ML20094G595
| ML20094G595 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/06/1984 |
| From: | Federal Emergency Management Agency |
| To: | |
| References | |
| OL-3, NUDOCS 8408130373 | |
| Download: ML20094G595 (14) | |
Text
' $DU 2:
c.
TRAINING 03ffl!NFIWS Q.121.
In the preparation of the testimony that follows on the above contentions, what material was reviewed by the witnesses?
A.
In addition to the LIIID Transition Plan, Revision 3, trair'y modules 1,2,3,4,5,7,8,9,10,11,12,14,16,17,18 and 19 which included 11 video tapes ard 12 scripts that were made avail-able to FDR; also a spot check of scme training logs ard workbooks was conducted at LIICO's Hicksville Office on July 24, 1984.
8408130373 840806 PDR ADOCK 05000322 T
- 101 -
GhO
)
t a.If Ottm!NTION 39 0 122. 39.A-Does the LIILD Transition Plan adequately provide for training of LIICO personnel so that trained replacements will be available to account for personnel loct via attrition?
A.
S e RAC evaluated NUREG 0654 element 0.1 as adequate. We plan states that in addition to the ongoing regularly scheduled train-ing, special accelerated training will be intiated to maintain staffire of key positions.
Se LIICO training program utilizes the concept of overstaffing' to insure the availability of adequate ntunbers of response per-sonnel. According to their records LIICO has trained, or is conpletire the trainiry of, approximately 50% excess staff.
Were is a tracking system whereby the ntsnbers of fully trained individuals for eadt job functicri is maintained.
O.123.
39.B-Does the LIICO Transition Plan adequately provide for train-ing of non-LIICO support organization personnel incit:3ity prcui-sions to account for attrition within these organizations?
A.
We LIICO Transition Plan adequately provides for trainirs of non-LIIf0 support organization perscmnel. We plan designates the (bast Guard arx1 anbulance personnel as exanples of such
- 102 -
f.
organizations but does rot limit training to these organizations.
In fact, as statei in the plan, LIIf0 suggests that the American Red Cross should nrticipate in LERO training. Other organiza-I tions which are included in the plan as organizations whidt have to take action but are not support organizations, will be offered annual training.
Non-LIILO support organizations, which have indicated their willingness to provide specific response by signing letters of agreement, accept the responsibility for informing LIICO of their training needs.
- 103 -
CCIm NrI m 40 0 124. 40-Does the trainirg program described in the LIIID Transition Plan adequately prepare LIIf0 enployees for their respective emergency functions as well as make provisions for maintaining this capability?
W e training program described in the LILOO Transition Plan is A.
%e designed to provide adequate training to LIILO personnel.
training program provides for classroon training, drills, table top exercise and full scale exercises. We LILOO Transition Plan contains a matrix of drills and exercises to be conducted.
Were is a trackirg system whereby the ntrnbers of fully trained individuals for each job function is rtaintained.
We ability of specific individuals to perform any particular job function during a real energency cannot be evaluated.
Ibwever, the specific duties of emergency response personnel are rot in most cases conplex ror do they require a job related experiences. Experiences in other types of energencies have shown that emergency workerc have performed their roles wil in all types of emergency situations where stress and fatigue are involved.
- 104 -
a.
.P 03ffENPICBT 41 0 125. 41-Ibes the LIIm Transition Plan provide for adequate trainire in the use of comnanications equipnent for emergency personnel?
'Ihe LIILO Transition Plan provides for adagate trainin3 of.
A.
emergency personnel in the use of cxxmunciations equipnent.
1he plan provides a listing of the radio systen functions which are to be tested quarterly, and provides for a mechanism whereby problens are to be resolved by the anergency Planning Coordina-
'1his portion of the procedure calls for radio system checks tor.
between the EOC (the cxxmunicators) ard various field locations.
It is our cx>nclusion that the field locations to be involved in these tests nust be staffed if this procedure is to be ocznpleted.
It is our underowxling that these quarterly cxxmunications drills have not been conpleted.
i I
i I
- 105 -
j l
E l
o I
I 9
ONTENTICE 44 0.126.
44.D-Does the LIIID Transition Plan adequately provide for the testing of tha understanding of +he message content by recipients at the Federal and State response organizations?
A.
'the LIILO Transition Plan does not specifically address this issue. Ibwever, the Radiological Energency Data Form which is used to transnit energency information is a general form and is used by other reactor sites within New York State.
It is our belief that the Federal Agencies and New York State, if they choose to receive such messages, will understard the content since in exercises for other sites this form has been successfully used.
Connecticut, the other State involved in the ingesticn pathway EPZ, is also involved with radiological energency planning for other sites and has denonstratal the ability to conpreherd such information.
O.127. 44.E-Does the LII.00 Transition Plan adequately address " free play for decision making"?
A.
'Ihe RAC review of the LIICO Transition Plan founi NUREG elenent N.3 to be adequate. 'Ihe plan prwides that scenarios for drills and exercises would allow for participant discretion and decision making. '1he exact details of how this " free play" wuld be accom-plished depends on the specific objective (s) of a particular drill
- 106 -
t.
or exercise. In the case of a Federally evaluated exercise, the offsite objectives of such an exercise nut be reviewal and approved by EU R.
Q.128. 44.F-Does the LIICO Transition Plan adequately provide for evaluation and critiques of the annual exercise?
A.
We RAC review of the LILCO Transition Plan fourxl NUREG 0654 elements N.4 arxl N.5 to be adequate. We plan correctly states that the coments frm the FE2% Post Exercise Assessmmt Report will be available for use in revisirg the plan. Ibwever, changes to revision 3 of the plan are required to nnintain cnnaistency (see PAC review pages 54 and 55).
It should be noted that the FE2% requirement is for biennual Federally evaluated exercises not annually as was requiral in the past. 'Ihere are also FDR provisions for Federally evaluated remedial exercises to insure that serious deficiencies have been corrected.
In additicn to the FE2% evaluations any participating organization may prepare an exercise evaluation.
- 107 -
CtamNFICBT 98 90-Does the LIIID Transition Plan adequately provide for initial 0 129.
training and periodic retraining of emm ency organizations which will be required to "take actions during an incident"?
According to their records, LIILO has conpleted training of the A.
(bast Guard and four of eleven antx11ance ecmpanies. According to LIILO personnel, contact has been made with schools, hospitals, and nursing hones to arrange for training in accordance with the plan provisions. According to LIILO personnel the training for the Wading River School District is planned for the fall of 1984, when the full staff will be available. Also, see answer to (bntention 39 B.
9 h
- 108 -
r-CCNffNTION 99 0 130. 99.C-Ibes the LIIID Transition Plan provide for adequate training of LIICO personnel by qualified instructors?
A.
We LIILO Transition Plan does not address the qualifications of the training instructors. Proof of the quality of instruction, or lack thereof, is the ability of energency response personnel to perform their job functions. mis ability is traditionally evaluated in a Federally observed exercise.
O.131. 99.G-Does the LIICO training program provide adequate information on how to perform various job functions?
A.
We LIICO Transition Plan and the training program for IERO emergency response organizations contain adequate infonnaticn for personnel to be cble to carry out their emergency functions. We knowledge and effectiveness of energency workers to perform their jobs, based cn their familiarity with these materials, muld be evaluated at a Federally observed exercise.
- 109 -
?
00NTDFfICai 100 O.132.
LOO.B-Ibes the LIICO trainin3 program make adequate provisions for observing, evaluating and critiqueing drills and exercise?
A.
%e plan defines drills as..." supervised instructional periods We plan lists drills which will be held as a part of the overall training program. In addition to the drills specifically required by NLJREG 0654, provisions for additonal drills are included in the plan. %e plan specifics that drills are evalua-ted by designated observers. We believe that the cbjective of these drill evaluations will be in accord with the supervised instructional purpose of the drills as stated in the plan. We observation and evaluaticn of exercise is discussed in the answer to Contention 44.F.
Q.133.
100.D-Does the LIIro Training program adequately provide ener-gency personnel the opportunity to perform their job function?
A.
We LIIf0 Transition Plan makes provisions for drills wherein the participants will utilize the facilities, equipnent and proced-ures to respond to the simulated incident.
- 110 -
?
o.134. 100.G-Does the LIILO Training program contain adequate provisions for ovaluating the performance of individual emergency response personnel?
A.
The LIILO Transition Plan is not specific with regard to the performance standards by which the adequacy of trainirx3 would be evaluated. A Federally evaluated exercise incittles objectives which constitute a type of performance standard. The FD%
evaluation is based tpon specific exercise objectives 4tich are keyed to NUREE 0654 planning starvlartis. The FDR Post Exercise Assessment would indicate'if the exercise objectives were met.
If the training of response personnel is evaluated as being deficient, there are provisions within the FD% rules requiring renedial exerciscs to denonstrate correcticn of problan areas.
- 111 -
i
..AOS s
m a. a......- M 9E? E D
k turTED srAnS cr inmICA NUCIEAR REGUIA'IORY COPHISSION 20'M T U RM; BEFORE THE ATOMIC SAETrY AND LICENSING APPFAL BOARD W G 10 NO:56 In the Phtter of
)
)
Docket Noij50-322-OL-3 L0tG ISIAND LIGfrING COMPANY
)
(Bnergency"Plannirig) x
}
"ONm (Shoreham t&aclear Power Station, Unit 1 )
CERTIFICATE OF SERVICE I hereby certify that copies of the Federal Bnergency Managenent Agency's Testimony on Training (bntentions 39,40,41,44,98,99 and 100 has been served on the following by deposit in the United States mail, first class or Where indicated by an asterisk by Telecopier this 6th day of August 1984.
James A. Iaurenson, Esq.*
Howard L. Blau, Esq.
Administrative Judge, Chairman 217 Newbridge Road Atanic Safety and Licensing Board Hicksville, NY 11001 U.S. NLaclear Regulatory (tunission East-West Tower, Bm. 402A W. Taylcr "eveley III, Esq.*
4350 East-West Hwy.
liantcm & Williams Bethesda, to 20014 707 East Main Street Richnond, VA 23212 Dr. Jerry R. Kline*
Administrative Judge Cherif Sedkey, Esq.
Atomic Safety and Licensing Board Kirkpatrick, Icckhart, Johnson U.S. t&aclear Regulatory Cbmnission
& liatchison East-West 'Ibwer, nn. 427 1500 Oliver Building 4350 East-West Inty.
Pittsburgh, PA 15222 Bethesda, MD 20814 Stephen B. Iatham, Esq.
Mr. Frederick J. Shon*
John F. Shea, III, Esq.
Administrative Judge
'IWtunoy, Iatham & Shea Atemic Safety and Licensing Ibard Attorneys at Iaw U.S. Maclear Regulatory (banission P.O. Box 398 East-West 'Ibwer, Rn. 430 33 West Second Street 4350 East-West Hey.
Riverhesad, NY 11901 Bethesda, 60 - 20814 i
Atanic Safety and Licensing Board Panel U.S.14aclear Regulatory (bmnission m ahington, D.C.
20555
\\
s g
e 3
a 1 Atmic Safety and Licensing Stewart M. Glass, Esq.
Appeal Boerd Panel Regional (bunsel U.S. -Ntaclear Pagulatory (bmnissicm Federal Dnergency Management Agency Washington, D.C.
20555 26 Federal Plaza, Rn.1349 New York, New York 10278 Docketing and Service Section Office of the Secretary Secretary of the (%mnission U.S. M.aclear Regulatory (bmnission U.S. NLaclear Regulatory Washington, D.C. 20555 (bmnission Washington, D.C.
20555 Spence Perry, Esq.
Associate General Counsel Federal Dnergency Management Ager1cy Bernard M. Bordenick, Esq.*
Oreste Russ Pirfo lbom 040 500 C. Street, S.W.
Edwin J. Reis, Esq.
Washington, D.C.
20472 U.S. NLaclear Regulatory (bmnission Herbert H. Brown, Esq.*
7735 Old Georgetown Ibad Lawrence Coe Ianpher, Esq.
(to mailrom)
Karla J. Iatsche, Esq.
Bethesda, MD 20814 Kirkpatrick, Lockhart, Hill Christopher & Phillipe Fabian G. Palomino, Feq.
1900 M Street, N.W.
Richard J. Zahnleute, Esq.
8th Floor Wal (bunsel to the Goverror Washington, D.C.
20036 Executive 01 amber State Capitol Eleanor L. Frucci, Esq.*
Albany, New York 12224 Attorney Atmic Safety and Licensing Board Panel Ben Wiles, Esq.
U.S. t&aclear Regulatory (banission Assistant (bunsel to the Governor Bethesda, MD 20814 Executive Chamber State Capitol Gerald C. Crotty, Esq.
Albany, New York 12224 Counsel to the Governor Executive Chamber Jonathan D. Feinberg, Esq.
State Capitol Staff (bunsel Albany, New York 12224 New York State Department of Public Service f
James B. Dougherty, Esq.
3 Dnpire State Plaza 3045 Porter Street, N.W.
Albany, New York 12223 Washington, D.C.
20008 i
14
~
Stewart M. Glass Regional (bunsel for Federal Dnergency Management Agency l
l l
l n.
Y a I COURPESY OPI LIST _
7dward M. Barrett, Esq.
Mr. Brain R. McCaffrey Janeral (bunsel Iong Island Lighting Campany Iong Island Lighting Canpany Shoreham tbclear Power Station 250 Old (bunty Ibad P.O. Box 618 Mineola, NY 11501 North Oxmtry Ibad Wading River, NY 11792 Marc W. Goldanith
!!hergy laammarch Group, Inc.
MIB Technical Associates 400-1 ibtten Pond Ibad 1723 Hanilton Avenue Waltham, MA 02154 Suite K San Jose, CA 95125 Martin Bradley Ashare, Esq.
Suffolk County Attorney Ibn. Peter (bhalan H. Ime Dennision Bldg.
Suffolk (bunty Executive Veteran's Memorial Highway 03unty Executive /Imgislative Bldg.
Hauppauge, NY 11788 Veteran's Menorial Highway Hauppauge, NY 11788 Men Ibbinson, Esq.
N.Y. State Dept. of Iaw Mr. Jay Dunkleberger 2 M)rld Trade Center New York State !!hergy Office Ibom 4615 Agency Building 2 New York, NY 10047 anpire State Plaza Albany, NY 12223 Ms. Nora Bredes thoreham Opponents Q)alition 195 East Main Street Snithtown, NY 11787 Iman Friednan, Esq.
Costigan,' Hyman & Hyman 1301 Franklin Avenue Garden City, New York 11530
'D s'
'