ML20151N213

Summarizes Meeting W/Fema Re Discussion on How to Approach Conduct & Scheduling of Plant Exercise Guidance for Exercises W/O State & Local Govts.Related Info Encl

ML20151N213
Person / Time
Site:	05000000, Shoreham
Issue date:	02/11/1988
From:	Spessard R NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:	Jordan E NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
Shared Package
ML20151N202	List: ML20151N198 ML20151N213 ML20151N225 ML20151N242 ML20151N261 ML20151N276 ML20151N291 ML20151X071 ML20153G743 ML20154D013
References
FOIA-88-280 NUDOCS 8808080142
Download: ML20151N213 (33)

Text

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, UNITED STATES

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m -) NUCLE AR REGUL ATORY COMMISSION WAsWeG To N, o. C. 20555 l j

\,' / Februa ry 11, 1988 l

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NOTE TO: Edward L. Jordan, Director, AE00 g  ;

THRU: R. Lee Spessard, Director, 00A/AE00 FROM: Bernard H. Weiss, IRB/00A/AEOD

SUBJECT:

EXER'!SE GUIDANCE FOR EXERCISES WITHOUT STATE AND LOCALS l

At the meeting last week between NRC and FEMA we discussed how we would approach the conduct and scheduling of the Shoreham exercise. At that time it was decid-ed that Ed Podolak and Vern Wingert would develop general guidance for the FEMA )

regions for exercises that oo not involve State and local participation. This j would be in the form of what the objectives for such an exercise should be and 1 what additional guidance would be necessary for FEMA to conduct such an exercise. 1 I have not been directly involved in the development of this document alt.9ough I have spoken several times to Ed Podolak mainly on the subject of whether ' stand-ins" should be used in conducting the exercise. Podolak did ask me to attend a staff-level meeting on Wednesday, February 10, 1988 to defend my position that "stand-ins" are necessary for this exercise. I attended the meeting and argued ,

that the guidance should not necessarily, at this point, discount either position, I but the document could provide guidance for how this could be accomplished with '

"stand-ins" and without "stand-ins." Podolak argued that he would not do that because the wording in NUREG-0654, Rev. 1 (Enclosure 1) does not allow the use of "stand-ins". I am arguing that the wording is permissive and that "stand-ins" could be used, if necessary to to adequately evaluate exercise objectives.

At the staff level, we could not come to an agreement on this issue but we did agree that it should be escalated to you and Frank Congel. Congel callec me to make sure that you would be available on Friday to discuss this issue. Jackie and I have arranged a lunchtime meeting (12 Noon, Friday) to try to come to some resolution. Lee will also be available.

At that meeting we will be discussing the guidance that Podolak and Winge-t have already sent out to the FEMA regions for comment (Enclosure 2). I have s:me dis-agreements with the document, again, primarily related to the issue of "stand-ins."

On Page 2 of the guidance, the additional objective implies that it is possible to adequately demonstrate the capability of the LERO organization to interface with State and local officials, provide appropriate briefings, request apprcval of certain actions that affect the public, etc. "through the mobilization of utility liaisons." I submit that what is called for in the Shoreham exercise, in particular, is a comprehensive testing of all the procedures that !.ILCD has developed to accommodate the presence of State and local officials and not just their mobilization.

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l Edward L. Jordan February 11, 1988 On Page 3, Item 4.b. , there are instructions for how evaluators will make their evaluation of utility liaison personnel by interviews. I submit that this may be a valid tecnnique to obtain a general understanding of the capability of a response organization. However, it is my judgement that it is not the best way to conduct "the demonstration of offsite response organization capabilities to interface with non participating state and local government..." In order to most adequately demonstrate the utility response capability to interface with and accommodate State and local officials, particularly decisionmakers at the LEKO EOC, there needs to be someone there who the utility person wculd interact with to determine how well they do their job under p essure conditions and I whether this interfacing and accommodating interferes in some way with the I utility response. Such a person (not a "stand-in"; call him/her a controller) would ask simple questions and not make any decisions, i.e. , what do you want l the official to do?, what is the basis for this action?, what does the plan  !

say?, when will your analysis be ready?, brief me on the situation, etc. The l FEMA evaluator would observe this interaction. There is, of course, the long- I known downside to this approach, i.e., those individuals can be accused of asking the wrong questions or acting in an improper manner. Granted, but for some unknown reason this never came up in the first Shoreham exercise. The biggest problee with using the "evaluator-interview approach is that no matter how well the utility performs, the exercise may be considered inadequate because this aspect of the LILCO plan was not properly demonstrated.

CONCLUSION: The questit,n for the meeting should not be "stand-ins or no "stand-  !

ins." Rather, the discussion should be: is an evaluator interview adequate to l demonstrate portions of the LILCO plan related to interfaces with state and '

local government or does something additional need to be done to assure that the LERO organization is given an appropriate opportunity to demonstrate the full capability of their plan.

Original Signed by  ;

Bernard H. Weiss Bernard H. Weiss, IR8/DOA/AE00

Enclosures:

1. Page 24, NUREG-0654, Supp.1 2, 2/10/68 Memorandum from G. Petersen to FEMA Regional Directors ec: T. J. McKenna, AEOD Distribution:

R. L. Spessard, AE00 K. E. Perkins, AE00 B. ri. Weiss, AE00 IRB Reading File DOA Reading File

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OFC :I AE : E00:0:00 E00 :  :  :  :

/- e :RL S essard :  :  :  :

DATE :02////88 fal:02///88 :02//l /88  :  :  :  :

0FFICIAL RECORD COPY

1 i

Fce Comment M. Exercises and Orills 1

Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emer-  !

gency response capabilities, periodic drills are (will be) conducted to <

develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

1 Evaluation Criteria

1. a. An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency pre-paredness plans and organizations. The emergency preparedness exercise shall simulate an emergency that results in offsite radio- .

logical releases which will require response by of fsite response )

organizations. Exercises shall be conducted as set forth in NRC and I FEMA rules.

b. An exercise shall include mobilization of of fsite response organi-zation resources adequate to verify the capability to respond to an accident scenario requiring response. This includes the demonstration of offsite response organization capabilities to interface with non-participating State and local government, but does not include the use-of standins for the anticipated State and local response. The offsite response organization shall provide for a critique of the biennial l exercise by Federal and of fsite response organization observers /

evaluators. The scenario shall be varied from exercise to exercise .

such that all major elements of the plans and preparedness organiza-  !

tions are tested within a six year period. Each organization shall '

make provisions to start an exercise between 6:00 p.m. and 4:00 a.m.

Exercises shall be conducted during different seasons of the year. At least one exercise shall be unannounced.

2. A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular operation. A drill is often a component of an exercise. A drill shall be supervised and evaluated by a qualified drill instructor. The offsite response organization shall conduct drills, in addition to the biennial exercise at the frequencies indicated below:

a. Coenunication Drills 1

Coenunications between the licensee and the offsite response organiza-  !

tion within the plume exposure pathway Emergency Planning Zone shall '

be tested monthly. Communications with Federal emergency response organizations and offsite response organizations within the ingestion pathway shall be tested quarterly. Communications between the nuclear facility, offsite response organization's operations centers, and field assessment teams shall be tested annually. Communication drills shall also include the aspect of understanding the content of messages. If practicable, attempts should be made to include non-participating organizations in the monthly communications drills.

24 ENCLOSURE 1

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l DRAFT 2/10/88 l

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MIMotMDUM FOR: Regional Directors  !

Acting Regional Director l TRai Grant C. Peterson Assotista Director State and Local Prograss and Support SU5JICT: Ouidelines for Regious to Use In Implementing NUREG-0654/ FEMA-REP-1, Ray. 1 Supplement 1 l With Exercises ,

The attached guidelines are provided for your use in implementing ,

l the criteria of NUREG-0654/PEMA-REP-1, Rev.1, Supplement 1 for exercise preparation and evaluation wherein State and/or local governmenet decline to participate in emergency planning and exercises. l These guidelices are provided for your interia use, review and consent. l These guidelines will become Amendment 1 to Guidance Memorandua (GM)

EX-3, to be issued soon.

The catalyst for the development of these guidelines is the December  ;

7,1987, Atomic Safety and 1.icansing Board ruling on the adequacy of the Jamary 1986 Shorehan exercise. The crux of this ruling is that i this esartise did not meet WRC regulatory requirements for a qualifying l exercise under 10 CFR 50 Appendix 1.IV.F.1. These guidelines address  !

the issue of gualifying exercises for NRC licensing as well as any I axercises in which 8tata and/or local govertasents are not participating. I As stated above, this guidanse is intended only for those exercises in which State and/or local governments do not participate. The existing modular format should continue to be used in conjunttion with the evaluation criteria of Supplement 1. The modular format is being revised by Headquarters and will include a section on the use of Supplement 1. For now, the existing modular format should be need along with the evaluation criteria in Supplement 1 and this amendment for evaluating azercises where State and/or local goverusents do not participate.

Distribution of these interia guidelines and request for review and comments by TD(A vill be acceeplished through the normal procedures set forth for m's in W 17-1. Comments should be provided to FEMA Haedquarters by April 8,1988. Any questions concerning this matter should be addressed to Vern Wingert at 646-2872.

Attachesat .

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ENCLOSURE 2

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. i Attschsene h[ 02/10/88 GM 11-3 Amendment I 1

. Pursoss

1. his document. amor.ds the guidance in GM EX-3 for use with exercises of commercial nuclear power plants where State and/or local ,

governments decline to participate in the emergency pisaning and i exercises. Se emendnent delineates what constitutea en adequate demonstration of those exercies objectives pertaining to functions for which utilities are dspendent. upon State and/or local governments for legal aut:bority to carry out their amergency responsibilities. l This a:nendse=t will assist evaluators in determining the knowledge I and capability of the utili'ty offeite response organisation personnel ,

to advise and, assist State and local officials in implementing those portions of the offsite plan where State and local respsese is identified. '

2. nis amendment is linked to the planning standarde and evaluation criteria in WRIG-0654/FD(A-REP-1, Rev.1, Supp.1. l

3. nis amendment will address the application of the 35 exercise objectives of CM 11-3 to axercises in which State and/or local governments j which have not participated in energency planning procese do not '

participata in esercisse with utility.

Cuidanos

1. ne nature of the qualifying exercies te stated in .10 CF150, App. E. IV.

7. (1), "nis exercise shall be conducted within two years before the iguance of the first operating license for full power and prior to operation above 52 of rated power of the first reacter, and shall include portfcipation by each State and local govertment within the plume exposure pathway IPZ and each State within the ingestion expos-sure pathuey 172. *

- This rzertise will be used by YAC to maka its licensig decision.

- 10 CF150 etates "a f all participation esercise which taats as much of the liosasse, State and local emergency plans as is reasonably Kevoahle without sandatory public participation shall be conduct-e4 for eneh site at which a power reactor is located for which the first operating license for that site is issued af ter July 13, 1981.*

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2. For qualifying exercise under Supp.1., the utility must fully demonstrate i 35 exercise objectives. This coesists of 34 of the existing exeraise objectives in EX-3, plus an addition of one to incorporate evaluation  ;

criteria of Supp.1.

- Objective 35, unannounced and vf f-hours exercises, does not apply to a gus11f ying exerciso.

- A nov objective that parallels the Supp.1 guidance states, l

• Demonstrate the capability to interfaca vich non partialpating Stata  ;

and local governments through the mobilisation of utility offeits j response organisation persocool who would advise and essist non-l participatics State and local of ficials in carrying out their emerg- l ency res ponsibilitie s ." (N.1.b. , E. 6. , C.5.) I

3. Amoeg the 35 objectives to be demonstrated at a qualifying exercise, below {

is a list of those objectives that may be legal authority-sensitive,  !

dependicg upon the specific provisions of offsite plans being tested  !

a. Objective 11. Plume Protective Action Decisionmaking (J.10.u) l

b. Objective s 12, 13, 15. Alert, Notification and Energency Informatten

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l (5.6)

c. Objectives 16,17. Use of KI (J.10.e,f.)

d.

Objectives 18,19. Implenentation of Froteccive Actions (J.9., J.10.d. ,g. ,

s. Cbjective 20. Traffic Control (J.10.j. k.)

f.

Objectives (1,.4,L.S.) 23, 24. Hadical Services (Transportation and Facilities)

3. Objective 25. Decontamination (K.S.a..b.)

b. Objective 26. Suppler.entary Assistance (Federal /0ther) (C.1.a..b.)

1. Objective 30. Ingestion Exposure Pathway (J.P. , J.11)

j. Objective 32. Racovery, Reentry and Ralocation (Mel.)

4. The demonstration and evaluation of t$w above objectives sNuld be carried out in accordance with'the~ follhitinUnidelinesI r.. The demonstration and evaluation of the objectives should follow the specific provisions of the plan being tasted. For example.

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i 3 DRAFT I

the activation and deployment of utility offsite response organisation i

personesi should be performed at the energemey casesification level designated in the plan. Also, the issue of sect.;/ing authority by l the utility offsite respons organization should follow the proced- '

ur6s contained in the plan such as the general deputination of utility of fsite response organisation personnel or the ad hot securicg of authority on a case-by cas4 ba s:f.s.

b. Consistent "k

with the guidelines in Supp.1, evaluation criteria N.1.b.,

exercise shall include mobilization of of fsite response organlaat-los resources adequate to verify the capability to respond to an ace.ident scenario requir'ing response. This includes the demonstration of offsite response organization capabiMeies to interface with non-participating State and local government, but does not include the use of standine for the anticipated Scace and local response":

1). Contacts with State and local governsects shall be simulated 2.) Exercise evaluators may ask the utility offsite response organisation personnel questions regarding their functies '

and how they. intend to advise and assist State sad local offinials and they may raise other questions related to tbs suercise play.

Coordination This docusent has been coordinated with and concurred in by RC staff.

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p' D Federal Emergency Management Agency Washington, D.C. 20472 DRAFT Guidance Memorandua RX-3 MANACING PRE-EXERCISE ACTIVITIES AND POST-EXER PURPOSE This cuidance Memorandum (GM)'provides guidelinen for managing settin pre-exercise activities and poet-exercise Agency'gs Pregraa in support of the Federal Emergency Ianage  !

nAcxcmoown i

local governments to conduct joint exercises to test t REP plans approval of as thesea condition plans. The of initial and continued FEMA predecessor GM 17, dated January 8,1981, provided procedural guidance intended to improve the conduct of exercises and to establish greater l un;,formity among the FEMA Regions in this activity. While '

progress Regions. has been made, there is still diversity among uniformit exercises.y in preparing for, conducting and ausessing I

It supersedes the January 8, -

35 exercise August 5, 1983, objectives memorandum. contained in attachment 2 of the1981, GM 17 and the GUIDELIBER I. Pfa-omarclea Activity

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'Past'emperience has shown that joint exercises must be planned considerably in advance and each step scheduled.

milestones should be met, at a minimum.In These order to ens milestones frequency are predicated on the biennial exercise than bienn;ially, tr.e milestone time frames placed in parentheses should be used.

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XILESTONES EQR HIERCIER XYALDATION No Later Than -

DAyA Prior in Exarcise Recuired Action 90 days State and licensee jointly develop (75) and submit exercise objectives to l FEMA and Nuclear Regulatory l Commission (NRC) Regional Offices.

1 75 days FEMA and NRC Regional Offices (60) complete reviews of objectives and l extent of play after meeting with  !

licensee /8 tate, if necessary.

60 days State and licenses submit exercise (45) scenario to FEMA and NRC Regions for review.

45 days FEMA and NRC Regions contact or meet (35) with 8 tate and licensee to discuss modifications and complete the scenario. Agreed upon changes or modifications should be documented and distributed.

35 days (optional) Regional Assistance Connittee (RAC)

(30) Chair calls controller's meeting to develop coordination of exercise.

30 days  !

FEMA and NRC Regions develop l (25) specific post-exercise activity l schedule for debriefings and l meetings with the State. '

' - - 15 days The RAC Chair (and NRC team leader as- available) develops evaluator action plan (where stationed, how many from each organisation, what to look for).

The' product of this will be the exercise ovaluator packet which includes the specific evaluation location assignment. The packet should provides o Portions of the plan applicable to their assignment; 2

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A list of all exercise evaluators and their assignments; -

o A time-line of events; '

o scenario summary; o

scenario teobnical data as required for those assigned; o Past exercise findings; o Applicable controller messages; o Applicable reference materials; o Logistic information and o Log forms for taking notes.

1 day All Federal evaluators, both onsite and offsite, meet in the exercise  :

area to receive orientation and final instructions.

Exercise Day (RD) Conduct Exercise. Evaluators hold Exit Interviews with participants (at assigned locations).

ED+1 Evaluator Debriefing conducted by RAC Chair.

3D+1 or 2 RRC holds onsite Exit Meeting.i BD+1

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Public Meeting is held by the RAC chairperson and the Stat.e(s).

(Qualifying Exercise)

Participants RAC Chair. Meeting is conducted by (Continuing Approval Exercises)

ED+30 Draft FEMA exercise evaluation report sent "to state (s).

Report issued.

Whenever an exercise is scheduled, the Region should promptly assure construction of a time line based on the above allertones and make it available to the state, RAC Members, NRC Region, and PEMA Readquarters.

is located on a Regional boundary, the Region in which theWhere a plant 3

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l plant is actually located is considered the lead Region for purposes of scheduling, coordination and establishing the time line. Adhering to the time line should permit ample time to review and negotiate any changes to the exercise objectives and the exercise scenario. However, should delays occur which may affect the scheduled exercise date, the Regienal Director shall so advise the state, the NRC {

Region, the RAC Members, and FEMA Headquarters. The FEMA l Regional Office should make every effort to rectify slippage l in the timetable to avoid rescheduling the exercise date.

The objectives for the offsite portion of the exercise l should be taken from this document's list of 35 in Section '

III, Isarcise objectives. These exercise objectives functionally restate the intent of those evaluation criteria in 30 REG-0654/ FEMA-REP-1 that can be demonstrated and l observed in exercises. They are restated in order to f acilitate the use of these evaluation criteria for evaluating exercise performance. They also constitute the "major elements' of offsite emergency planning and l preparedness that are to be tested at least once every six  !

years as set forth in NUREG-0654/ FEMA-REP-1 evaluation '

criterion N.3.b. as revised in GM PR-1 (page 2). Therefore, the objectives should be selected in order to test all major elesents at least once every six years. Some objectives, because of their infortance to adequate emergency response, are to be included ;,n each biennial exercise for each i participating organization. This set of exercise objectives, referred to as the ' core objectives,' are listed in group A of section III of this document. The initial six-year period began on the date of the first joint exercite after November 3,1980, the effective date of the I NRC rule,10 CFR 50 (see GM PR-1). However, objective 9 is I new as Ete the milestone dates for exercise evaluation.

This new objective and the new milestone schedule should be implenestad with all joint exercises beginning in calendar year 1989.

-~~ . . The objectives for each exercise shall be reviewed by both the FERA and MRC Regional Offices before specific scenarios are written. Once reviewed, the State and licenses shall develop a scenario for submisalon which will include, at a minisses o the esercise objectives; ,

o Ibe date(s), time period, place (s), participating orgaalsetion(s) and extent of State and local government participation (i.e., full or partial);

o a time schedule of all key events;

• o Identification of simulated events and activities; .

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o A chronological narrative of exercise events and activities and o Appropriate radiological offsite release data with appropriate values for dose calculations, desimetry, field monitoring and meteorological data.

PIMA and NRC Regions will coordinate the review of the scenario and notify the State and licensee of any necessary modifications. If necessary, a meeting to discuss modifications should be held. If agreement cannot be reached, FEMA and NRC Headquarters assistance should be sought. .

II. Post-ererelse Debriefinen And Meetinam A. Three audience groups may be involved in post-exercise meetings:

1. Evaluators,

2. Exercise Participants and

3. Public/ Media.

• The timing and intent of the meetings may vary depending upon whether the exercise is conducted in advance of FEMA 350 approval (qualifying exerciee),

for continued 350 approval or af ter a remedial exercise.

B. The following chart illustrates post-exercise meeting requirements for qualifying exercises and

• exercises for continued FEMA approval.

ODALIFYING 31 00 IRE

@ NTINDID APPROVAL M tvaluator/ Participant Evaluator / Participant

. - - - Exit Interview -

Exit Interview Evaluator Debtigfing Evaluator Debtisfing Exercise Participants Exercise Participants Briefing Briefing Public Meeting Meeting'to which public and media are invited.

C. Guidance on each type of debriefing / meeting follows.

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l realuater/Partieinant hit interview fin .

! analifyina gd continued approval exercisas( i l

- Immediately following the conducrt of the exercise,  ;

an eneroise evaluator exit interview with the participants should be held at their assigned l  !

locations, as appropriate, to briefly provide a '

preliminary assessment of the esercise participants' strengths and weaknesses. No attempt should be made i to categorise exercise performance inadequacies as

' deficiencies' or ' areas requiring corrective l actions' (ARCA). Also no indication of a ' bottom line' finding on emerg,ency preparedness at these locations should, be made.

2. Evaluator Debriefines 8oon after the exercise, the RAC Chair should hold debriefings for all evaluators. These debriefings may be conducted by team leaders selected by the RAC Chair. The purpose of these debriefings is to secure accurate and cosJ1ete information from the evaluators per their ass:gnments to provide the RAC Chair with the basis for each finding as presented during the Exercise Participants' Briefing. During this same period the IRC team leader conducts a parallel meeting w,ith the NRC evaluators of onsite performance in the exercise. l I

If exercise deficiencies are indicated which would l trigger remedial action, the RAC Chair shall report '

same to FEMA Headquarters by telephone, per GM Ex-1. l Following the RAC Chair's telephone contact with  !

FanA teadquarters, this debriefing can serve as the initial step in the consultation process required in CE II-1.

3. Extraine Particinanta Briefine [fg ana11fvine g aa=+inu ed-ano r oval anareimani .

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a. As soon as possible af ter their independent interviews, the RAC Chair and the NRC teaa

. leader should meet to coordinate and arrange for Federal participation in the joint Exercise Participants' Briefing.

A within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the completion of an esercise, a briefing involving the exercise prticipants, RAC Chair,- NRC representative and -

other RAC members and Federal. evaluators, as appropriate should be preliminary, results of the heldexercise. to discuss the This nelefing should be held in accordance with 44 crA 350.9(a) and (d).

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c. Recommended agenda to be used is as follows:

i 1)

Review of onsite actions presented by NRC; 11)

Licensee presents their views (clarifying questions or comments);

111) Review of offsite actions by RAC Chair;

17) State and local governments present their views (clarifying questions or comments);

v) Review of Federal response (if applicable) by RAC Chair and

11) Opportunity for clarifying questions or comments by licensee, state and local )

governments. i I

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d. The presentations should comprise a brief, integrated overview covering the highlights ,

of the exercise. Included in the

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presentation should be appropriate I commendation s for good performance and a preliminary a(ss)essment of the participants' I strengths and weaknesses. At this stage i no attempt should be made to categorise exer,cise performance inadequacies as 'deficienclos' or AncA's. Also, no indication of a ' bottom line' finding should be made as to whether state or local preparedness is adequate.

e.

As soon as possible af ter this briefing, the RAC Chair, through the consultation process, should provide the state with a tentative identification of the exercise inadequacies, if any, by classification, i.e.,

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' deficiencies' and ARCA's. A indication of a "bottom line' gain, no should finding {

1 be made as toiswhether

.pceparedness 8 tate or local adequate.

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4. Pubile Meeting Jfgg qualifying erarelseni

a. A mblic meeting in accordance with 44 CPR 35b.10 should be held 'as soon as-possible af ter the exercise in the vicinity of the suelear power facil.lty. This meeting shall be withnoticed 44 CFRin the local media in accordance 350.10. Exercise participants, -

representatives from the NRC and other appropriate should attend. Federal, State and local agencies 7  !!

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i b.

! The meeting should acquaint members of the public emergenc with appropriate state and local exercise,yincluding plans and the results of the-strengths and weaknesses observed. The meeting should also answer any questions about FEMA's review and evaluation, and receive suggestions from the public for improvements or changes.

c. During this Public Meeting an assessment of the exercise participants' performance should be made. The timing of the P!:blic Meeting with relation to the post-exescine etw1uation procedures will dictate the degree to which i l

the RAC Cheir participants' can perf address the exercise ormance. When the consultation process has progressed to the point of agreement on the degrees of inadequacies in the exercise participants' ,

performance, these inadequacies can be l 61scussed in their groper categorization, i.e., "deficiencies and ARCA's. When an, agreement on the inadequacies in the exercise participants' performance has not been  !

reached, discussions should be more general, 1.e., i in terms of strengths and weaknesses.

d.

For situations in which a Public Meeting has I been held during the 350 approval process and, thereafter, a plan amendment is submitted which significantly changes th context or nature of the planning (e.g., e a change in the emergency planning sone (EPI) results in the inclusion of additional jurisdictions], the FEMA Regional Director shall determine whether the amendment necessitates holding another Public Meeting.

5.

Meeting int continued ZMA Anpreval Exercisaq

a. _ Po11owing an exercise for continued FEMA approval, a meeting ihvolving exercise participants, representatives from the NRC, other appropriate Federal agencies, the public and the media should be held in accordance with_44_CFR 350.S vicinity of the nuclear power (e) in the meeting shall be noticed in the local facility. This newspaper with the largest circulation in the trea, or other media as the Regional Director may exerciseselect, date.within five to seven days of the -

At the discretion of the hegional Director, this meeting may be ,

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• 1 combined with the exercise participants briefing.

b. The pblic and media may attend the meeting as observers. At the discretion of the i 1

Regional Director, written quettions from the public and media may be submitted at or af ter the meeting for consideration in the exercise evaluation. The Regional Director may further use his/her discretion to solncit and respond to oral questions and comments during this meeting. Under no circumstances should  !

it be indicated whether state or local preparedness is adequate or inadequate.

c. During the meeting, the RAC Chair should offer an overview of the exercise and should provide his/her observations. Comments from the RAC members and FEMA evaluators may be -

solicited at the discretion of the RAC Chair.

6. 'Maetinan' far amarelman condue_ted durino lig l anpraval procang Requirements in 44 CFR 350 l

do not address the conduct of 'neatings' for I exercises, held after the initial qualifying l exercise but before the completion of the 350 l approval process. For such exercises, a neeting as described in 350.9(e), i.e., a meeting conducted for continuing FEMA approval i exercises, should be held. FEKA's evaluation I of such 'interia' exercises is an integral part of FINA's overall 350 approval :nocess. Again, l the Regional Director may exerchse further I discretion by giving the public and the media an opportunity to orally discuss the performance of the exercise and the preliminary evaluation. ,

7. 'Nameinaa' af ter renadial exercisant After renetial exercises required under 44 CFR 350.9(a) and, 9(c)(5), it is necessary to hold a debriefing (iten II.C.2. above) and may be necessary to hold -

a meeting (iten II.43. above). Because remedial actions may vary from remedial exercises i

involving many organizations to drills including only one.or..two organisatlons, discretion is given to the Regional Director to determine the need to convene a meeting to which the public and media are invited, in accordance with 44 CFR 350.9(e).

4 e

III, Exareina Objectiven l

l The fo11ovins list of 35 exercise objectives is to'be incorporated into the design of RIP exercises. These objectives are correlated to the original 35 exercise objectives from the Aug:st 5,1983, memorandus by the numbers provided in parentheses following the text of each objective.

The objectives are presented in three groups. Group A, numbers 1-15, are "core objectives' that are to be demonstrated in each biennial exercise. Core objectives represent fundamental energency preparedness capabilities needed by all organizations for effective response to radiologleal energencies. These objectives are scenario independent and, therefore, need to be demonstrated by all organisations in each biennial exorcise. For all 35 objectives,.tbe need for organiss;tiens to demonstrate these capabilities is dependent upon their assigned plan responsibilities.

Group 3 objectives, numbers 16-25, also represent fundamental radiological emergency response capabilities and should be demonstrated in each biennial exercise. However, these objectives are scenario dependent and any only impact i some organisations. Scenarios should be varied froa l exercise to exercise to ensure that these objectives are i demonstrated by each appropriate offsite energency response organisattes at least once every six years. Some organisations may need to demonstrate these objectives more frequently because of factors such ass (1) Geographical l location and size of jurisdictions, (2) use of 360 degree l ovacuaties for a significant part or all of the plume Energency Planning tone and (3) need to retest capabilities previously evaluated as areas requiring corrective action.

If the Presence of such f actors causes an undue hardship for l an organisation, appeals may be made to FEMA Regional Directors asaer 44 CFR 350.9(c) to seek relief from having

__ _ _. . . to 6encestrate some of the Group B exercise objectives more than esce every six years.

Group C objectives, numbers 26-35, while not as critical as l the more primary and time-sensitive Group A and 3 objectives, also represent important energency preparedness capebilities. For example, the ingestion-related objectives (19-31) inslade functions that generally would not have to be laplananted immediately to Protect public health and safety. troop c objectives need only be demonstrated once every six years.

10

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Bach of the exercise objectives in Groups B and C shoulo be demonstrated during an exercise within the initial six-year period and then tracked individually to ensure inclusion in l exercises within air-vaar intervala. For example, if the initial six-year period for an offsite response or begaa June,1982 and a shift change (Objective 33) ganisation was demonstrated during the June,1984 exercise, this objactive must be demonstrated again at the latest by the end of calendar year 1990.

ggggy, & - ggEE CBJECTIVES THAT A33 SCENA1IO INDEPENDERT

• NUREG-0654/

QBJECTLYE 1 FEMA-RRP-1 EMERGENCY t'tAESIFICATION LEVELA I l

1. Demonstrate the ability to monitor, D.3.4.

understand and use emergency classification levels (ECL) through the appropriate implementation of emergency functions and  ;

activities corresponding to *CI.'s as i required by the scenario. The four ECL's ares j

Notification of unusual event, alert, site  !

area energency and general emergency.

MOBILIIAYIQI Qt, RMERGENCY DERSOMMEL

2. Demonstrate the ability to fully alert, E.1.,

mobill e, and activate personnel for both E.2.

f acility and field-based emergency functions. (see objective 31 for 24-hour, continuous staffing function within a six-year time frame). (1)

DIRECTIQI &Eg pfalTROI4

3. Demonstrate the ability to direct, coordinate A.1.d.,

and control emergency activities. (3)

A.2.c.

COMMUNICATIONS

4. Demonstrate the ability to communicate with F.

all appropriate locations, organisations and f: eld personnel. (5) (not F.1.f.)

---

- FACILITIES 20DIPMENT AHR DIGPLAYS

5. Demonstrate the adequacy of facilities, G.3.a.,

equipaent, displays and other materials to R 2.3.

support energency operations. (4) '

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. '. l EMERGENCY 1Q2113 EXP0$t!EE CQNTRO4

6. Demonstrate the ability to cou.:Inuously K.3.a.b monitor and contrel emergency worker exposure. (20)

FIELD RAD 10 LOGICAL MQHITORI]tfs

7. Demonstrate the appropriate equipment and I . 8.,

i procedures for determining field radiation I.11.

measurements. (7)

8. Demonstrate the appropriate equipment and I.9.

procedures for the measurement of airbor e radiciodine concentrations as low as 10 microcurie per ec in the presence of noble gases. (8)

9. Demonstrate the ability to obtain samples of I.10 partienlate activity in the airborne plume and promptly perform laboratory analyses so that projections can be made of the area requiring relocation. (This objective has relevance to making reentry decisions, Objective 32.) (New objective) t PLUME 3081 pea 15CTION

10. Demonstrate the ability, within the plume I.10.

eyposure pathway, to proje punio via plume exposure,ct dosage to the based on plant and field data. (10) m ytoT3CTIII ACTICM McIBIONMARTwo

11. Demonstrate the ability to make appropriate J.10.a.

protective action decisions, based on projects 4 or actual dosage, EPA PAO's,

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availability of adequate shelter, evacuation time estimates and other relevant factors. 00)

ALRRt unirISTION ARQ EMERGENCY INFORMATION

12. Deseastrate the ability to initially alert the E.6.

oublic within the 10-mile EPI and begin hissestastion of an instructional message witMn ~~ ~

15 ciantes of a decision by appropriate state and/or lecel official (s). (13) 12 '

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- . 3:c res e rw as 1 7. , 3

13. Demonstrate the ability to coordinate the 3.5.

formulation and dissemination of accurate 0.4.b.

' Information and instructions to the public in a -

timely fashion after the initial alert and notification has occurred. (14, 25)

14. Demonstrate the ability to brist the media in G.3.a.,

an accurate, coordinated and timely manner. G.4.a.

(24)

15. Demonstrate the ability to establish an5 G.4.c.

operate rumor control in a coordinated and tlaely fashion. (26) ,

GROUP R - SCRRARIO-DEPENDENT OBJECTIVER E A X Q F. 1 1

16. Demonstrate the ability to make the decision J.10. e. f.

to recommend the use of KI to emergency workers and institutionalised persons, based on predetermined criteria, as well as to distribute and administer it once the decision is made, if necessitated by radiolodine releases.

(21,22)

17. Demonstrate the ability to make the J.10.2 decision, if the State plan so specifies, to reconnend the use of II for the general public, based on predetermined criteria, as well as to distribute and administer it once the decision is made, if necessitated by radiciodine releasse (21,22)

SPLEMENTATION QF. PROTECTIVE ACTIONE

18. Demonstrate the ability and resources necessary J.9.,

to inPlenent appropriate protective act. ions 0.10.d.g.

. _ _ _ . for the impacted plume RPI population, i (including transit-dependent persons), special j needs populations, handicapped persons and institutlonalised persont. (15) 1

19. Demonstrate the ability and rasources 0. 9. ,

necessary to implement eppropriate protective J.10.g.

acticas for school children withih the plume EP5. (19) -

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, TRAFFIC CONTROL

' 20. Demonstrate the organisational ability and 5.10.j .k.

resources necessary to control evacuation traffic flow and to control access to evacuated and sheltered areas. (16,17)

RELOCATION CRETERE fRROIBTRATION 1 gagg Ag onc0NTAMIMATION) MONITORING. CONGREGATE {

21. Demonstrate the adequacy of procedures, J.12.

facilities, equipment and personnel for the registration, radiological monitoring and decontamination of evacuees. (27)

22. Demonstrate the adequacy of facilities, J.10.h.

equipment and personnel for congregate care of evacueen. (28)

MEDICAL SERVICES (?RAMEPORTATIQR AND FACILITIES)

23. Desonstrate the adequacy of vehicles, L.4.

equipment, procedures and personnel for transporting individuals. contaminated, injured or exposed (30)

24. Demonstrate the adequcey of hospital facilities L.1.

equipment, procedures and personnel for handling contaminated, injured or exposed individuals. (31)

BECOMTAKIMA?f0M

25. Demonstrate the adequacy of facilities, E.5.a.b.

i equipment, supplies, procedures and personnel for decontamination paent and vehiclesof emergency workers, and or waste disposal. I gaggE C - Q2EER NB380T2VE81 ggggg arr-YnAms 2Q B3 DEMONSTRATan A2 LEA 82 QHCA 3pppLaninTARI 184ISTANCE f PEDERAf./0THER)

16. Demonstrate the ability to identify the need C.1.a.b.

for and call upon Federal and other outside support agencies' assistance. ( 3 2 ) - - - - -- -- - - - - - - -

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, .  :... :: .::.: cw -:- .. .a . 2, g INGESTION EXPOSURS PATHWAY l .

27. Demonstrate the appropriate use of equipment 2.6.,

and procedures for collection and transport J.11.

of samples of soil, vegetation, water, and milk. (9)

28. Demonstrate the appropriate lab operations C.3.,

and procedures for measuriat and analysing J.11.

samples of food crops, milk, seat poultry, water and animal feeds indigenous,to the area.

(9)

29. Demonstrate the ability 'to projech dosage to I.30.,

the public for ingestion pathway exposure and J.9.,

determine appropriate protective measures. J.11.

(11)

30. Demonstrate the ability to implement both J.9.,

l preventive and emergency protective actions J.11.

for ingestion pathway hazards based on field data, FDA PAG's and other relevant factors.

(12)

RECOVERY. REERTRY AH]2 MOCATlQB i

31. Demonstrate the ability to estimate total M.4.

popaletion exposure. (34)

32. Dcaonstrate the chility to determine and M.1.

implement appropriate nivesures for controlled reentry and recovery based on estimated total 1 population exposure, available EPA PAG's and other relevant factors. (35) 1 MOBILItATIDI DE IMERGENCY PERE 010fRL 124-RoDa- CONTIR

33. Demonstrate the ability to mainte.in. staffing A.1.e.,

on shiftachange.

continac"? . *'-M"n&se i- W -- et"-1 *'

(2) tyAcar.21Q3

, Qf, OMSITE PERSONMEI 3

34. Demonstrate the ability to coordinate the B.6 avacuaties of onsite personnel.

(23) J 2.

35. Demonstrate the ability to carry-out-emergency----~ ~

response functions (i.e., activate EOC's, moblline staff that report to the 50C's, establish communications linkages and complete telephone call down) during an unnannounced off-hours orill or exercise.

15 f

'. IV. CORRELATf 0N QZ EXERCISE OBJECTIVE 2

As set forth in 44 CFR 350.2(j)(k), there are two levels of participation in exercises, full and . partial partici tion.

In demonstrating exercise objectives 1n tall partici tion both facilitythe exercises, and objectives should be fully demonstrat d in field operations. In demonstrating exercise objectives in partial participation exercises, the objectives should be fully demonstrated in all facilities while field operations may be simulated.

v. IMPttMENTitrox The provisions of this GM should be ieplemented 120 days from the date of this memorandum. Thece are two exceptions to this isplementation tirte frames milestone dates (e.g., from 75 days to(1) The expanded 90 days) initial allestone and (2) exercise objective 9. for the These should be implemented in all joint exercises to be held beginning in calendar year 1989.

VI. C00RDINAYIDN l

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l This GM has been coordinated with and concurred in NRC staff.

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1. Revision 9, RAC comments

2. Revision 10, highlights

3. Outside Organization Participation Expectations

a. New York State - /\c,c j

b. Suffolk County <% ,c. 4 ,

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School Districts- f.1,$([j, [ '

d. Nassau County w, . x . #

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American Red Cross _f Other Federal Participati

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Schedule (GM EX-3 Milestones)

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5. Other Deliverables AQ m Q

6. FEMA needs from LILCO prior to exercise c{ N '.

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LILCO needs from FEMA prior to exercise

8. Schedule next meeting fifI "

• 9. June 1988 Graded Exercise Planning

a. Exercise Scope (GM EX-3)

b. Exercise Objectives

c. Exercise Duration

d. Prompt Notification System (REP 10) l

e. Public Education (Brochure / Survey) (REP 10) 1 f.

Field Demonstrations (In/Out of Sequence, Required Resources)

• 10.

Exercise Scenario Rad./ Met./ Protective Action Requirements

• 11.

Government Interface (NUREG 0654 Supplement 1) not for discussion with potential exercise participants

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BRIEFING NOTES FEMA APF.:L 8,198d MEETING WITH LILCO REGARDING CONDUCT OF 'IHE SHOREHAM EXERCISE I

EXERCISE APPROACH As in first Shoreham exercise, NRC will provide support to FEMA in conducting certain aspects of the exercise because of the non participation of State and local authorittes.

Cffsite Controller Staging Areas Field Monitoring Teams LERO EOC Emergency News Center Other Offsite Emergency Response Facilities Control Cell (s)

Telephone Communications Liaison Interfaces o

NRC will be more active in developing the exercise objectives, extent of play, evaluation plan, and control plan than in the previous exercise.

• • Make a determination if LILCO offsite exercise objectives are adequate to be "qualifying exercise" under NRC rules.

• • Review extent of play parameters and provide comments to FEMA.

• • Participate in FEMA /LILCO meetings in the development of the evaluation plan and the extent of play.

• • Eevelop the offsite control plan and head up the of f site control activities.

O NRC resources that may be required.

• • Based plan and oncontrol initial plan discussions. Will be refined further as evaluat on is developed.

• • Representatives f rom AEOD and NRR will be involved essentially full-time until the exercise.

• • 15 or more EXPERIENCED staf fers from HQS and the regions will be required at the exercise as controllers.

• • Some preparation time for controllers (1-2 days) at their offices.

• • Controllers will spend 3-5 days at the Shoreham area.

The manner in which .he LERO interface with non par :ipants will be evaluated will use the following guidance:

• • Intent of evaluation is to observe those aspects of the LERO plan for which procedures have been. developed to interface with non participatir.g Suffolk County and New York S. ate officials. No satisfactory method has been identified to evaluate a non participating response.

• • LERO EOC responders will call control cell when they need to communicate with Suffolk County or New York State officials to request legal a;thority, when procedures require, and/or when updates are appropriate.

• • Controller will ask suf ficient questions, as necessary, to fully understand requested. what is being told and/or to give LE.;.0 the authorityW

• • Controller will give LERO limited authority to carry out the '

particular request, NOT general authority.

• • LERO Liaisons will go to a location and interf ace directly with controllers in a manner similar to above.

• • Consider the possibility of having the ASLB review this approach for adequacy?

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ANTICIPATED PARTICIPATION EY OUTSIDE ORGANIZATIONS

• LILCO will send registered letters enortly to all outside organir.ations (15;i requesting their participatior. in the exercise, o New York State - No participation.

o Suffolk County - No participation.

• Nassau County - No participation.

O Scheol Districts - Wading River expected to play. Others are not. LILCO is assuming these are non participating government entities.

o Connecticut - Staff is cooperative and willing to play.

Seeking permission from Governor, o Special Facilities

- Most are not cooperating. Expect at least one of each category.

o Dept. of Energy - Brookhaven Lab will play fully.

• US Coast Guard - Expect cooperation. Not sure what effect Coast Guard budget cuts will have, o American Red Cross - Not cooperative. Uncertain whether they will play.

Other Federal Agencies - LILCO may send letter to NRC and FEMA requesting participation in the exercise play.

• Based on LILCO comments at April 8, 1988 meeting.

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H_hEHAM MILESTONE DATES AFFECTIS; NRC 1

April 15 FEMA snd NRC Regional offices complete review of offsite exere se objectives.

april 18 LILCC will submit exercise scenario t: FEMA and NRC along with propcsed extent of exercise play.

April 21 FEMA v;'1 submit RAC approved offsite objectives to NRC for deternination of "qualifying exercise under NRC rules.

April 29 NRC :: provide FEMA with response on  !

qualifying exercise.

)

April 29 Next :heduled meeting of FEMA, LILCO and NRC for exercise plann;ng.

May 3 FEMA vill provide NRC with their plan for extent of exercise play.

May 10 NRC and FEMA will provide comments to FEMA RII regarding extent cf play, l i

May 15 Last revisions of LILCO plan that will be accepted by FEMA 1 before the exercise. l 1

May 17 or 247 Expected last Shoreham drill before the exercise.

June 14 Shorehun exercise.

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OTHER ITEMS LF INTEREST AND CONCERN Some of these activities are expected to be conducted at the Ieabrook exercise.

The Shoreham exercise will be 3 days:

Day 1 - Plume exposure activities Day 2 - Ingestion pathway activities 1 t

Day 3 - Reentry / Rec ery activities ,

i Reception centers are now plar.ned to be on LILCO property. Because of legal issues, receptionwill centers. For exercise, center set trailers cannot be put at these reception the reception center area withoutup as much of activities as pcssible at evaluate the reception center trailer trailers for evaluation operations at otherand then location.

According to FEMA policy, FEMA RI will evaluate any State of Connecticut participation, 1 l

All of the sirens will be rung, I be evaluated during the exercise.although it is doubtful that they will  !

i In accordance distribute with "realism",

ingestion brochures,LILCO will expect New York State to l

will be included in Rev. 10. as necessary, after an emerger.:y. This I l

The current RAC Chairman, Ihor Husar, I the designation of a new RAC Chairman vill be made by April 15has been prom i

that both groups involved in a shif t change have to make protective action recommendations.

i This is causing LILCO some concern. i 1

LILCO has offeredand LERO organization to provide any Federal group with a briefing on the operations. l 1

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