ML20077P093
| ML20077P093 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/07/1983 |
| From: | Brown H KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20077P097 | List: |
| References | |
| ISSUANCES-OL-3, NUDOCS 8309130295 | |
| Download: ML20077P093 (21) | |
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-00CKETED UNITED STATES-OF' AMERICA
. NUCLEAR REGULATORY' COMMISSION Before the Atomic Safety and'Licensin B
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'In the-Matter of
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.LONG ISLAND LIGHTING COMPANY'
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oreham Nuclear Power Station' r
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SUFFOLK COUNTY MOTION TO COMPEL DISCOVERY On August 23, 1983, Suffolk County filed notices of d'eposition-for'RichardIKrimm, Jeffrey Bragg, and Gary. Johnson.
4
'The' depositions were' noticed for September 21 and 22.
Each of
-these gentlemen is employed-by the: Federal Emergency Management
~
T Agency :(" FEMA") ~ and has been identified in discovery responses i
as-having reviewed the.LILCO Transition Plan.
Although no motion for a protective order has;been filed by FEMA, the County's counsel have been informed by-FEMA's regional counsel-i that'.these gentlemen.will not-appear voluntarily.: -See Exhibit 1.
Accordingly,'.the County is. required to file the instant motion.
t
-Relevance.
There can b'e no dispute that,the depositions
^
seek relevant data.- FEMA exercises the principal role in NRC proceedingr L :encarning review and' approval of offsite emergency
" response plans.' : See 10 CFR 550.47 (a) (2).
FEMA's role in the
. instant proceeding may be.even more important than in other cases,
'since FEMA.for: the first time is assessing the adequacy of a t
i 9
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. s; 2-rutility offsite plan.
That LILCO plan does not have governmental support.
In'the) instant. case, it is essential'to depose.each of
~
the noted' FEMA reviewers.' Messrs. Krimm, Bragg and Johnson
.have'each participated personally in the FEMA review of the JLILCO Transition Plan.: See Exhibit.2, p. 2.
Further, it was
'Mr. Krimm who transmitted FEMA's June 23 " Findings'" to the NRC.-
~
See Exhibit 3.
It:was Mr..Bragg to whom Mr. Dircks of the
-NRC-Staff directed inquiries to clarify FEMA's June 23 Findings,
- and~Mr. Bragg responded in a letter dated. August 29, 1983.
r I
See Exhibits 4 and 5.
.Mr.: Johnson was one of the FEMA persons involved in FEMA's use of Argonne National Laboratory to review
'the LILCO Transition Plan.-
See Exhibit 6, pp. 3-4.
- Finally, it.is'the county's' understanding that each of these gentlemen has played a central roleLin determining how FEMA would conduct L
lits' review'of the-LILCO Transition Plan -- a review which has not.followed FEMA's normal "350," process.
See Exhibit 3.
FEMA Objection.
FEMA takes-the position that Messrs.
I
)KrimE, Bragg and Johnson do not need to be produced for deposi-tion ~ because they are protected by 10 CFR S2.720 (h) (2) (i).
That regulation provides that "the Commissioners and named NRC
'l,
- personnel".cannot be forced to be deposed absent a showibg of
" exceptional circumstances."
-(emphasis supplied).
FEMA's
/.
counsel states that these FEMA personnel "are entitled to the same protection as provided NRC personnel as stated in 10 CFR l
2.720 (h) (2) (i). "
Exhibit 1.
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There is no: legal basis for this FEMA objection.
The regulation protects " named.NRC personnel" from deposition.
Messrs. Krimm, Bragg and Johnson are not "NRC perconnel" or.
consultants retained by the NRC.b! FEMA is an independent agency -- not a part.of the NRC -- which is performing emergency-planning review functions pursuant to an inter-agency Memorandum of Understanding.
See 45 Fed. Reg. 82713.
FEMA has agreed to
' review offsite emergency response plans and to "make expert witnesses available.
Memorandum of Understanding, SIII.A.
There is obviously nothing in the Memorandum of Understanding, however, or in the NRC rules which can be said to transform FEMA personnel into NRC personnel-for discovery purposes or anything else.
Similarly, there is nothing in
~
the Memorandum or the NRC's rules that " entitles" FEMA personnel to the protection of Section 2.720 (h) (2) (i).
Accordingly, there -is no basis for FEMA to assert that 10 CFR S2.720 (h) (2) (i) applies to the FEMA personnel whose depositions have been noticed.
L From-oral discussions with FEMA counsel, the County under-stands that FEMA is concerned about the potential burden which t-l might-be experienced if persons such as Messrs. Krimm, Bragg and Johnson were to be deposed.2[ FEMA apparently fears that l'
l' 1/'Section 2.720 (h) (2) (1) also protects the Staff's consultants i
from deposition.
See 10.CFR Part 2, Appendix A, SIV (d).
l2/ Mr.~Krimm is an Assistant Associate Director of FEMA.
Mr.
Bragg'is FEMA's Executive Deputy Director.
Mr. Johnson is a
~
. FEMA Executive Officer in the Office of Natural and Techno-logical Hazards Programs..
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iffit produces these persons in the Shoreham proceeding, it 7
-might be forced to produce them in other cases as well, resulting in these persons being unable to perform their normal work.
The Board should' reject this " reason."
Whatever may be a Licensing Board's ruling in another. case', the. fact is that
.these three FEMA. employees.have been centrally-involved as reviewers in this= case.
The Board is not facing a " fishing" expedition here, but is instead being asked by FEMA to shield from inquiry the very persons who hold personal knowledge which
~is essential to the County's preparation of its case.3/
FEMA also takes.the position that'it is sufficient for the County.to depose only those persons whom FEMA will be pro-viding to testify at-trial -- Messrs. Tanzman (of Argonne
' National Laboratory), Kowieski '(of the FEMA Region II office),
and Sharrocks. (of FEMA's Washington, D.C. office).
The County L oes intend.to depose these; proposed FEMA witnesses (their d
depositions are scheduled for September 12 and 13) because they are important reviewers of the.LILCO plan, just as are Messrs.
-Krimm, Bragg and Johnson.
This is no substitute for deposing any of these persons.1/'
so 3/ The County notes that it expects.the depositions to be rela-
.tively short -- a best estimate of a half day for each person.
This ic hardly a great burden given the'significant personal frole the FEMA employees'had in reviewing LILCO's plan and the hardships.which the County would experience in being denied access to the information these persons possess.
4/ The need to depose Messrs. Krimm and Bragg is particularly great since only Mr. Krimm can state with authority what he meant-in the June 23 FEMA Memorandum (Exhibit 3 hereto) and only Mr.
-Bragg.can' state-his reasons and intentions regarding his response to:Mr. Dircks'_-letter (Exhibits 4 and 5 hereto).
_a__._-.__.,..___.
For1the foregoing reasons, Suffolk County respectfully moves this Board to grant the instant motion.
Respectfully submitted, David J. Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 ub $
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Herbert H. Brown
/
Lawrence Coe Lanpher Karla J. Letsche KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS 1900 M Street,'N.W., Suite 800 Washington, D.C.
20036 September 7, 1983 Attorneys for Suffolk County l
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EXHIBIT 1
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Federal Emergency Management Agency u
A
~ Region II '
26 Federal Plaza New York, New Yofk 10278
.8 SEP W3 Karla J. Istsde, Esq.
Kirkpatrick, Iockhart, Hill Christopher & Fnillips 1900 M. Street, N.W.
Washington, D.C. 20036
~
Dear Ms. la' ache:
We are in receipt of your Notice of Deposition for Richard Krim, Jeffrey Bragg and Gary Johnson. As you discussed with Bernie 3crdenick on Aug 23th and as reiterated in our conference call on Tuesday, August 30th we are of the positlen that we have ccxuplisivith the re-quia..urnt.s of 2.720 (h) (2) (i).
4 As you are aware, the FEMP. witnesses. are appaarig before the ASLB pursuant to the terms of the NRC/EDR Menorands of Understandig.
We have already agreed to make our witnesses Boger Ecwleski, Edward Tanzman and Frederick Sharrocks av=41ahie for deposition on Segtember 12th and 13th..
The additional individuals that you have requested to W.
Jeffrey Bragg, Executive DrAv Director;. Richard Krim, -Assistant Associate Director; and Gary Johnson, Executive officer are entitled to the same prot.ection as provided NRC P wel as stated in 10 un 2.720 (h) (2) (i). We therefore res e dally decline to produce these
==+=-s of our agency's senior executive staff.
Very truly yours, k
j, Stewart M. Glass Regional Counsel i:
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EXHIBIT 2 g u.
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UNITED STATES
. NUCLEAR REGULATORY COMMISSION
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. August 5,1983 John E. Birkenheier, Esq.
~ Kirkpatrick, Lockhart, Hill Christopher & Phillips 11900 M Street, N.W.
. ashington, D.C.
20036 W
In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
' Docket No. 50-322 (Emergency Planning)
Dear Mr.' Birkenheier:
This is in reply to your letters of July 27, 1983, and August 2, 1983, which enclosed a list of sixteen infonnal~ discovery requests to the Staff.* Set out below are the Staff's responses to your:infonnal requests which have been
-provided to me. As to the first eight requests, with,the exception of items 5_ and 6/I-gave you these responses over the telephone.on July 29, 1983.
I.
gave you most of item 5 on August 3,~ 1983.
I gave verbal responses to items 9-16 to you by telephone on August.3,:1983.
- 1. -
The Staff presently expects to call the following named persons as witnesses during the Shoreham emergency planning hearings.
' Witness Subject matter John R. Searc-Onsite emergency preparedness as it interfaces with offsite planners Thomas Urbanik, II Evacuation Time Estimate Analysis-In order to expedite this proceeding and to continue the long standing
. spirit of cooperation between the Staff and Suffolk County with. respect to discovery matters, the Staff agrees to treat the County letters as informal discovery requests. The Staff's voluntary response to the County's requests should not, however, be construed as a Staff acknowledgement that the County discovery requests in any way comply-with the provisions of 10 C.F.R. I 2.720(h)(2)(ii) or i 2.744 as regards. discovery against the Staff.
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Thomas Urbanik, II, is a consultant retained by a Staff. consultant
((Battelle) to perform an. Evacuation Time Estimate Analysis. Mr. Urbanik is from the Texas Transportation Institute of the University of Texas (College Station, Texas). See also 4 below.
3.
To date there are no NRC staff evaluations etc. of the LILCO Transition 3
Plan. The criteria which will be used to evaluate the Plan are set out
-in NUREG-0654, a copy of which I-believe the County has in its possession.
' 4..
Attached find copy of a letter dated December 2,1982 from Thomas Urbanik, II, identified above, to John Sears, also identified above.
(This was telecopied to you on August 3, 1983).
The 5thff presently expects to call the following named FEMA (or
' 5.
contractor) witnesses as a panel to testify to whatever contentions are admitted in the Shoreham proceeding which relate to FEMA.
4 A.
Roger B. Kowieski - FEMA Region 2,
- Radiological Assistanct Committee Chairman B..
Fred-Sharrocks - FEMA, Washington, D.C.
Emergency Management 0/fices C.
Edward Tanzman Argonne National Laboratory 6.
Argonne National-Laboratory Personnel who reviewed the LILCO Transition Plan.
Edward Tanzman Chris Saricks
- Kenneth Lerner Phyllis Becherman James H. Opelka lFEMA personnel who reviewed the LILCO Transition Plan.
Headquarters Richard Krimm Jeffrey Bragg George Jett Gary Johnson Fred Sharrocks Spence Perry e
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Region II Roger Kowieski Stewart Glass Frank Petrone Phil McIntire
- 7 and 8.
The Staff is presently defining the scope of work for review of the recently submitted Shoreham PRA and expects to have this task completed by the end of August. This task is being performed by Edward Chow of the Staff.
A schedule for completion of the review has not yet been finalized..It is presently anticipated that the review will require six to twelve months to complete.
It has not yet been decided who the review contractor will be for the Staff. As you are no doubt aware, the Staff does not view the PRA as a prerequisite for the licensing of Shoreham.
(See generally the record compiled with regardtoSC-SOCContention7E]T 9.
See 4 above.
In addition Battelle is preparing a comparison or the range of evacuation time estimates, including Shoreham, based on input from Mr. Urbanik.
I will provide-further information on this next week.
- 10. John R. Sears
- 11. Mr. Urbanik is a subcontractor for Battelle who works independently.
His contact at Battelle is Art Desrusiers.
- 12. See 14 below.
i-
- 13. Mr. Urbanik is not under' contract to the NRC.
(In any event I faii to.
l see the relevance of this request to any potential County contention.)
- 14. Mr. Urbanik has' testified at hearings in Allens Creek, Indian Piont, Byron, Waterford, Diablo Canyon, Zimmer, Three Mile Island, and Fermi..
i He also prefiled testimony at Comanche Peak. We are checking on the dates of such testimony.
In any event, this information may 've obtained
-at the Commission's Public Document Room.
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15 and,16. See attached Biographical Data for Mr. Urbanik which responds to youi requests (Telecopy was sent to you on August 3, 1983).
. Sincerely, M-7-C'-$ M Bernard M. Bordenick Counsel for NRC Staff
Enclosures:
As Stated (w'enclosuresand
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cc:
incoming)
James N. Chrisman, Esq.
Stewart Glass l'
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EXHIBIT 3
'f 1 Federal Ernergency Management Agency 4
Wsshington, D.C'. 20472 AN 2 3 193 MEMORANDUM FOR: Edward L. Jordan Director, Division of Emergency Preparedness and Engineering Response
~
Office of Inspection and Enforcement U.S. Nucle latory Commission FROM:
ard W. Krimm' ~ '
Assistant Associate Director Office of Natural and Technological Hazards SUBJECI:
Findings on the LILCO Transition Plan As Requested by the NRC as Part of NRC. Licensing of the Shoreham Nuclear Power Station This is in response to your June 1,1983, memorandum in which you invoked Section II.4 of the November 1,1980, NRC/ FEMA Memorandum of Understanding by requesting the Federal Emergency Management Agency (FEMA).to provide' the Nuclear Regulatory Commission (NRC) with findings and determinations.
as to whether the LILCO-County plan and/or the interim plans for the Shoreham Nuclear Station are adequate and capable of implementation. As a result of an Atomic Safety and Licensing Board (ASLB) order, your isubsaquent memorandum of June 17. 1983, requested that FEMA provide findings and determinations. on the LIILO Transition Plan as a first priority. This Plan; developed wholly by LILCO, proposes to use LIIED j'
personnel to carry out the offsite preparedness aspects of the plan (to include the - total direction and control function) in the case of an emergency involving an accident at the Shoreham Nuclear Power Station.
First, we would like to indicate how the review process for the LILCO 7
Transition Plan differed from the usual "350"' approval process.
As you know, under normal processing, the plan review is initiated by a formal request by the Governor of the State in which the melear facility is
' located, af ter he/she has received and analyzed plans submitted by the local governments in the emergency planning zone surrounding the
. facility. The request includes the-State plan which is site-specific to ;
the applicable power f acility, appropriate local plans and a statement l
l by the. Governor that the State plan, together with the local plans, are j.
adequate to protect public health and safety of the citizens living within the emergency planning zones for the nuclear power facilities
. included -in the submission by providing - reasonable assurance that appropriate
. protective measures can and will be taken in the event of a radiological emergency for the site. The FEMA processing of a Governor's submittal includes extensive review by the relevant Regional Assistance Committee l
(RAC), a public meeting and most importantly, a drill or exercise, including -
all appropriate governments, to test whether the plan can be implemented.
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In contrast to the process described aMve, the LILCO Transition Plan was submitted, without Suffolk County or New York State endorsement, directly to FDfA Headquarters through the NRC for review under the terms of the NEC/FDfA Memorandum of Understanding. Because the Plan was not submitted -
under 44' CFR 350, a RAC review was not. undertaken. For this reason, coupled with,the fact that the NRC needed a FEMA finding within three weeks, it was necessary to obtain the support of Argonne National Laboratories to assist and perform a technical review of the plan against the 16 planning standards and criteria (A-P) listed in _NUR,EG-0654/ FEMA-REP-1, Rev. 1.
PEMA Headquarters, assisted by FDfA's Region II Regional Director and seaff, direeted this technical review.
FEMA finds that the LIICO Transition Plan has 34 inadequacies in terms of NUREG-0654/FDfA-REP-1, Rev.1.
Our analysis relating these inadequacies to the various criteria is attached.
There are two preconditions, identified below, that need to be met for a FDiA finding as to whether the plan is capable of being implemented and whether LILCO has the ability to implement the plan.
(1) A determination of whether LIICO has the appropriate legal authority to assume management and impletantation of an offsite emergency response plan.
'(2) A demonstration through a full-scale exercise that LIIro has the ability to implement an offsite plan that has been found to be adequate.
FDfA will continue to review the other plans associated with your June 1 request in anticipation that the ASLB will require FEMA findings on thess plans at a' later date.
Attachment.
s' As Stated I
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E%HIBIT 4 JUL 2 2 983 1
-Mr. Jeffrey S. Bragg.
Executive Deputy Director 1 Federal Emergency Management Agency 500 C Street 5.W.
Washington, D.C.
20472
Dear Mr. Bragg:
On. June 23, 1983, your agency reported to the NRC the results of your review.
-of the LILCO Transition Plan for the Shoreham Nuclear Power Station.
In your report you found 34 inadequacies in the plan in terms of NUREG-0654/
FEMA-REP-1, Rev. 1, and in addition, set forth two preconditions that had to
.be met for there to be a FEMA finding on whether the Transition Plan was implementable and whether LILCO had the ability to implement the plan.
These preconditions involved a detemination as to the legal authority of the utility to manage and implement the plan, and a need for a full scale exercise
.. to demonstrate an ability to implement the plan.
'We recognize that a full scale exercise must be conducted to demonstrate LILCO's ability to implement the plan-before it can be authorized to operate the Shoreham-facility-in ' excess of five percent of rated power. However, it is unclear from a reading of your r'eport as to what FEMA's views would be 's a
to the' adequacy of the Transition Plan if the preconditions were removed and the 34 inadequacies were corrected. Specifically, would FEMA find the Transition Plan acceptable if these encumbrances were removed?
In order for us' to have a better understanding of FEMA's views in this regard,
' I would appreciate your advice as to whether FEMA would find that there exists reasonable assurance that the LILC0~ Transition Plan, as written, is adequate.
and capable of implementation if the noted inadequacies wer.e cured and there existed no question of legal authority to carry out the plan.
Thank you very much for your attention to this matter.
Sincerely.
f8DMS KT.Iit= j.phtg T
William J. Dircks Executive Director for Operat. ions t
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EXHIBIT 5 f,. /,'.7,%k k.
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Federal Emergency Management Agency Q ' 4 Washington, D.C. 20472 August 29, 1983 Mr. William J. Dircks' Executive Director f or Operations U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Dircks:
This is in response to your. July 22, 1983, letter requesting the Federal Emergency Management. Agency (FEMA) to provide additional information concerning our report to the Nuclear Regulatory Commission (NRC) 23, 1983, entitled " Findings on the LILCO Transition Plan as of June requested by the NRC as Part of NRC Licensing of the Shoreham Nuclear
. Power Station."
Generally, for any non-governmental plan submitted to us for review, our position will be:
p The plan could be considered adequate, if there are no deficiencies 1.
when the plan is reviewed against the NUREG-0654/ FEMA-REP-1 standards.
The plan could be implemented,'if.the organization or persons
- 2.. required to implement planned actions have the authority to do so.
FEMA, in its advisory role to NRC, could make a finding that 3.
there is reasonable assurance that offsite preparedness is adequate, if a full scale exercise demonstrates that, with the authority and resources, the plan can be carried out effectively.
Specifically with respect to our June 23 report:
If the NRC requests, we will review the revised LILCO Transition Plan against the standards and-criteria in NUREC-0654/ FEMA-REP-1, o
and if we find that the 34 previously identified deficiencies are corrected, we could certify to the adequacy of the plan.
i If LILCO is given the authority to perform response roles of Suffolk County personnel, and there is an exercise in which o
this is demonstrated, FDiA, in its advisory role to the NRC, i-could,make a finding that offsite preparedness is adequate to prctect the. public living in the vicinity of the Shoreham plant.
~
because of the short time that NRC allowed
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With regard to the first point, for the FEMA review of the LILCO Transition Plan we had to modify our
~
If NRC procedure and not use the Regional Assistance Committee (RAC).
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requests a further review of the LILCO Plan, and there is adequate time, we would want to use the services of the RAC.
6
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y I also want to enphasize again that there is a real need to resolve the',
issue of LILCO's legal authority to act in accordance with the plan either in an exercise or during an actual emergency.
This problem is one that. can be resolved by the State of New York.
FDfA's praference, in any case, is to gain the active participation of State and local governments in the emergency planning and preparedness Perhaps the diesel generator problem at process related to Shoreham.
Shoreham vill provide more time for the State and Suffolk County to work out the offsite em:rgency p(eparedness problem.
This should clarify FDIA's views. Please do not hesitate to contact me if I can be of further assistance.
Sincer
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rey S. Bragg Executive Deputy Director e
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EXHIBIT 6 Federal Emergency Management Agency 1
5 Region II 26 Federal Plaza New York, New York 10278 Sg 2
ci.
Karla J. Ietsche, Esq.
Kirkpatrick, Iockhart, Hill Christopher & Phillips 1900 M. Street, N.W.
Washington, D.C. 20036 FDR's Response to Suffolk County's Informal Discovery Request
Dear Ms. Ietsche:
Enclosed please find FE R's responses to Suffolk County's Informal Discovery Request (Interrogatories) to FDR of August 12, 1983. We will attenpt to provide all the doctments as requested in your document request of the same date by September 7,1983.
Please do not hesitate to telephone if you have any further questior.s regarding these discovery requests.
Very truly yours, l h :_m_f h $
Stewart M. Glass Regional Counsel r
cc: Bernard M. Bordenick, Esq.
Stephen B. Latham, Esq.
Ralph Shapiro, Esq.
James Dougharty, Esq.
Ikward L. Blau Spence W. Perry, Esq.
James Christman i
s.
'PAKr 11 - FB%
1.
-Identify the subject areas upon which each of the following FDR witnesses identified by the NRC will be testifying before the ASLB in this case:
~
(a). Roger B. Kowieski
-(b) Frederick H. Sharrocks b
-(c). Edward A.'Tanzman Response 1.
4 (a) Roger B. Kowieski will testify as fto the experiences of the
' Radiological Bnergency Preparedness Program in Region II.
~
(b)- -Frederick H. Sharrocks will testify as to M2% Headquarters role in the review of the LIIID Transition Plan.
(c) Edward A. Tanzman will testify as to the review of the Shoreham/LIliD Transition Plan. for local offsite Radiological Bnergency Response as -
onducted by the Energy and Environmental Systems Division of-the c
Argonne National Labortory.
2.
Identify the date, location and proceeding of all prior testimony given by any of the witnesses identified in Request 1 before any judicial, administrative or legislative body.-
Response 2.
9 (a) Roger B. Kowieski testified before the Atomic Safety.and Licensing Board on the Radiological Bnergency Response Plan for Indian Point-(Units 2 & 3)
'(b). Neither, Frederick Sharrocks or Edward Tanzman have previously
- testified before any. Judicial adninistrative or legislative body.
3.
Identify the positions with Argonne National Laboratory ("Argonne") or H2%
held by the following persons:
.(a) Chris Saricks -
(b) Kenneth Imrner i.
(c) Phyllis Becherman I
(d)~ James H. Opelka (e) - Gary -Johnson '
(f) Richard Krima (g) Jeffrey Bragg 1(h).' George Jett
.(i) ' Spence Perry -
-(j) Frank Petrone (k) Phil McIntire 4
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Response 3.
.(a) 01ristopher L. Saricks'
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. Transportation Systems Planner Energy Resource Analysis Center for Transportation Research
.Ehergy & Favironmental System Division Argonne National Laboratory (b)
Ken lerner-Research Attorney Economic & Social Sciences Division Ehergy & Environmental Systens Division
^*
Argonne National Laboratory (c)
Phyllis P. Becherman Assistant Enviromental Systems Enginaar-Energy & Ehvirornnental.Syt.tems Division Argonne National Laboratory
-Washington, D.C.
(d)
James H.-Opelka Nuclear Physiciet Argonne National Laboratory (e)
Gary Johnson Executive Officer.
Office of Natural.and Technological Hazards Programs.
(f) ' Richard W. Krian Assistant Associate Director:
L Office of Natural and Technological Hazards Programs (g) Jeffrey Bragg Executive Deputy Director Federal Emergency Manageant Agency
'(h) George Jett General' Counsel l
Federal Emergency Management Agency (i) ~ Spence Perry Associate General thunsel Federal Energency Management Agency i
L (j) ' Frank P. Petrone l.
. Regional Director Region 11 l
Federal Bnergency Management Agency l
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(k)' Pailip McIntire Catef, Natural and Technological Hazards Division
- Region II Federal Emergency Management Agency (1). Margaret Singh Assistant Favironmental Scientist Center for Transportation Research
' Energy and Environmental Systesns Division -
Argonne National laboratory (m) Susan Viessman Sunner Research Assistant Argonne National Laboratory
.(preliminary research)
. 4. ' Other than the persons and entities identified in Mr. Bordenick's letter of August 5,1983, identify any other consultants which FEMA has retained or intends to retain to review, analyze, or connent in my manner on the LILOO
' Transition Plan or any other offsite emergency plan for the Shoreham plant.
. What'is the schedule for any such reviews, analyses or connents?
Response 4.
No.other consultants are presently mder consideration to review, or connent on the LIiOO Transition Plan.
. 5.
Identify all studies, reviews, analyses or other such tasks, -if any, that
'Ihomas Urbanik has conducted for FDR, either directly or indirectly as a subcontractor.
Response 5.-
Mr. Urbanik has not been under contract to FDR for any work relating to the REP Program.
.6.
Does FB R intend to review Revision I of the LI W O Transition Plan? If yes, describe' the schedule for such review, and identify the person or persons who will conduct the review.
1 Response 6.
FDR has not received a request to review Revision.I of the LIwo Transition Plan fran the NRC. Under Section 11.4 of the November 1,1980, NRC/FDR Memorandan of Understanding the NRC can request such a review. '1he FDR/NRC sterring connittee will determine if such a review will be undetaken and if it is to be undertaken FDR will at that time determine who will conduct the review.
- 7.. Identify the HMA personnel who requested, directed, or supervised the Argonne review of the LIw o Transition Plan.
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Response 7.
c Gary Jchnson Executive Officer Office of Natural and Technological Hazards Programs.
Craig Wingo Chief, Field Operations Branch Technological Hazards Division Federal Energency Managenent Agency Headquarters J Frederick Sharrocks, Jr.
Senior Program Manager Technological Hazards Division Federal-Emergency Managenent Agency Headquarters 8.
Describe the subject areas of concentration and ' division of responsibilities, if any, of each of the Argonne reviewers of the LIIDO Transition Plan.
Response 8.
The following is a strenarization of the Shoreham plan review assignments.
Assignment of' Responsibility - Ed Tanzman Bnergency Response Support and Resource - Ed.Tanzman Bnergency Classification System - Jim Opelka
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Notification Methods and Procedures - Ken I4rner Bnergency - Coarnunications '- Ken Imrner Public Education and-Information'- Phyllis Becherman
- -Bnergency Facilities and Equipment - Ken Imrner Accident Assesc:nent - Jim Opelka
- . Protective Response - Margaret Singh, Chris Saricks Radiological Exposure Control Jim Opelka Medical and Public Health Supp6rt - Jime Opelka Recovery and Reentry Planning and Ibstaccident Operation -
Phyllis Bechennan
'*.-Exercises and Drills - Phyllis.Becherman
. Radiological Energency Response Training - Philis Bechennan Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Bnergency Plans
- Phyllis Bechennan Editing - Donna Kenski 9.
Describe' the division of responsibility, and subject areas of concentration,
'if any, of each of the FH % reviewers win reviewed:
. (a) - - the' LIILO Transition Plan (b).- the Argonne review of the LIILO Transition Plan
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Rescanse 9.
FDR Headquarters review primarily consisted of reviewing the effort performed by its contractor "Argonne National Laboratory" because of severe time constraints. Fred Sharrocks, Senior Project Manager, was responsible for this review.
Craig Wingo and Gary Johnson reviewed the effort performed by Sharrocks.
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