ML20196B087
| ML20196B087 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/01/1988 |
| From: | Cumming W Federal Emergency Management Agency |
| To: | NEW YORK, STATE OF |
| References | |
| CON-#188-5518 OL-3, NUDOCS 8802080032 | |
| Download: ML20196B087 (23) | |
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55/f RELATED CORREspounggggg February 1, ) @@@.;E TEC' tbNRC UNITED STATES OF A'iERICA NUCLEAR REGULATORY COMMISSION
'88 FEB -4 A10:34 Before the Atomic Safety and Licensing Board 0FF!CE OF ECnsAv g
00CKEimG a ::avict; s
BRANCH k
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
Shoreham Nuclear Power Station, Unit 1)
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FEMA'S FIRST RESPONSE TO NEW YORK'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS AND FIRST SET OF INTERROGATORIES TO FEMA CONCERNING CONTENTION 25.C--ROLE CONFLICT OF SCHOOL BUS DRIVERS I.
FEMA hereby responds to the NEW YORK STATE Interrogatories and Request for Production of Documents served on January 23, 1988.
All documents referenced in these answers are provided with these responses to the extent that FEMA has no objection to their production.
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II.
By responding to these Interrogatories FEMA does not waive its objections (1) to the method of service; (2) to the fact that FEMA is called on to respond for other federal agencies and their contractors; (3) to the f act that FEMA is not subject to formal discovery under the NRC rules and regulations and the FEMA-NRC Memorandum of Understanding dated April 18, 1985; and (4) to the fact that FEMA does not by responding indicate that discovery for all parties in this proceeding with respect to FEMA is not governed by Ions Island Lighting Company (Shoreham Nuclear Power Station, Unit 1),
ALA3-773, 19 NRC 1333 (1984).
III.
FEMA objects to any or all interrogatories addressed to on-site matters.
IV.
FEMA objects to any interrogatories that may be considered to request information protected by the attorney-client privilege or the attorney work-product doctrine.
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V.
FEMA objects to all interrogatories insofar as they purport to require information outside the possession, custody or control of FEMA or require FDIA to answer based on documents not prepared or requested by FBiA personnel or contractors, or not considered official records of FEMA.
Based on a conversation with the Deputy Special Counsel, FEliA has attempted to canvass other Region II REP plans outside New York State to be responsive to these interrogatories.
VIII.
FEMA objects in general to the interrogatories as being overly broad, unduly burdensome, and designed to gain information not relevant and not material to this proceeding.
FEMA enters this objection for each and every interrogatory and will for economy not restate the objection in each answer.
IX.
FEMA Counsel has also instructed the Counsel for the Applicant that no documents prepared at the direction or request of FEMA officials, employees, or its contractors may be released without FDIA Counsel being given the right of review and inspection and the opportunity to enter appropriate objections.
X.
FEMA notes that many of its objections are premised on the need to protect in the discovery process its deliberative process based on the request dated January 27, 1988, by NRC for FEMA to review Revision 9 of the SNPS Local Offsite Radiological Emergency Response Plan (Copy furnished with these responses).
XI.
FDIA response to the first interrogatories consists of (1) this general response by FEMA counsel; (2) the numbered answers to the Interrogatories; (3) the Declaration of Margaret Lawless and (4) referenced documents not objected to by Counsel and (5) the appropriate service list.
Respectfully submitted, k.
William R. Cumming
--[
Counsel for FEMA Dated at Washington, D.C.
this 1st day of February, 1988
Interrogatories and Document Requests 1.
When bus drivers for nuclear plants other than Shoreham are trained to drive buses during radiological emergencies, what, if anything, are they told, on a plant by plant basis, about caring for their families in emergencies?
FEMA Response _:
FEMA has no specific information on bus driver utilization during radiological emergencies beyond that contained in specific plans. All plans are submitted to NRC for its public document room, and are available for inspection.
In New Jersey, bus drivers for the general public live outside the Emer3ency Planning Zone (EPZ) of both New Jersey nuclear power plants with their families and are generally State employees. Thus, no specific steps are necessary for care of their families.
At Artificial Island, except for Salem City, all school population bus drivers are local, i.e. live within the EPZ. At Oyster Creek, all school bus drivers are also local, i.e. live within the EPZ. With respect
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to these l'ocal school bus drivers, according to officials of the New Jersey Office of Emergency Management, care for other family members during a radiological emergency at the nuclear power plants has never been raised as a subject of concern in any driver training. Therefore, they have made the assumption that appropriate arrangements have already been made.
2.
Do any radiological emergency response plans for nuclear plants other than Shoreham rely either fully or partially on utility employees to drive buses for school children? If the answer is affirmative, please identify the particular nuclear plants and the relevant pages of the corresponding radiological energency response plans.
FEMA Response:
the According to officials of the New Jersey Office of Emergency Management, State of New Jersey does not use utility employees as bus drivers. Also, see answer to Interrogatory 1 above.
~3.
Has the NRC or FEMA ever met (on or about January 14, 1988 or at any other time), or engaged in telephone conversations or discussions, with LILCO regarding in any way LILCO's schools evacuation proposal? If the answer is affirmative:
(a) identify the dates and locations of the meetings or the dates of the telephone conversations or discussions; (b) identify all attendees or participants; (c) specifically describe all statements that were made about LILCO's schools evacuation proposal; (d) attribute all such statements to particular individuals; and (e) provide any documents that concern LILCO's schools evacuation proposal that were produced in preparation for, during, or as a result of the meetings, telephone conversations or discussions.
FEMA Response:
FEMA has not met with NRC on the LILCO School evacuation proposal, nor has it had phone conversations.
4.
Provide a copy of all docunents used in preparing the answers to these interrogatories.
, FEMA Response:
FEMA testimony on role conflict previously provided in this proceeding is attached. No other documents have been relied upon in this response.
5.
List, on a numerical interrogatory by interrogatory basis and on a lettered subpart by subpart basis, all people who were asked to provide information or documents in response to:
(a) this pleading; (b) the pleading submitted by Suffolk County entitled, "Suffolk County's First Set of Interrogatories and Request for Production of Documents to the NRC Staff and FEMA," dated January 4, 1988.
FEMA Response:
Counsel for FEMA provided copies of the New York State and Suffolk county Interrogatories and Document Production Requests to the Natural and
-Technological Hazards Division of the State and Local Programs Directorate and FEMA Region II.
Specific individuals contacted included Phil McIntire, Ihor Husar, Margaret Lawless, Joseph Keller of Idaho National Engineering Laboratory, Dr. Thomas Baldwin of Argonne National laboratory, and Ralph Swisher of the FEMA Office of Civil Defense.
These FEMA responses to New York's Interrogatories have been made by me, Margaret Lawless.
I am employed by FEMA in its Office of Natural and Technological Hazards Programs of the SLPS Directorate.
In the performance of my duties I am the liaison between the Office of General Counsel and FEMA Region II on the OL-3 proceeding.
I hereby affirm, subject to the penalty of perjury, that the foregoing responses are true and correct to the best of my knowledge and belief.
Margar t Lawlek's/
Emer acy Management Specialist February 1,1988 i
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J 00CgTED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Qif!."g, "* i n,, e In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3 (Shoreham Nuclear Power Station,
)
Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of "FEMA RESPONSE TO NEW YORK'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS" in the above-captioned proceedings have been served on the following by deposit in the United States mail, first class, this 1st day of February,1988:
James P. Gleason, Chairman G. Palomino, Esq.
Shoreham OL-3 Proceeding Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Wachington, D.C.
20555 Albany, NY 12224 Oscar H. Paris W. Taylor Reveley III, Esq.
Administrative Judge Hunton & Williams Atomic Safety and Licensing Board 707 East Main Street U.S. Nuclear Regulatory Commission P.O. Box 1535 Washington, D.C.
20555 Richmond, VA 23212 Frederick J. Shon Jonathan D. Feinberg, Esq.
Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Empire State Plaza Washington, D.C.
20555 Albany, NY 12223
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John H. Frye, III,-Chairman Dr. Jerry R. Kline Atomic Safety and Licensing Board Atomic Safety and Licensing Board
-U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
. East-West Towers, Rm. 430 East-West Towees, Rm. 430 4350 East-West Hwy.
4350 East-West Hwy Bethesda, Maryland 20814 Bethesda, MD 20814 Stephen B. Latham, Esq.
John F.-Shea, III, Esq.
Christopher M. McMurray, Esq.
Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.
Attorneys at Law David T. Case, Esq.
P.O. Box.398
-Kirkpatrick & Lockhart 33 West Second Street 1800 M Street, N.W.
Riverhead, NY 11901 South Lobby-9th Floor Washington, D.C.
20036-5891 Atomic Safety and Licensing Board Panel Joel Blun, Esq.
U.S. Nuclear Regulatory Commission Director, Utility Intervention Washington, D.C.
20555 NY State Consumer Protection Board Suite 1020 Atomic Safety and Licensing 99 Washington Avenue Appeal Board Panel' Albany, NY 12210 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Monroe Schneider North Shore Committee P.O. Box 231 Docketing and Service Section Wading River, NY 11792 Office of the Secretary U.S. Nuclear Regulatory Commission RAC Chairperson Washington, D.C.
20555 Federal Emergency Management Agency 26 Federal llaza Spence Perry, Esq.
New York, New York 10278 General Counsel, Rm. 840 Federal Emergency Management Agency 500 C Street, S.W.
Washington, D.C.
20472 Robert Abrams, Esq.
Attorney General of the State Alfred L. Nardelli, Esq.
New York State Dept. of Law Attn:
Peter Bienstock, Esq.
120 Broadway Department of Law 3rd Floor, Room 3-118 New York, N.Y Two World Trade Center 10271 Room 46-14 New York, NY 10047 MHB Technical Associates General Counsel 1723 Hamilton Avenue Long Island Lighting Company Suite K 250 Old County Road San Jose, CA 95125 Mineola, NY 11501
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l County Executive Martin Bradley Ashare, Esq.
Suffolk County Executive Suffolk County Attorney County Executive / Legislative Bldg.
H. Lee Dennison Building Veteran's Memorial Highway Veteran's Memorial Highway Hauppauge, NY 11788 Hauppauge, NY 11788 Mr. Jay Dunkleberger Ms. Nora Bredes New York State Energy Office Shoreham Opponents Coalition Agency Building 2 195 East Main Street Empire State Plaza Smithtown, NY 11787 Albany, New York 12223 Ellen Blackler Mr. Robert Hoffmnan New York State Assembly Ms. Susan Rosenfeld Energy Committee Ms. Sharlene Sherwin 626 Legislative Office Building P.O. Box 1355 Albany, NY 12248 Massapequa, NY 11758 Brookhaven Town Attorney Richard Bachman, Esq.
475 E. Main Street George Johnson. Esq.
U.S Nuclear Regulatory Agency Patchogue, NY 11772 Office of General Counsel Washington, D.C. 20555 l h, - - -
William R. Cumming
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Federal Emergency Management Agency r
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/p'cc.k UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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Ja nua ry 27, 1988 I
i HEMORANDUM FOR:
Richard W. Krimm
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Assistant Associate Director j
Office of Natural and Technological Hazards t
Federal Emergency Management Agency FROM:
Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
SUBJECT:
FEMA SUPPORT FOR NRC LICENSING OF SHOREHAM NUCLEAR POWER STATION Enclosed is a Long Island Lighting Company (LILCO) letter transmitting the offsite plan for Shoreham Nuclear Power Station (SNPS) which LILCO has provided to you separately. The plan, "SNPS Local Offsite Radiological Emergency Response Plan" Revision 9, is further described in the licensee's transmittal letter of January 22, 1988.
Under the provisions of the April 9,1985 NRC/ FEMA Memorandum of Understanding, we request that FEMA review the SNPS plan.
As you are aware, the NRC and FEMA have jointly developed an interim-use document entitled:
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of s
Nuclear Power Plants (Criteria for Utility Offsite Pl nning and Preparedness).
The document has been published as Supplement I to NUREG 0654/ FEMA-REP-1, Rev.1. The guidance contained in this document is to be used for the development, review and evaluation of offsite utility radiological emergency planning and preparedness for accidents at commercial nuclear plants.
In reviewing and evaluating utility offsite plans and preparedness, FEMA should assume that in an actual radiological emergency. State and local officials that l
have declined to participate in emargency planning will:
(1) Exercise their best efforts to protect the health and safety of the public; (2) Cooperate with the utility and follow the utility offsite plan; and (3) Have the resources sufficient to implement those portions of the utility offsite plan where State and local response is necessary, i
Richard W. Xrimm In accordance with 10 CFR 50.47(a), the NRC must make a finding on whether the state of emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event o the interim criteria described above.
We understand that FEMA will provide its
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findings on a mutually agreeable schedule consistent with the hearing schedule for r
Shoreham.
A specific request as to the FEMA finding date will be coordinated by
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our staffs.
If you have any questions, please call me at 492-1088.
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Frank J. Congel, Director
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Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
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Enclosure:
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ENCLOSURE fL[__ /Eco fLONG ISLAND LIGHTING COMPANY J
SHO8tEHAM NUCLEAR POWER STATION P.O. 80X 418, NORTH COUNTRY ROAO e WADING RIVER, N.Y.11733 I
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JOHN D. LEONAAD. JR.
M PasseawT.mucuAm CN44tos SNRC-1420 JAN 221988 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555 Shoreham offsite Emergency Plant Rev. 9 Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 Gentlemen:
Long Island Lighting Company hereby submits Revision 9 to LILCO's Local Offsite Radiological Emergency Response Plan for the Shoreham Nuclear Power Station.
This letter describes the principal changes set forth in Revision 9 of the LILCO Plan.
As with previous revisions to the Plan, Revision 9 changes are marked in the right hand margins vertical bars denote the addition or replacement of material in Revision 9; horizontal bars denote its deletion in Revision 9.
LILCO has reproduced all pages of the Plan and Implementing Procedures, not just Revision 9 pages.
This alleviates the tedious process of replacing each outdated page in the document with Revision 9 pages, and insures that each plan holder has an updated Plan.
Because there are so few of them, only replacement pages for Appendix A have been Thus, while the Revision 9 package sent you includes j'
included.
all pages of the Plan and Implementing Procedures, plus Revision 9 pages for Appendix A, only pages marked "Rev. 9" in the bottom t:
right corner with revision bars in the right margin have been i;
changed.
Instructions for handling the Revision 9 package are
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included as Attachment I to this letter.
I The principal areas of change in Revision 9 respond to NUREG-0654, Rev. 1, supp. I and the "best efforts" regulations the Licensing Board's emergency planning decisionst the RAC comments on Revisions 7 and 8 of the Plan; FEMA Guidance Memorandum MS-1; and various ministerial updates to the Plan that-are required from time to time.
These areas of change are described generally below and in some detail in Attachment II to this letter.
l l
SNRC-l'420 Page 2 1.
NUREG 0654, Rev. 1, Supp. 1 (Nov. 1987) and "Best Efforts" Regul_at_ ion, 10 C.F.R. paragraph 50. 4 7 (c), 52_ Fed. Rec. 42079
_( Nov. 3, 1987).
Revision 9 reflects the regulatory p.
requirements of the new NRC "best efforts" regulations.
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legal authority sections of the plan have been revised toThe "r"~
li3M take into account the regulation; two Emergency Preparedness
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Advisors have been added at the EOC to liaison with State and County government representatives during an emergency, as required by NUREG 0654, Rev. 1, Supp. 1 (Nov. 1987);
implementing procedures for coordination between LERO and and government representatives during an emergency have been NF, L
revised.
L Because certain governmental facilities have not g}jj(q; agreed to participate in planning, LILCo has relied upon governmental support in the Plan by naming certain entities pr4 3Xd that would provide support during an emergency.
J These entities are identified in sections 1.4 and 2.2 of the Plan tc*
as being relied upon pursuant to the "best efforts" gg; regulation.
They include such facilities as, for example, GXi the Nassau County Coliseum and Maasau County Community
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College, which are identified in the Plan as school 24 relocation centers.
EOh Letters are being sent to each non-LILCO entity named in the Plan reminding them of the existence of
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the Plan and their role in it, and offering to plan with them Wp and to train them.
7 Attachment II.1 lists the revised V ':~
criteria in NUREG-0654, Supp. 1, and describes the response g{j for each included in Revision 9.
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rt' 2
Issues _previously litigated.
Pyl facility reception centers; Revision 9 identifies special
$S hFs drivers, and reception centers for school children; evacuation time estim evacuation time estimates for hospitals; and an RSS station, 7%
as required by the Licensing Board's Partial Initial Decision 1,
and Concluding Partial Initial Decision on emergency planning.
Long Island Lighting Co_._ (Shoreham Nuclear Power
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Station, Unit 1), LBP-85-12, 21 NRC 644 (1985); 14.
'#8 LBP-85-31, 22 NRC 410 (1985).
These issues and tKe Plan i
pg revisions responding to them are listed in Attachment II.2.
3 Regio _n_al A_ssistance Commi_ttee (RAC) Comments.
The December 15, 1987 FEMA RAC comments on Revisions 7 and 8 of the LILCO Plan identified inadequacies in the LILCO Plan.
r All these items have been resolved in Revision 9.
The inadequacies identified by the RAC, and the LILCO responses in the Plan, 5
are listed in Attachment II.3.
p 4
Hospita_1s_for Contamina_ted Iniured Public.
FEMA Guidance p[
Memorandum MS-1 requires identification of a primary and 7
backup hospital for treatment of contaminated injured members Dof the public.
Revision 9 contains a letter of agreement between LILCO and Brunswick Mospital in Amityville for use as the primary hospital during an emergency.
In addition, LILCo has identified Wassau County Medical Center and Northport
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Veterans Administration Medical Center as backup hospitals.
1 SNRC-1420 Pagt 3 The Nassau County Medical Center, a government-operated facility, would be available during an emergency pursuant to the "best efforts" rule and NUREG-0654, Rev. 1, supp. 1 (Nov.
1987).
Northport Veterans Administration Medical Center (is available under the Federal Radiological Emergency Response Plan (FRERP). and other Federal policies.
All three hospitals have Nuclear Medicine / Radiology Departments and are therefore qualified to treat contaminated injured individuals.
The identification of these three hospitals in Revision 9 satisfies the MS-1 requirements.
This revision is listed in Attachment II.4 to this letter.
5.
Ministerial update _s.
The remaining Revision 9 changes update Information about personnel, fr.cilities, or equipenent, including such items as updated farm listings.
These revisions are listed in Attachment II.4 to this letter.
Very truly yours,
/
A N%)
JohnD. Leonard,Jr.A.
Vice President - Nuclear Ope, rations KEBMick Attachment cc: R. Lo/S. Brown W. T. Russell F. Crescenzo Service List I:
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/2/ 8 // 75 0 UNITED STATES OF A! ERICA NUCLEAR REGULAIORY CDINISSION BEEDRE THE AICMIC SAFETY AND LICENSING BOARD In the Matter of
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tecket Ib. 50-322-OL-3 IIN3 ISIAND LIGHTING COMPANY
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(Emergency Planning)
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(Shoreham Nuclear Power Station, Unit 1
)
DIRECT TESTIFOW OF PHILIP MCIhTIRE, CONCERNING CONTENTIONS 23, 25, 65 The Federal Energency Management Agency's Natural & Technological Razards Division is currently engaged in an intensive program of assistance to the States for development and review of offsite emergency plans and emergency response capability to be used in the event of a nuclear power plant accident.
Following the t ree-Mile Island incident, the need for a coordinated offsite emergency response effort became apparent and on December 7,1979, the President assigned FEMA the lead responsibility in offsite radiological emergency preparedness and res;cnse planning.
FE!G is responsible for making interim and final findings and determinations as to the state of offsite emergency plans and preparedness.
FEMA's rule, 44 C.F.R. 350, establishes policy and' procedures for the approval of State and local energency plans and preparedness for coping with offsite effects of radiological emergencies which may occur at nuclear power plants.
We Nuclear Regulatory Commission (NRC) is responsible for onsite emergency planning and licensing of commercial nuclear power plants.
FF#A and NRC have a Memorandum of Understanding (FDJ) relating to Radiological Dnergency Planning & Preparedness (45 F.R. 82713, Dece:rber 16,1980) which defines inter-acency responsibilities. Specifically, FF/A has agreed to make
- - ~~ 35 dings as to ih' ether offsite emergency plans are adequate and capable of f
implementation. Such findings are referred to as "interim" because they are provided outside the formal procedures set forth in 44 C.F.R.
350 and they reflect the status of the plans and the capability of the response at the time of evaluation. Requests for interim findings are usually made by the NRC to assist the NRC Staff's presentations in the licensing process.
l In the.wecec-ding ptsuntly befora u2, tha NRC hr.s sequtsted that FEMA revicw the Long Island Lighting 02npany (LILCD) TranTition Plan, Revision 2.
W e NRC has requested that FE%.'s findings on this plan be transmitted to the NRC by February 1,1984. In addition, FF.% has been requested to provide witnesses, where appropriate to appear before the Atcrnic Safety and Licensing Board in this matter. Ebr the first phase of testinony, Philip H. McIntire sill appear on behalf of FEMA.
I Philip H. McIntire, am employed as the Chief, Natural and Technological Hazards Division of the Federal Dnergency Management Agency, Region II, New York.
I have been requested to address a number of issues raised in Contention 23 dealing with the Evacuation Shadow Phenomena, Contention 25 dealing with Ible Conflict of Emergency Workers and Contention 65 Evacuation Ti;ne Estimates (Phase I of the Hearing).
0.1 - to you have a staternent of professional qualifications?
A.
Yes, My statement of professional qualification is attached to this testimony.
Q.2 - When did you first become involved in energency planning?
A.
In 1966 I joined the Office of Emergency Planning in Washington, D.C.
tis was a predecessor agency of the Federal Emergency Management Agency.
1 In 1915 I first became involved in emergency radiological planning when i
the Federal Disaster Assistance Administration became a member of the' Ccmnittee that preceded the Regional Advisory Cbmnittee.
Q.3 - Please describe the nature of that involvement up to the present time, including the various activities engaged in, persons comnunicated with and responsibilities.
A.
My involvesnent with Radiological emergency planning in FDR began soon after FDR was assigned its offsite res;cnsibilities.
I was Acting Director of the Plans and Preparedness Division, for the period April July 1981 that Division planned and carried out the first exercise at Salem in April 1981 and Nine Mile Point in Septenber 1981. When FEMA was realigned in November 1981 I was named as Acting Chief of the Natural and Technological Hazards Division. In that position I managed the Division's plan reviews and exercise observations at the Ginna, Nine Mile Point, Indian Point and Oyster Creek, power generating stations.
In my present position as Chief of the Natural and Technological Hazards Division, I have met with the top FEMA staff at FEMA's National Office, the Regional Director of NRC Region I, and State Officials workine in the REP program in order to help formulate policy and make decisions.
Q.4 - Are you authorized by FDR to present your professional opinion to this Board on the contentions contained in Phase I of this hearing?
A.
Yes.
I
u Contention 23 he Evacuition Shadow Phrnanenn Q. 5 - Is there a need to consider the effects of sgentaneous evacuation in the preparation of an offsite plan for the shorehan power Station?
A.
Experience has shown that spontaneous evaucuation will occur normally in most cases. As a result it is entirely possible that fewer people would actually have to evacuate when an order to leave is issued. At Wree Mile Island it appears the reason for the high rate of s;cntaneous evacuation was conflicting information frm the authorities.
Q.6 - Based on your experience and review of other plans, what is the function of traffic control point and traffic controllers? Are the individuals asigned to this function exped or intended to physically stop individuals from entering the EPZ?
A. Traffic Controllers a;e stationed at key points in the transportation system to guide traffic. Wese individuals are at their duty stations only to facilitate the mvement of traffic. W eir task is to assist irxlividuals leaving the EPZ, and discourage individuals frczn entering the EPZ but not to physically prevent people frcrn entering it.
Q.7 - k' hat steps can be taken to assure that individuals outside the EPZ will not evacuate into the EPZ? hhat steps can be taken to assure that individuals will not attempt to evacuate dring or imnediately before.a release and dispersion of radioactive materials?
A. WJREG-0654, ETFA-REP-1, Rev. I requires that educational information is made available to the public on a periodic basis on how they will be notified and.what actions should they take in a radiological emergency.
B is program should include provision for written material that is likely to be available in residence during an emergency.
In addition, a system for disseminating to the public appropriate information to ap;$ropriate broadcast media, e.g., the Emergency Broadcast system (EBS) should be in place. Assuming that the public education program is effectively implemented, we can assume that the public will follow the instructions issued over the EBS system.
It is also asstrned that decision the maker will provide a clear instruction to the populace in a timely fashion.
Contention 425
_. _.. Ible Conflict of Dneccencv kbrkers Q. 8 - Based on a review of the literature and your personal experience, how have emergency workers resolved their conflict betwen performance of their emergency functions and obligations to their family?
A.
Based upon my more than 15 years experience in emergency operations, I have never been made aware of a situation where there was a conflict of such magnitude on the part of emergency workers that the response operations were negatively impacted. Rather the literature, particularly l
from the Ohio State University Disaster Research Center, indicates that the nest ecmon problem is coordination of the activities of all the people who wish to assist.
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Q. 9 - Are you familar with the experiences and response of emergency workers at T.4I?
A.
Generally, yes, through a review of some of the literature and discussions about the subject at meetings and conferences.
Q.10 - htat conclusions can you draw frcm this material?
A.
In order to ensure a successful emergency response, an individual with unquestened authority must be in charge and directing trained e:rergency responders.
In addition the person in charge must be recognized as a credible individual by the general public, and there must be a steady flow of accurate information to the public from the person in charge.
Finally, there must be close coordination among the three levels of government.
Q.11 - Is there a difference between asking an individual already within the DZ to re'spon$ and asking an individual outside the DZ to respond? What is your answer based on?
A.
As a general rule we believe not. An individual in the DZ wuld probably be sure that arrangements for his/her family are made before responding. Itis minor delay, in nost cases, wuld probably be off-set by the longer travel times needed for rest people outside the DZ where safety of ones family would not be a concern.
0.12 - Will emergency workers look to assure that their own families safety is provided for before responding? htat actions will emergency workers take to assure this protection before assuming their emergency roles? hhat type of delay will this cause in the assumption of their emergency duties?
A.
It is our experience, because of their training, most emergency workers develop procedures to assure the safety of their families during emegency con $itions, similar to hane fire evacuation procedures.
Implementation of these procedures are generally timely and would cause l
only minimal delay in carrying out emergency duties.
l 013 - htat is the anticipated response of emergency workers such as police officers, firemen, and traffic control officers if they feel they may be exposed to same sources of contamination?
A.
Properly trained and equipped emergency workers would in almost all cases undertake their assigned res.consibilities even though exposure to contamination is passible. Based upon my more than 15 years experience in emergency operations I have never been made aware of a situation where emergency workers did not fulfill their responsibilities even through they were exposed to hazardous conditions.
Q.14 - What role mnflict, if any, will be experienced by teachers and other school personnel (including crossing guards)?
A.
We believe'it will be similar to that of bus drivers, but that it can be mitigated by the same methods.
Q.15 - On what do you base your assumption that non-emergency workers such as teachers, will remain to assist in an evacuation or sheltering effort instead of leaving to rejoin their fanilies?
A.
%e history of disaster response has consistently shown that non-emergency workers, and particularly teachers, also more than meet respnsibilities when faced with emergency situations. Continued improvement in training and public education will~ provide a higher confidence level to non-emergency workers regarding the safety of their fanilies.
-Q.16 - What role conflict is expected to be experienced by BE (Brookhaven National Laboratory) personnel who have family residing within the EPZ?
A.
Because of their knowledge of and experience with radiation, it is expected that role conflict with Brcokhaven National Laboratory personnel would be ainest non existent.
Q 17 - What role conflict is expected to be experienced by Bus drivers? Is this different than that expected of LILOO employees? Why?
A.
Based upon our experience at Indian Point we would expect role conflict on the part of bus drivers to exist until they are trained and equipped with protective devices; the matter of empensation for responding to a radiological emergency is resolved; and letters of agreement are signed.
We believe that role conflict would not be a serious problem with Lilco employees because of their knowledge of and training in the field of t
radiation as well as their loyalty to the cmpany.
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Q.18 - What role conflict, if any, will be experienced by drivers of aT.bulance and other rescue vehicles, and paramedical support service personnel?
Will they perfrcrn their assigned functions? hhat steps can be taken in advance of an actual emergency that will better assure the response of
..- --these individual and your ability to assure their response?
A.
W e same answer as for question i 14.
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Q.19 - Whtt h;s been your prior axoericnce with tha r:sponsa of members of tha American Red Cross, Salvation Army and other volunteer groups to perform their assigned tasks in emergencies. In emergencies involving fixed nuclear facilities? htat response would you expect' in case of an accident at the Shereham Nuclear Power Station? What do you base your judgment on?
A.
FEMA and its predecessor agencies' experience with the Red Cross, Salvation Army and other voluntary agencies has been outstanding in all types of omergencies. We would expect that all the primary voluntary agencies would carry out their response roles in a similar matter in the event of an accident at Shoreham, especially in light of the fact that most of their personnel would be working outside the 10 mile EPZ.
Contention 65 Evacuation Time Estimate Q.20 - What purpose do evacuation time estimates serve?
A.
Evacuation time estimates are utilized by decision-makers when determining the availability of the timely utilization of alternative protective actions.
They are utilized to determine if evacuation can be accomplished before release dispersion of radi.oactive materials.
(See 10 CFR 50-47 (b) (10) NURD3-0654 (II J-10m).
Q.21 - Did FEMA contract for or receive any data on evacuation time estimates?
A.
Yes, Under the Memorandtrn of UnderstaMing between the U.S. Nuclear Regulatory Commission (NRC) and the Federal Dnergency Management Agency (FEMA) of January 14, 1980, FEMA agreed to provide IRC with an independent assessment of evacuation times around 12 reactor sites which have the highest population density'within the 10-mile Dnergency Planning Zone or were mutually agreed by FE.vA and NRC. S e report, "Dynamic Evacuation Analyses," ('ID-13 October,1981) fulfills this agreement. The report was ccrnpleted by the Radiological Dnergency Preparedness Division.
W e FEMA independent assessment of the 12 reactor sites consists of contractor assessments, major conclusions by the contractors, comentary by pertinent State and tocal government officials on these assessments and a critique of the contractor' methodologies.
In addition, the report was reviewed by our Mitigation and Research Office and our Government Preparedness Office. nis report contains the assessment of evacuation times for Shoreham which were conducted by Wilbur Snith and Associates.
Q.22 - htat does the literature and your experience show to be the most comen unit by which families evacuate during a natural or man-made disaster?
A.
Families evacuate as a unit.
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Q.23 - Are parents expected to follow instructions and leave the plume exposure pathway EPZ without stopping to pick up their children from school? hhat effect will parents driving to schcol to pick up their children have on an orderly evacuation or sheltering effort?
A.
FEMA is not sure what percentage of the parents would drive to schcols to pick up their children.
If a significant percentage of parents did drive to the school to pick-up their children it would have an impact on an evacuation.
FDT believes that an intense public education progra would a
result in a rise in the confidence level, on the part of the parents. We also hope that consideration will be given in the Shoreham EPZ of adopting the early release program developed by Westchester County for Indian Point.
Q.24 - What impact will secaration of family members have on the orderly evacuation or sheltering of the general population?
A.
While it is impossible to give a categorical answer it should be noted that most major evacuations have been carried out with the family unit-emerging intact. This is one area where further education will increase parents' confidence that their children will be evacuated safely by teachers or other adults if the early release prcgram is rot adopted.
Q.25 - bhat does the literature as well as your experience show to be the expected response of the general population in cases of disasters and radiological incidents?
A.
In over thirty years of research, the evidence is that a negligible proportion of persons panic in disaster situations.
The research covers a range of situations from massive strategic b:rbing in Europe and the two accmic bcznbs dropped on Japanese cities during World War II through more recent natural and technological hazards including the three Mile Island accident and the eruption of Mount St. Helens, and other natural disasters. Panic occurs only under special circumstances, e.g. when people are faced with a highly visible and innediate threat to survival within an enclosed area and escape routes are closed off.
Non-cooperative behavior during evacuation is always isolated.
Q.26 - hhat effect will a power fai16re have on an evacuation?
-- --A. -A power failure during an evacuation would have significant initial effects brought on by traffic-signals and gas pumps not functioning.
During the New York City black-out of 1977 volunteers a:x! off-duty officials manned key traffic control points until off-duty personnel could be' recalled to duty.
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Q.27 - hMt impact is expected on tticphona ssrvice during an emergency?
A.
It can reasonably be expected that the telechone system could become overloaded in the event of an incident. This is w!iy b' JAM-0654 regaires a backup comunication system and an effective alert and notification system via EBS so people will not be dependent u p n the phon'es. Also, an effective public information program relating directives frcn a credible authority figure would reduce the phone demand.
Q.28 - Are there certain circumstances whereby evacuation muld not be available.
as a protective measure? If yes, what other actions would be taken?
A.
In the case of a fast noving event it is pssible that evacuation would not be available as a protective action. In that cases, sheltering of individuals would most likely be implemented.
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-PHILIP H. McINTIRE PROFESSIONAL QUALIFICATIONS Philip H. McIntire is employed at FEMA Region II, 26 Federal Flaza, New York, New York. Mr."McIntire is the Chief of the Natural and Technological Hazards Division of the Region II Office of the Federal Emergency Management Agency.
Mr. McIntire holds a B.A.. Degree with a major in political science from Bowdoin College in Brunswick, Me. and an M.B.A. Degree from Baruch College with a major in human resource management.
The witness began his Federal service in 1966 as a management intern in the Office of Emergency Preparedness, a predecessor agency of FEMA.
After a year of rotational assignments, he was assigned to the of fice which administered the President's Disaster Relief Progra=.
Soon af terwards, OEP created a disaster preparedness branch and Mr.
McIntire was assigned to it.
This was the first effort by the Federal Government to institutionalize a natural disaster preparedness function.
During the next few years, the witness was involved with several major disaster preparedness projects including serving as a principal author of "Disaster Preparedness: A Report to Congress" in 1971, and a major hurricane preparedness conference in Miami in 1972.
Mr. McIntire also served as a special assistan't to the Director of the agency for the NATO Committee on the Challenges of Modern Society.
The witness planned and participated in meetings of international disaster experts in Brussels, Rome, Venice and San Francisco.
The head of the American delegation to the NATO committee was then Counselor to the President and now U.S. Senator Daniel Patrick Moynihan.
In 1972, Mr. McIntire transferred to the newly created Regional Office of OEP in New York. His first assignment in Region II was
.to.. direct the. Federal ef fort to te=porarily house nearly 4,000 families who were forced from their ho=es by the floods generated by Tropical Storm Agnes.
During'the 1970s, the witness held key manage ent positions in Federal responses to nearly 15 Presidentially declared disasters and emergencies, including the Xenia, Ohio tornado of 1974, and hurricane Eloise in 1975, and David and Fredrick of 1979, all in Puerto Rico.
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In 1974, Mr. McIntire was named Assistant Regional Director for Preparedness.
In this position, the witness managed $250,000 grants to each jurisdiction in Region II (New Jersey, New York, O
Puerto Rico and the Virgin Islands) to develop a State plan and preparedness capability to respond to disasters.
Subsequently, he managed $25,000 per year grants to each jurisdiction to maintain the plans and improve preparedness posture. During the period 1974-1979, Mr. McIntire served as the Federal Disaster Assistance Administration's representative on the. interagency committee that preceded the current Regional Assictance Committee.
In this regard, the witness was involved in'the first efforts by the Federal Govern-ment in radiological emergency planning in the States-of New York and New Jersey.
With the Realignment of the Regional Office in Nove=ber 1981, Mr.
McIntire was named Acting Chief of the Natural and Technological Hazards Division, and in August 1982 he was named Chief of the Division.
The Natural and Technological Hazards Division has re.
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sponsibAlity for FEMA's Radiological Emergency P1'anning progra=.
In this regard, Mr. McIntire has supervised the preparations for conduct of and the completion of the Post Exercise Assesssents for a dozen full-scale er.sreises in New York and New Jersey. He also i
served as the agency's chief expert witness for the Indian Point Atomic Safety and Licensing Board.
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