ML20090K373
| ML20090K373 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/21/1984 |
| From: | Glass S Federal Emergency Management Agency |
| To: | |
| Shared Package | |
| ML20090K363 | List: |
| References | |
| NUDOCS 8405240185 | |
| Download: ML20090K373 (17) | |
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s LNITED frA1TS OF AMDLICA NUCLEAR IWOUIATC.d CCPMISSION COL, TED tefore the Atanic Safety and Licensing Appeal Board
'84.T 23 t!i:d5 In the Mattar of
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CYxAet No. 52-322-ote3' long Island Lighting 0:mpary
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(Dnergency Planning)
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(shoreham naclear Power station, )
Unit 1)
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i MDORANDlN IN SUPPORP OF FDR's APPEAL t
or AN ORDER OF 1NE A10MIC 5 Art, t Att T
LICENSING 90hAD Att REQUErr FOR A FRAY Introduct. ion on April 20, 1984, kffolk County filed a Moquest for Prcduction of Dxunents by FD%.1he broadly weded requeJt sou@nt *All docunents that were produce 1 in connection with, or in any relate to the FD% Mogional Assistance 0:mmittee
("RAC") rwiew of the L1140 Transition Plan for the #creham maclent Power Station, incimiin), but not limited to..." all memorarsia, correspondence, questions, coments, reports, evaluations, ratings, sumarier, notes, drafts, and transcripts, minutes, sunnaries or roten of meetings, discussions or conferences inciating telethone mnferences among RAC meters or others relatinJ to the RAC revlow, i
On my 8,1964 Nffolk Cbunty, seeking to expedite its docunent, disowery request, filet a M. ion to OMwl Response to the Request for Production of Dmanents ty Ptt%. On my 9, 1984, the tacensin; Ibard held an off-tJw-recon! conference to discuss this discwory dispute. YttM reporte1 that it
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wmid object to disclosure ani umid assert o privilege with respect to a ruber of the doctanents within the scope of the osunty's disowery request. At the anference, the hard set a schedule for the parties to file their respective papers (Tr. 8751-8754). 'the schedule did not provide for a Response by FD% to the county's etim to 0:npel.
As the initial item on that schedule, FDR file 3 on my 15, 1964, its full list of doctanents respmsive to the suffolk county discovery request. mn identified and zwieases approximstely 50 doewunts that cor$ies with the rather broad and ambiguous disowery requit fra the Osunty. '1his fblicwiry) closely upon 82ffolk county's counsel's voluminous Freedom of Information Request to rD%,14C and DOE. m%
also identifiel 37 other documents consisting of drafts, that personal rv>tes, predecisional nivisory menorania etc.
it assertel were irrelevant to this proceedity; an! protectal by the doctrine of " executive privileys".
On my 17,1984 auffolk Cbunty file! Its Mw.ian to 02tpel the Production of Dxunents. Litt:0 an1 the MC Staff both filed Responses supportive of FD%'s position. On Friday, my 18,
?984 at approkimately 3:30 P.M. the Atomic Saft.y and Licenstrvj lbard by conference en11 orally ruini on Suffolk osunty's mtion to Osrpel Production of Dxwnnts fra the Peterni Dwrgency mtw;ement hjency.1/
l 1/IAm to'tlw neel for an expelital Giliion tra Baard epwout l
to rule orally on the 0)unty's mtion to 03nvel with a written order to in distritutal on Mantay, my 21, 1964.
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o m is Licensing Board has previously discussed procedures for ruling on motions to empel FENA to produce docunents. See "Menorandtzn and Order Ruling on Suffolk (bunty MX.icn to i
Capel FD% to Prodtx:e Docunents", Novenber 1, 983 (Memorandum and Order, IBP-83-72,18 NRC 1221 (1983)).
No party has contested the procedural requirenents for asserting executive privilege or the standards utilized by this Board to determine if executive privilege applies.
'1he Board ruled that EDR catplied in the present matter with all the. procedural requirenents for asserting executive privilege.
he Ibard indicated that the privilege is a qualified cne and does not absolutely bar discovery. he ASLB has held that it may be necessary for the Ibard to conduct an in camera inspection of the disputed documents in. order to " balance the need for the privilege against the need of the Cbunty to have
-the doctrnants". 'ihe Ibard indicated in its oral order of thy 18th the various-factors that it considered in its ruling as to whether the docunents should be ampellei to be produced.
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We Ibard indicated that the following factors called for
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N release of these docunents 1) inportance of doctanents, 2) l 1 unavailabilify'ofbwnants, 3) philosophy of broed
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discovery, 4) overweighing of harm, 5) RAC Katuurs not v6 ordinates of EDR.
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'Ihe Board indicated the following factors called for the protection of these doctnwnts fran disclosure 1) concern for future RAC participation, 2) curtailment of activi. ties, 3) relevant infontation could be tested by cross-examination of the FD% panel, 4) docznents not relevant, 5) what one individual PAC menber feels is not relevant, 6) the upholding of exe utive privilege.
'Ihe Board determined to protect seven (7) docuents as they relate to the advisory opinion of FDR staff arri policy decisions.
'Ihe Ebard determined to order the production of thirty other documents relating to the activities of the Regional Assistance Castittee. 'Ihe Ibard ordered FDR to provide to the Cbunty the individual review catments of the iniividual RAC members, consultants and staff of FDIA as provided to the RAC Chaiman (items 1-19); the iniividual personal notes of the RAC members of a RAC meeting held on January 20, 1984 (items 20-23) it should be natal that the only docment in this group that had been seen by other than the original author was item 23 which was reviewed by counsel to determine the relevancy to this diso:wery request; a draft of definitions and categories as proposed by the RAC Chairman and distributed to the RAC members (itan 25); a sample of four draft pages of February 1984 (bnsolidated RAC Review (item 26); a FD4A ertployees notes and knpressions of the RAC h
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Paview (itern 31); a confidential merrorardum to th2 FAC meubers fran the RAC.@mirman concernire the Imgal Issues Identified during the PJC Peview of the LIIf0 Transition Plan for Shoreham, Rev. 3 (item 34); three drafts of the Cbnsolidated RAC Review dated January 20, 1984 annotated with the individual notes of FDR ernployees ard contractors (itan 35); draft of LIIf0 Plan Review of LIIf0 Transition Plan, Revision 1 (iten 36); and 26 pages of a flip chart of the LIIf0 Transition Plan titled Shoreham Review Cbstpilation of RAC Ccriments with the FAC mernbers' individual ccmnents clearly identifiable as such he Atomic Safety and Licensing Ibard rejected FB%'s oral notion for reconsideraticn of its ruling but granted FDR's mot on for a stay of its order to prcduce until tenday, my 21,1984 at 5:00 P.M. in order to allow FD% time to Appeal its decision.
FDn respectfully requests a continued stay of the ASIB's order until such tine as this bcdy can rule on FDR's appeal of the Order to Produce.
We' individual opinions of the' RAC msnbers are irrelevant to this proceeding. he RAC submitted its final report which l
reflects the collegial judgment of the RAC. 'Ihe RAC review is t
1 incitded as a prtien of '.he testimony which further addresses the specific contentions which are the issues in litigation before the ASIB. We FDR witnesses have indicated l
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I e that the purpose of their testinony is to address the contentions relating to offsite preparedness at the shoreham 142 clear Power Station dtich are pxperly the natter before the ASLB. Further, the FDA witness panel has irdicated that their testimcmy (p.ll, ques. 8 FDR Testinony) represents the current FD% evaluation of the LILCO Transition Plan, Revision 3.
'Ihe Director of the Federal Energency Managenent Agency expressed his concern as to the ramifications the release of these docunents would have on the functioning of FDR and its Regional Assistance Comtittee. 2/
Both the Ocmnission and the At<2nic Safety and Licensing Board in the Mitter of Consolidated Eiiscn 02npany of New York et.
al (Indian Ibint) addressed a similar canpelling issue as it related to the discovery of the individual impressions of observers at an Exercise. (It should be noted a substantial ntrnber of these observers were contractors or employees of government agencies other than FB%). 'Ihe Q2mtission, in particular Ccmnissioners Ibberts and Ahearne raised very serious concerns as to the chilling effect of releasing individual execrit forms (exercise critique forns utilized to record individual observations, evaluations and ocmnents relatire to an exercise of a hiiological Dnergency Prepared-ness Plan). (Memorandtzn dated 20th August,1982, Ibberts concurrirg cn p.4).
2/ Affidavit Attached -
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'Ihe issue raised here as it relates to the RAC's deliberative ecmnents and rotes carries with it the same pitfalls identified in the Chunissions menorandum. 'Ihe confidentiality of the eczments and concerns of the RAC msnbers is important to their ability to carry out their assigned task. 'Ihe RAC manbers in their review of plans ard in the observation of exercises carry out their assigned duties in a highly professional manner often in an at:msphere of hostility and strong opposing philosophies. 'Iheir review necessitates their making ecmnents that are at times quite critical. '1here are many situations @en in their other duties they have to interact with the people whose w rk or actions they have subjected to criticism. In addition, their evaluations may at times not conform with the policies of their particular l
agency. 'Ihe Indian Point ASIB (Tr. 12206-12227) recognized the chilling effect that disclosure of their individual cx2nments would have and limited the scope of discovery to a team execrit in order to balance the needs of the intervenors while still insuring that the individual observations muld ret be disclosed.
l FDR contends that after the Appeals Board considers all of the facts in this particular case as well as the prior decisions of the ASIBs and the Ommission, FDIA's position on the merits will prevail.
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- m If a Stay is not granted ard the material is released there is no relief that could be granted that muld remedy the damage caused by the release, not only in this matter but in other Radiological Dnergency Preparedness proceedings in which FD% and/or the RAC is requested by the NRC to review ard ccmnent on emergency plans, exercises or preparedness. 3/
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'Ihe issuance of a stay will rot result in substantial hardship to any party. 'Ihe parties will just adjourn the deposition of the FD% witnesses. 'Ihis deposition has been previously adjourned by the unilateral action of the 0:unty, so they certainly can ret assert prejudice at this time. All parties urderstand that this may result in the postponemerrt of the appearance of the FHR witnesses before the ASIB. B2t this is not the first time the hearing witness schedule has been adjusted nor will it be the last. With over a week before the resumption of hearings ard with over half the contentions relating to offsite preparedness to be heard there is no lack of material. 'Ihe substitution of witnesses at this time can be acccrtplished with a minimum of disruption. 'Ibe one party that would have the most to lose by any delay, the applicant, indicated in the conference call I
that they could arrange for other witnesses to proceed when the hearings restrne and that they would rot object to the postponement of FH R's witnesses if necessary to resolve this impartant issue.
3/McIntire affidavit attached.-.
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Tha public interest requirss a full, detailed, sonetimes critical reviea of energency plans, exercises ard preparedness around nuclear plants. They need the individuals who are mnductirg that review to be able to functicn fully, without reservations or handicap. %erefore, the public interest is best served by the full adjtdication of this issue ard the protection of the integrity of the Regional Assistance Comtittee process.
We Atonic Safety and Licensing Board does rot conterd that executive privilege was inproperly asserted. Tb the contrary, the Ebard stated in its ruling that the procedural requirements to assert executive privilege were met. The only issue for this body to determine is if the Cbunty's claim to access to the thoughts, personal notes, ard irdividual coments of the RAC members outweight the p31 icy cancerns of preserving those thoughts, opinions ard the whole RAC process.
FEMA has provided to Suffolk Cbunty doctnents outlining the asstriptions made in order to alloa the BAC nembers to proceed with a technical review and has released copies of changes and clarifications to the Review after its subnittal to FEMA headquarters. We County will have the opportunity to depose.
the FENA witnesses as well as subject them to cross-examin-ation at hearing. %e County's doctnents make no showing of any ciretnstances regturing overriding the policy considerations of executive privilege. -
'Iha individual opinions of ths RAC membera are irrelevant to this proceeding. 'Ihe RAC sutmitted its final report which reflects the collegial judgment of the FAC. 'Ihe Ibard as unable to distinguish to the satisfaction of this party the difference to be afforded the pre-decisional deliberations aM advisory opinions of the RAC frm those of the NBC's Advisory 02mtittee on Reactor Safeguards (ACRS).
Deliberations and advisory opinions in preparation of the ACRS repart are protected by executive privilege. Virginia Electric and Power Co. (tbrth Anna Power Station, Units 1 &
2), CLI-74-16, 7 AEC 313 (1974) aM Consumers Poer Co.
(Midland Plant, Units 1 & 2), ALAB-33, 4 AEC 701 (1971) aff'd AIAB-123, 6 A E 331 (1973). See also Consumers Power Co.
(Midland Plan, Units 1 & 2), 1BP-81-4, 13 NRC 216 (1981) and Consumers Power Co. (Palisades Nuclear Ibwer Facility),
ALI-80-1, 12 NRC 117 (1980).
Further, the structure and functioning of the RAC itself (see 44 CFR 351.10, 351.20 through 351.28) - a collegial, advisory body of experts in their subject areas, not all of whan are enployees of the parent agency -- are closely analogous to that of the ACRS. As the 03' missions regulations, practice and records of the ACRS are protected by executive privilege the RAC's deliberations and records and a fortiori, the records of its individual menbers aM consultants, should be given protection analogous to that given the closely cmparable ACRS. _
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'Ihe RAC review is a collec,1ve document. If the individual RAC members and consultants hold a spectrun of views cn any given issue, that fact would not vitiate the validity of the consensus expressed in the rep 3rt. Resoluticn of the divergent individual views is an inherent part of the ommittee process ard the privacy of that process has been consistently recognizei as being entitled to protection. In short, disclosure of the materials sought to be protected is unlikely to produce or to lead to the production of relevant information and would chill the conduct of the cmmittee deliberations process.
It is obvious frcan recent developnents that the role played by FD% in the various hearings before the Atanic Safety and Licensing Boards has been expanding while the NRC in its proposed regulaticns 10 CFR 2 and 50 propose to reduce the role of its cwn staff in these proceedings. If the NRC expects to receive full cooperaticn of FDR ani the RAC it should be willing to afford to FDR the same protection that it feels is necessary for its own ACRS to function.
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l All parties to this proceeding have been informed that the NRC will shortly receive revision four (4) to the LIIf0 Transition Plan for Shoreham. It is expected that NRC will transmit this revisicn to FDR for review by the RAC. 'Ihe RAC i
m airman has indicated (affidavit attached) that the recent ruling of the ASLB if left to starxi will adversely affect the ability of the RAC mairman to receive in written format the omments, concerns and opinions of the Regional Assistance Ommittee. 'Du chilling effect caused by the release of this material will undoubtedly result in a delay in the review of revision 4. Considering the ccntinuing nature of the discovery requests in this proceeding FDR will have to alternative but to turn over to the Cbunty the individual RAC members coments as received, drafts as produced, notes as made. 'Ihis is not a conducive atnesphere for the frank exchange of ideas and views that es envisioned when Executive Order 12148 and 10 CFR 350 and 351 were prmralgated.
CJNCWSICN Ebr the foregoing reasons, the Federal Bnergency Management Agency's Appeal and Regaest for a Stay should be. granted.
Respectfully subritted, Stewart M. Glass Regional Q)unsel Federal Energency &nagenent Agency Boom 1349 - 26 Federal Plaza New York, New York 10278 l
Dated: May 21, 1984 l
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tNITED STATES OF AMERICA NUCLEAR REGUIATORY COMISSION Before the Atomic Safety and Licensing Board
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In the Matter of
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AFFIDAVIT OF UXO IS1AND LIGHIllG COWANY
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IDOIS 0. GIUFFRIDA
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Director, Federal (Shorehan Nuclear Power Station Unit 1)
Faergency Management
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4mg IDOIS 0. GIUFFRIDA, hereby declares:
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I am the Director of the Federal Emergency Managenent Agency (FEMA), an agency of the executive branch of the Federal government.
I make this declaration in support of the Agency's Response to Suffolk County's Discovery Request.
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Executive Order 12148 charges the Director, DNA, with esta-blishing policy for and coordinating all civil, emergency planning and assistance functions for Executive agencies. On December 7, 1979, the President, directed that FEMA assume lead responsibility for all offsite nuclear acergency planning and response.
L Notwithstanding the procedurcs which may be set forth in 44 CFR 350 I
for requesting and reaching a FEMA adninistrative appproval of State and local plans, findings and determinations on the current status of emer-
. gency preparedness around particular sites may be requested by the l
NRC/ FEMA Steering Comittee and provided by FEMA for use as needed in the f
l NRC licensing process. These findings and determinations may be based
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upon plans currently available to FEMA or furnished to FRR by the NRC.
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Regional Assistance Comittees were established in each r:gion 3.
pursuant to 44 CFR 351.10. They consist of representatives frcxn the Mx: lear Regulatory Comission, Envirtxxnental Protection Agency, Departnent of Health & Rznan Services, Department of Energy, Deparcnent of Transportation, U.S. Deparanent of Agriculture, Deparonent of Connerce and other Federal departments as appropriate.
It is chaired by the FER regional representative.
Pursuant to 44 CFR 351.10 and 351.20 through 351.28 each federal agency menber of the RAC supports the RAC and has a specific assigrynent which includes the review of plans.
Pursuant to a request from the NRC, EHR arranged for a review 4.
of the LIIS Transition Plan by the Regional Assistance Conrnittee and transnitted the results of that review to the imC on March 15, 1984.
FBR has identified eighty-five (85) doctunents that appear to be 5.
responsive to Suffolk County's Discovery Request. FalA has provided copies to Suffolk County of all but the following doctanents.
14tter dated November 3,1983 conveying NRC RAC member, Craig Z.
l 1.
Gordon's, connents on the LIIE Transition Plan, Revision 1 for Shoreham.
Henorandon dated Novenber 2,1983 conveying DOE RAC menber, Herb 2.
G. Fish's, coments on the Lilm Transition Plan, Revision 1 for Shoreham.
I 3.
Letter dated October 21, 1983 conveying FDA (HMS) RAC menber, i
Bernacki's, coments on the LILOD Transition Plan, Ronald E.
i Revision 1 for Shoreham.
I Memorandtrn dated Novenber 3,1983 conveying Der RAC member, Paul 4.
j Intz's, connents on the LIIDO Transition Plan, Revisicx11 for l
.Shorehan.
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14ttrr dated October 14, 1983 conveying USDA RAC member, meryl Malina's, coments on the LIIID Transition Plan, Revision 1 for Shorehm.
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Submission dated November 1, 1983 conveying FD % employee, Robert L. Acerno's, coments on the LIIID Transition Plan, Revision 1 for Shoreham.
7.
Letter dated Novenber 2,1983 conveying INEL RAC consultant, Joe H. Keller's, coments on the LIIID Transition Plan, Revision 1 for Shoreham.
8.
Memorande dated November 4,1983 conveying ANL RAC consultant, Thomas E. Baldwin's, coments on the LII/D Transition Plan, Revision 1 for Shoreham.
9.
Letter dated December 5, 1983 conveying EPA RAC member, Linda Olmer's, comants on the LIIID Transition Plan, Revision 1 for S,horehan.
- 10. Ietter dated January 12, 1984 conveying NRC RAC member, Robert J.
Bores's, coments on the LIllD Transition Plan, Revision 3 for Shorehan.
- 11. Memorandum dated January 6, 1984 conveying DOE RAC member, Herbert Fish's, coments on the LILCD Transition Plan, Revision 3 for Shoreham.
- 12. Letter dated January 6,1984 conveying FDA RAC member, Ronald E.
Bernacki's, coments on the L11/D Transition Plan. Revision 3 for
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Shoreham.
- 13. Memorandum dated January 10, 1984 conveying Dar RAC member, Paul lutz's, coments on the L11/D Transition Plan, Revision 3 for Shoreham.
- 14. latter dated January 6, 1984 conveying USDA RAC member, Cheryl Malina's, coments on the LillD Transition Plan, Revision 3 for Shorehan.
- 15. Submission dated January 9, 1984 written directly on copy of preliminary draft conveying FB% staff member, Robert L.
Acerno's, coments on the LILCO Transition Plan, Revision 3 for Shoreham.
- 16. m% Plan Review Form - dated January 12, 1984 conveying EPA RAC member, Joyce Feldman's, coments on the L11/D Transition Plan, Revision 3 for Shoreham.
- 17. 14tter dated January 10, 1984 conveying IIEL RAC consultant Joe H.
Keller's, coments on the LillD Transition Plan, Revision 3 for Shoreham.
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- 18. Memorandun dated January 9,1984 conveying FDR msnber, Marianne C. Jackson's, consnents on the LIILO Transition Plan. Revision 3 for Shorehan.
- 19. Submission dated January 9,1984 written directly on Preliminary Draft conveying ANL RAC consultant, 'Ihomas E. Baldwin's, consnents on the review of the LIILO Transition Plan, Revision 3 for Shorehm.
- 20. Preliminary Draft of Consolidated RAC Review dated January 20, 1984 with individual notes of Cheryl Malina of RAC meeting of January 20, 1984.
- 21. Preliminary Draft of Consolidated RAC Review dated January 20, 1984 with individual notes of Robert Bores of RAC meeting of January 20, 1984.
- 22. Preliminary Draft of Consolidated RAC Review dated January 20, 1984 with individual notes of Joyce Feldnan of RAC meeting of January 20, 1984.
- 23. Preliminary Draft of Consolidated RAC Review dated January 20, 1984 with individual notes of Paul Lutz of RAC meeting of January 20, 1984.
- 24. Pre-Decisional Drafts of March 15, 1984, Imtter Transmitting FD%
Finding to NRC.
25.
Pre-Decisional Draft of Definitions of Categories, etc., for February,1984, Consolidated RAC Review of the LIlm Transition Plan.
- 26. Sample of Four Random Draft Pages of February,1984, Consolidated RAC Review of LIIDO Transition Flan.
27.
Pre-Decisional Drafts of the 2/21/84 Region 11 Transmittal Menoran-dun to Headquarters for the RAC review of the LIlm Transition
- 28. Pre-Decisional Drafts of the 2/3/84 Manorandun to Frank P.
- Petrone, Regional Director, Region II, From Samuel W. Speck, Associate Director, State and local Prograns and Support, Federal Daergency Managenent Agency,
Subject:
Shoreham Plan Review.
Pre-Decisional Draft of Discussion Points, for Richard W. Krinin and 29.
Joseph Winkle for Press Conference (not held) on the FB% finding of 3/15/84 for Shorehan.
- 30. Pet-Decisional Sets cf Q's and A's for Pracs Confirenca (not held) on the FD % Finding of 3/15/84 on Shoreham.
- 31. Margaret Lawless" copy of Region 11 RAC findings with her annotated notes.
- 32. Pre-Decisional Notes and Option Paper on Strategies for Handling Shorehm Offsite Bnergency Preparedness Problem.
- 33. Draft Telefax Header and Pre-decisional draft of FDIA 10/27/83 Memoran-de to: Edward L. Jordan, Director, Division of Bnergency Preparechess and Engineering Response, Office of Inspection and Enforcement, Nuclear Regulatory Comission, From: Richard W. Krim, Assistant Associate Director, Office of Natural and Technological Hazards Programs,
Subject:
Federal Bnergency Management Agency Support for Nuclear Regulatory Commission Licensing of Shoreham Nuclear Station.
- 34. Memorande to Regional Assistance Comittee members from Roger Fowieski,
Subject:
legal Issues Identified During the RAC Review of LIILO Transition Plan for Shorehm (Revision 3).
- 35. Three (3) Drafts of Consolidated RAC Review of LIICO Transition Plan for Shoreham - Revision 3, (1/20/84)-Annotated with notes of FS % employees and contractors
- 36. Drafe LIILO Plan Review (LIIID Transition Plan Revision 1) consolidated RAC review.
37, 26 pages of a flip chart of Regional Assistance Comittee meabers' individual coments on LIIDO Transition Plan titled I
Shorehan Review Compilation of RAC Coments.
6.
I have personally examined all of thd above docments except for itens twenty (20) through twenty-three (23). As to items twenty (20) through twenty-three (23), I m familiar with the underlying docment and understand that the notes appended thereto are the individual notes of 4
the Regional Assistance Comittee members of a RAC meeting. I have concluded that the production of the above enmerated docments wuld be contrcry to the public interest. These docments are being withheld frcru discovery at my direction as they consist of intra-departmental and inter-deparcnental menoranda and comunications containing opinions, recu w adations and deliberations pertaining to decisions that the Federal Bnergency Managenent Agency was required to Inake in response to requests from the Nuclear Regulatory Comission.
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As the exec 2tive in charge of the overall operations of the agency, I assert that these docunints are subject to the protection of executive privilege. The production of these docunents will have a chilling effect on this agency's ability to receive in written format the connents, concerns and opinions of our staff. It will also adversely affect the ability of our RAC Gairman to receive in written format the comnents, concerns and opinions of the representatives to the Regional Assistance Conrnittee.
Liifs~0. Giuffrida, Director Federal Dnergency Management Agency 4
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