 25% power that may have safety implications. Examples of areas of review include the stability of recirculatien system, feedwater system and control systems; increases in manual modes of operation and demands 'c on operator attention. If the review identifies any items of safety ,> d'. jAf sionificance, that information will be used as inputs tn the Subtask 1 "d aciident probability evaluation effort. "/
.. ~ 7-f D. Subtask 4 - Assessment of NRC Regulations Applicable to LILCO's Reouest to Operate Shoreham at 25% Power.
[
! This assessment will provide the legal frare work for the staff's recom-mendation to the Comission on the request. The assessment will provide the staff with guidance on the following issues:
(i) if the staff's technical evaluation results in a recemendation to grant the LILCO request, is granting the request an action on the pending application for full power operation with the 25% power operation being an interin condition of the full power operation or is the action an amend-ment to the existing license authorizing operations below 5% power? !
/ . s (ii) If LILCO demonstrates satisf actorily to the Comissinn under the tb provisions of 10 CFR 50.47(cM1), is that the applicable regulation for the Comission to grant the request and issue a license to operate up to 255 power?
Iiii) FEMA has a role to provide the NRC with a findirg on the adequacy of the LILCO plan for full power operation. For this case of LILCO's l request to operate at 251 powe*, could the staff, by their evaluation, n'.""4 detemine if the inadequacies identified by FEMA will become insignificant " . ,
issues with the 25% power linitation and other safety enhancerents not previously considered in the full power licensing review?
E. Subtask 5 - Review of other Compelling Peasons for granting the Motion to Operate Shorehen at 25% power.
This review will enable the staff to make a recomendation to the Comission if there are other corpelling reasons under 50.47(c)(1) that the LILCO's reauest should be granted. The review will examine the rerits of operating i
Shoreham at 251 power because of the need for power in the LILCO service area and the dependence on foreign oil in LILCO's generating facilities.
The staff will solicit the inputs from DOE which has recently addressed similar issues on a request by the Department of Comerce for a petition by LILCO on an unrelated subject.
IV. Principal NRC Staff Organizations involved A. Project Directorate I-2 Division of Reactor Proiects I/11. Has overall lead responsibility in mareging the task and coordinating the staff efforts in the evaluation as well as inputs from other agencies, e.g., DOE, if needed. Results of the staf f evaluation will be sumarized in a report to the Commission, Manpower Estimate: 0.2 man-year FY 1987 l
B. Risk Application Branch, Division of Radiation Protection and Emergency Preparedness. Has the responsibility of performing accident and risk assessment reviews as discussed in Subtask 1.
Manpower Estimate: 0.3 man-yetr FY 1987 C. Emergency Preparedness Branch, Division of Radiation Protection and Emergency Preparedness. Has the responsibility of perfoming an assessment of the scope of offsite protective reasures required and the adequacy of LILCO's plan. The elements of this assessment is discussed in Subtask P.
4 Manpower Estimate: 0.2 man-year FY 1987 D. Reactor Systems Branch, Division of Engineering and Systen Tech-nology. Has the responsibility of exanining any safety implications of prolonged operation at 25% power as discussed in Subtask 3; Manpower Estimate: 0.1 r.an-year FY 1987 -
E. Electrical Systems Branch, Division of Engineering and System Tech-i nology, Has the respersibility for evaluating reliability of en-site i energency power system taking into account availability of the TDI diesels, the Colt diesels, the EMD diesels and the gas turbines.
Manpower Estinate: 0.1 man year FY 1987 .
l F. Division of Reactor Projects. Region 1. Has the responsibility of ;
- evaluating the licensee and its facility for readiness to operate at 25% power.
l Manpower Estir. ate: 0.1 man-year FY 1987 G. Reactor Licensing Branch Office of the General Counsel. Has the responsibility to provide quidance to the sta'f on regulatory and legal issues related to LILCO's reouest. 1 I
Parp:*er Estirate: 0.15 ran year FY 1987 j l
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A (1 Issue Task Action Plan (2 Request DOE for subtask 5 input Receive DOE input Start draft report Corplete draf t report (6 Receive cements on draft report (7 Start final report (S Comolete final report (9 NRR approved final report B (1) Start subtask 1 Input progress to EPB ,.
(2 Input from RSB on subtask 3 (3 Complete conclusions to EPB (4 Complete draft subtask 1 (5 Review draft report complete C (1) Start subtask 2 Rereive progress from RAB (2)Completesubtask? inputs .
(3) Review draft report complete D(1)Startsubtask3
(?) Input priliminary result to RAB :
(3)Completesubtask3reportinputs (4) Review draft report cceplete E (1) Start plant readiness review (2) Plant readiness review complete (3) Review draft repert complete l F (1 Infonn Comission of Action Plan (2 Inputs to draft report complete (3 Review draft report complete l
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- This is the optimistic estimate assuming minimum need for iterative reviews.
Other NRR Technical Branches whose inputs are needed for systen and procedural verifications will be identified later.
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.q WEDNESDAY THURSDAY FRIDAY SATURDAY p =- ___
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MANAGEMENT BRIEFING LILCO'S . ..
MOTION AND REQUEST ,
FOR AUTHORIZATION T0 OPERATE SHOREHAM AT UP TO 25% OF FULL POWER t
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PROJECT MANAGER PROJECT DIRECTORATE l-2 I
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CHRONOLOGY d
APRIL 14 LILC0 FILES REQUEST BEFORE THE COMMISSION ,
APRIL 29 OGC/ STAFF RESPONSE BEFORE THE COMMISSION LILC0'S MOTION FOR EXPEDITED REVlEW SHOULD BE GRANTED STAFF iS DEVE!0 PING A WORK SCOPE AND SCHEDULE '
THE STAFF WILL ESTABLISH THE SCHEDULE BY MAY 15, 1987 AND REPORT TO THE COMMISSION APRIL 30 NRR TECHNICAL STAFF MEETING WITH LILCO ON PLANT SYSTEMS FOR 25% POWER OPERATION MAY 12, AND 13 NRR TECHNICAL STAFF AND CONSULTANTS MEETING WITH LILCO
_ ON ACCIDENT ANALYSES FOR 25% POWER
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MAY 15 STAFF REVIEW ACTION PLAN FINAllZED l
MAY 15 OGC/ STAFF RESPONSE TO INTERVENOR'S MOTION FOR COMMISSION !
4 TO ORDER A HALT TO STAFF'S TECHNICAL REVIEW )
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10 CFR 50,47 (C)(jj, APPLICANT WILL HAVE OPPORTUNITY TO DEMONSTRATE TO THE SATISFACTION OF THE COMMISSION THAT:
P DEFICIENCIES IN THE EMERGENCY PLAN ARE NOT SIGNIFICANT FOR l L
THE PLANT IN QUESTION E .
ADE0VATE INTERIM COMPENSATING ACTIONS HAVE BEEN OR WILL BE TAKEN E THERE ARE OTHER COMPELLING REASONS TO PERMIT PLANT OPERATION a N-~ '
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, LILCO'S POINTS TO SUPPORT RE0 VEST COPPENSATING ACTIONS:
, 25% POWER LIMITATION PLANT IMPROVEMENTS i
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! INSIGNIFICANCE OF DEFICIENCIES IN THE CASE OF SHOREHAM W
COMMISSION (CLI-86-13) PRESUMES THE GOVERNMENTS TO RESPOND WITH "BEST EFFORTS" f ,
REDlJCED DEMANDS AND CHALLENGES TO EP W
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THE STAFF'S REVIEW PLAN FOR SHOREHAM REVIEW PLANT SYSTEMS AND OPERATING PROCEDllRE FOR PROLONGED OPERATION AT 25% POWER l SAFETY ASSESSMENT
! EVALUATE EMERGENCY PLANNING i
! READINESS REVIEW
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DOE INPUT FOR NEED FOR POWER AND FOREIGN O!L F
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PPINCIPAL TECHNICAL STAFF GROUPS: -
P! VISION OF PROJECTS I/II AND REGION I DIVISION OF ENGINEERING AND SYSTEM TECHNOLOGY DIVISION OF RADIATION PROTECTION AND EMERGENCY PREPAREDNESS INEL, ORNL, BATTELE-COLUMBUS -
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, / 'o UNITED STATES 8 ~ ,%
NUCLE AR REGULATORY COMMISSION
. I WASHINGTON. o. C. 20555 l.'e May 15, 1987 Mr. Samuel J. Chilk, Secretary
- U.S. Nuclear Regulatory Commission Washington, DC 20555 In the Matter of Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3
Dear Mr. Chilh:
In the "NRC-, Staff Response to LILCO Motion for Expedited Commission Consideration of Request to Authorize Operation of Shoreham at 25% of Full Power " the Staff stated it would supply the Commisrton with a scheculo for review of the LILCO Request by May 15, 1987. I l
attach that schedulo hereto.
Sincerely.
M Edwin J. )t is Deputy Assistant Gent 'al Counsel
Enclosure:
As stated cc w/ encl.: Sersice List i l l l
F o G rf-6 3 gwt'e-3D ,
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EEI_{pDtENTS OF A_CTION PLAN i
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REVIEW PLANT SYSTEMS AND OPERATING PROCEDURES FOR PROLONGED '
OPERATION AT 25% POWER 1
1 SAFETY ASSESSMENT l
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, EVALUATE EMERGENCY PLANNING L
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- i REVIEW OTHER COMPELLING REASONS l
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j REVIFW SCHEDULE FOR 1987 l
.l f LILCO FILING APRIL 14
- ISSUE ACTION PLAN MID-MAY t l
MEETINGS WITil LILCO APRIL 30 AND MAY 12-13 !
J PREPARE DRAFT SER JU!E t 3
ISSUE FINAL SER JULY l l
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I U.S. Nuclear Regulatory Commission
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3 Long Islan6 Lighting company
.l (Shoreham Nuclear Power Station)
NRC Docket 50-322-0L Gentlemen:
As you know, LILCO has submitted Revision 9 to the Shoreham l N7.0 on January 22.
of f site Radiological Emergency P l an to the ;
Copies were simaltaneously provided to all parties to the LILCO accord-i Shoreham proceeding and to TEMA at the same time.
! ' ingly requests that the NRC officially request FEMA to conduct an LILC0 also renews its request
' expedited review of Revision 9.
that the NRC promptly transmit its outstanding request for an
! for the Shoreham plant to exercise, dated December 18, 1987,1
> r r.M A . A copy of that request is attached.
This letter also responds briefly to Mr. Lanpher's letter of the NRC December 30, which suggests, in various forms, that Most of his refuse to transait LILCO's exercise request to FEMA. l arguments are actually directed to FEMA rather than to the NRC.
1/ Letter, John D. Leonard (LILCO) to the Commission, t
5ecember 18, 1987 (SNRC-1406).
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( M t x T ox & Wr t.I.t A.x s U.S. Nuclear Regulatory Commission January 27, 1988 Page 2 Givon, however, that periodic exercises are a requirement under both NRC and FEMA regulations for issuance or retention of a full power license, he is in effect requesting that the NRC summarily terminate the shoreham docket. This would be such a flagrait denial of due process to LILCO that it does not merit further discussion.
His other suggestion, that the state and local governments which have intervened in this proceeding be allowed to partici-pate in the process of exercise development, must be discussed in some detail. LILCO has always sought legitimate governmental participation in offsite emergency planning and preparedness for
( Shoreham, and still would welcome it at any time. If any of these governmental units wish to join in protecting their citi-sens by participating in emergency planning for Shoreham --
including proper assurances of good f aith participation in the exercise itself -- LILC0 would welcome their participation in the l l exercise planning process. l 1
Mowever, the role of these governmental units appears to i remain that of opposing LILCO at every turn in the federal pro-cess as well as of using and occasionally abusing their powers under state law.1/ Unless the policies of these governmental 1
1 2/ For instance, Suffolk County went so far in opposing the l T986 exercise as to enact a criminal ordinance which would have )
subjected anyone participating in the exercise to a year of '
imprisonnent and a fine of $1000. That ordinance, which was obviously designed to chill preparation for the exercise as well i as participation in it, was declarid unconstitutionsi by the l United States District Court. Long Island Lichting Co. v. Countv l of suffolk, 628 r. Supp. 654 ( E ~. D . N . Y . 1985). l l
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