ML20204B699
| ML20204B699 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/20/1987 |
| From: | Colwell W, Cosgrove P, Evans P, Perrow C, Rowan F, Streeter J, Zook R AFFILIATION NOT ASSIGNED, ARKANSAS, UNIV. OF, FAYETTEVILLE, AR, SUFFOLK COUNTY, NY, YALE UNIV., NEW HAVEN, CT |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#187-2880 OL-5, NUDOCS 8703250132 | |
| Download: ML20204B699 (300) | |
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2 776 kEOTED COfMM.YM 00tKETED t:SNRC UNITED GTATES OF AMERICA NUCLEAR REGULATORY COMMISSION '87 tiAR 23 PS:24 Before the Atomic Safety and Licensina Board 0FFict. S . hat lAnY 00CKETit4G '. SEPVir:i.
BRANCH
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In-the Matter of )
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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5 >
) (EP Exercise)
(Shoreham Nuclear Power Station, )
Unit 1) )
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DIRECT TESTIMONY OF WILLIAM LEE COLWELL, DEPUTY INSPECTOR PETER F. COSGROVE, PHILIP EVANS, CHARLES B. PERROW, FORD ROWAN, LIEUTENANT JOHN W. STREETER, JR., AND HAROLD RICHARD ZOOK ON BEHALF OF SUFFOLK COUNTY 3 REGARDING CONTENTION EX 50 -- TRAINING OF OFFSITE EMERGENCY RESPONSE ,
PERSONNEL March 20, 1987 0703250132 870320 PDR ADOCK 05000322 T PDR
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board
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In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5
) (EP Exercise)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
DIRECT TESTIMONY OF WILLIAM LEE COLWELL, DEPUTY INSPECTOR PETER F. COSGROVE, PHILIP EVANS, CHARLES B. PERROW, FORD ROWAN, LIEUTENANT JOHN W. STREETER, JR., AND HAROLD RICHARD ZOOK ON BEHALF OF SUFFOLK COUNTY I REGARDING CONTENTION EX 50 -- TRAINING OF OFFSITE EMERGENCY RESPONSE PERSONNEL l.
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CONTENTION EX 50 TESTIMONY Table of Contents Page I. INTRODUCTION . . . . . . . . . . . . . . . . . . 1 A. Identification of Witnesses . . . . . . . . 1 B. Familiarity with LILCO's Plan . . . . . . . 20 C. Purpose of Training . . . . . . . . . . . . 25 II. PURPOSES AND
SUMMARY
OF CONCLUSIONS. . . . . . . 34 A. Purpose . . . . . . . . . . . . . . . . . . 34 B. Summary of Conclusions. . . . . . . . . . . 34
- 1. The Exercise Results Demonstrate Fundamental Flaws in LILCO's
- Training Program . . . . . . . . . . . 34
- 2. LILCO Has Not Fixed its Training Problems . . . . . . . . . . . . . . . 41 i
III. DISCUSSION OF CONTENTION EX 50 SUBPARTS. . . . . 55 A. Contention Ex 50.A: Training for Unanticipated and Unrehearsed Situations. . . . . . . . . . . . . . . . . 55
- 1. The Importance of Being Trained to i Respond to Unanticipated and Unrehearsed Situations . . . . . . . . 57
- 2. Examples of LILCO's Lack of Training i to Respond Properly, Appropriately or Effectively to Unanticipated and Unrehearsed Events . . . . . . . . . . 60 (a) Road Impediment Examples. . . . . 61 (b) Rumor /Public Inquiry Examples . . 68 (c) Other Examples. . . . . . . . . . 75 1
Pace
- 3. The LILCO Failures to Respond Appropriately to Unanticipated Events Were Not Unexpected . . . . . . 78
- 4. LILCO Has Not Corrected its Failure to Provide Training in Responding to Unanticipated and Unretearsed Events . . . . . . . . . . . . . . . . 93 B. Contention Ex 50.B: Failure to Train Personnel About Basic Knowledge and Information Essential to Implement the Plan and Procedures . . . . . . . . . . 99
- 1. Introduction . . . . . . . . . . . . . 99
- 2. Examples of LILCO's Failure to Provide Effective Training to Provide Personnel with Basic Knowledge on How to Follow and Implement the Plan and Procedures . . . . . . . . . . . . . . 102 (a) Introduction. . . . . . . . . . . 102 (b) Communications Problems in Dealing With Traffic Impediments . . . . . . . . . . . 104 (c) Failure to Follow Plan and Procedures in Dealing with the News Media. . . . . . . . . . 111 (d) Other Examples of LILCO's Failure to Train Personnel in How to Follow and Implement the Plan and Procedures. . . . . . . . . . . . 114
- 3. LILCO Has Not Corrected its Failure to Train its Personnel in Basic Knowledge Necessary to Implement the Plan and Procedures. . . . . . . . . . 118 C. Contention Ex 50.C: The Exercise Results Demonstrate that LILCO Has Failed to Teach Personnel to Communicate Effectively. . . . 125
- 1. Examples of Lack of Communication Training Which Were Reflected in the Exercise Results . . . . . . . . . 126 l
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- 2. The Communications Deficiencies Which Were Demonstrated During the Exercise are Significant . . . . . 135
- 3. LILCO's Communications Training Program Has Not Been Fixed . . . . . . 138 D. Contention Ex 50.D: Training to Follow Directions of Superiors . . . . . . . . . . 148 E. Contention Ex 50.E: LILCO Has Failed to Train Personnel to Exercise Good Judgment and Use Common Sense . . . . . . . 150
- 1. Examples of LILCO's Training Failures . . . . . . . . . . . . . . . 151
- 2. The Importance of Training Personnel to Exercise Good Judgment and to Use Common Sense . . . . . . . . . . . 159
- 3. The Post-Exercise Drills Support the Allegations of Subpart E . . . . . . . 161 F. Contention Ex 50.F: LILCO Has Failed to Train Personnel to Deal Effectively with the Media and the Public. . . . . . . . . . 166
- 1. Examples of LILCO's Failure to Train Personnel to Deal with the Media . . . 167
- 2. LILCO's Failure to Provide Effective Media Training is Significant. . . . . 170
- 3. The Post-Exercise Drills Do Not Solve LILCO's Training Problems. . . . 185 G. Contentions Ex 50.G and H: Training for Persons and Organizations Relied Upon by LILCO and Training in Exposure Control . 186
- 1. Subpart G. . . . . . . . . . . . . . . 187
- 2. Subpart H. . . . . . . . . . . . . . . 191 l
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F Page H. Contentions Ex 50.I: LILCO's Modifications to Its Training Program are Ineffective . . 196
- 1. LILCO's Proposed Training Changes Represent No Real Change . . . . . . . 196
- 2. LILCO's Organizational Structure Will Make It Difficult for LILCO to Successfully Train Its Personnel . . . 200 218 IV. . CONCLUSION . . . . . . . . . . . . . . . . . . .
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t March 20, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic' Safety and Licensina Board
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-S
) (EP Exercise)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
DIKECT TESTIMONY OF WILLIAM LEE COLWELL, DEPUTY INSPECTOR PETER F. COSGROVE, PHILIP EVANS, CHARLES B. PERROW, FORD ROWAN, LIEUTENANT JOHN W. STREETER, JR., AND HAROLD RICHARD ZOOK ON BEHALF OF SUFFOLK COUNTY REGARDING CONTENTION EX 50 --
TRAINING OF OFFSITE EMERGENCY RESPONSE PERSONNEL I. INTRODUCTION A. Identification of Witnesses Q. Please state your names and occupations.
A. My name is William Lee Colwell. I am an Associate Professor in the Criminal Justice Department, University of Arkansas at Little Rock. Prior to joining the faculty at the University of Arkansas at Little Rock, I was the Associate Director and (hief Ixecutive Officer of the Federal Bureau of f Investigation (" FBI"), a position widely regarded as the senior i
i law enforcement position in the country.
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My name is Peter F. Cosgrove. I am the Commanding Officer of the Personnel Bureau, Headquarters Division, County of Suffolk Police Department. I hold the rank of Deputy Inspector in the Police Department.
My name is Philip Evans. A statement regarding my quali-fications is included in the testimony I submitted on March 13, 1987 on Contentions Ex 38, 39, 22.F, 44, 40.C and 49.C (hereafter the " Contention Ex 38/39 Testimony").
My name is Charles B. Perrow. I am a teacher by profession, having taught classes at all levels in a university setting for 27 years. Since 1981, I have been a Professor in the Department of Sociology at Yale University. My teaching interests include, among others, complex organizations, industrial society, technology and social change, social movements, research design and sociological theory.
My name is Ford Rowan. A statement regarding my qualifica-tions is included in the Contention Ex 38/39 Testimony.
My name is John W. Streeter, Jr. I am the Executive Officer of the Suffolk County Police Academy, County of Suffolk Police Department. I hold the rank of Lieutenant in the Police Department.
My name is Harold Richard Zook. Since my retirement last year as the Deputy Director of the Standards Division, State of Arkansas Commission on Law Enforcement Standards and Training, I have served as a consultant in the areas of law enforcement administration, management, and training. Of these three areas, I remain most involved with training, serving as a coordinator for and consulting with training programs at the local, national and international levels of the criminal justice system.
Q. Please summarize your current duties and responsibi-lities and briefly explain your professional qualifications and backgrounds.
A. (Colwell) As an Associate Professor at the University of Arkansas at Little Rock, I teach a number of courses in the University's Criminal Justice Department. I am also a member of the University's International Studies Faculty, and I am an Adjunct Professor at the University of Virginia in connection with the FBI's Training Academy in Quantico, Virginia, where I sometimes serve as a guest lecturer. From 1980 through 1985, I was also an Adjunct Professor at the University of Southern California Washington Public Affairs Center, where I lectured and provided consulting services on a variety of public administration topics.
Prior to my present teaching position at the University of Arkansas at Little Rock, I was the Associate Director and Chief Executive Officer of the FBI, a position which frequently required me to serve as the Bureau's Acting Director. As Chief Executive Officer of the FBI, I had direct responsibility for a budget in excess of one billion dollars (of which approximately 13 percent was dedicated to training at not only the federal level, but also for state and local law enforcement agencies),
the direction of policy review and analysis, budget formulation and implementation, and allocation of FBI resources and oversight of all administrative investigative operations involving 20,000 employees in the approximately 520 offices in this country (including 59 field offices) and 14 foreign posts. I was also responsible for program evaluation, long-range planning, and review of personnel actions. I oversaw FBI public affairs and congressional liaison functions, frequently testified before Congress, and consulted with cabinet-level officers, officials in the White House, governors, state legislators, prosecutors, attorney generals, chiefs of police, training directors at both the state and federal levels, and foreign government representa-tives. In addition, I acted as one of the FBI's chief repre-
- sentatives in dealing with the media, over 16,000 law enforcement agencies, independent agencies, inspector generals, over 700 l citizen interest groups, 13,000 local governments, tens of thousands of private organizations, thousands of corporations, l
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and members of the federal and state judiciaries. I was actively involved in the general supervision at a national level of all criminal and intelligence investigations.
My duties and responsibilities as Chief Executive Officer of the FBI also included responsibility for ensuring that the Bureau's training programs, which involved over 475,000 police officers around the country, were effective. I was responsible for reviewing the activities of the FBI to ensure that it operated in an effective manner and that its conduct, and that of its employees, was under the rule of law and in accord with the rules and regulations of the Bureau. I made recommendations to the U.S. Department of Justice, including directly to the Attorney General of the United States. Other responsibilities included internal audits, evaluations, personnel recruiting, promotions, transfers, and disciplinary matters. Finally, I was the Director's personal representative in ensuring that the FBI was an effective organization in meeting the high expectations of the President, the Attorney General, members of Congress, the judiciary, the media, and, equally important, the citizens of this country.
Prior to serving as the Associate Director and Chief Execu-tive Officer of the FBI, I held virtually every investigative and management position in the Bureau during my approximately 26-year FBI career. These positions included the position of Executive i
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Assistant Director for both Investigations and Administration. I helped develop the FBI's National Emergency Operations Center located in the FBI's Headquarters, with links to the White House, the Department of Justice, the Department of Energy, the Depart-ment of Defense, all FBI field offices, and other local, state and federal agencies. I was one of the five original evaluators for the FBI's Personnel Assessment Center, which conducts reviews of the leadership capabilities of candidates for supervisory positions within the Bureau. I am a graduate of the FBI's Senior Executive Program and National Executive Institute.
During the last 15 years of my tenure with the FBI, I was specifically involved with the training and the evaluation of personnel. For much of this time, I served as an instructor and lecturer at the FBI's Training Academy in Quantico, Virginia; I also participated in the planning, development and preparation of courses sponsored by the Academy, and served as an evaluator of new agents attending the Academy. In addition to active involvement in the classroom portions of FBI training, I also helped to design, implement and evaluate drills and exercises in connection with the FBI training program. I also was involved in the evaluation of training programs which included, among others, l
participation by PEMA. I have been certified by the Arkansas Law Enforcement Training Academy as an instructor.
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I During the past 18 months, in addition to my position with the University of Arkansas at Little Rock, I have served as a consultant to numerous representatives of city, county and state
! governments on issues concerning the effectiveness of police services, including training, in the State of Arkansas. I have I also consulted with federal and foreign government agencies, lectured abroad, and conducted evaluations of existing as well as
- proposed training programs. The statement of my qualifications and experience attached to this testimony as Attachment 1 summarizes my other qualifications and experience.
i (Deputy Inspector cosgrove) I am presently the Commanding 1
Officer of the Suffolk County Police Department's Personnel
! Bureau. Prior to my appointment to this position, I was a Deputy Inspector assigned to the position of Executive Officer of the l Department's Third Precinct, where my duties were to assist the Precinct Commander in exercising line and staff command over all personnel and operations in the Precinct.1 I was also a former Commanding Officer of the Suffolk County Police Academy, which l
provides a broad range of training to 22 police agencies, as well as several related law enforcement agencies. Included among the j training programs offered by the Police Academy are New York l State certified courses in criminal investigation, instructor l
1 There are six Precinct commands within the Suffolk County Police Department. For an explanation of the general organiza-
, tion and structure of the Department, agg the Testimony of l Assistant Chief Inspector Richard C. Roberts 11 al. on Behalf of i Suffolk County Regarding Contention EX 40 (Feb. 27, 1987) at 7-8 l and Attachment 5 thereto.
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development, radar operations, firearms training, and emergency '
l vehicle operation. The Police Academy also offers New York State j certified programs in basic police training, supervisory training I
and in-service training. These programs include, among other <
things, training in the subject areas of traffic direction and i i ,
l control, command and control, responding to emergency situations, j l community relations and crowd control, radio usage, and first aid. The Police Academy conducts a wide variety of drills and exercises designed to ensure the emergency response capabilities t
' of police personnel. I have been involved in the design, imple- 1
! mentation and evaluation of these drills and exercises. I have !
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continued to serve as a lecturer at the Police Academy since i
leaving the command of that facility. In fact, I have now been a ;
- lecturer at the Academy for about 15 years. [
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i I have been employed by the Suffolk County Police Department j j since May, 1966. From February 1979 to October 1981, I was the l 1 Commanding Officer of the Department's Personnel Section respon- l sible for, among other things, recruitment and selection, job s
i descriptions and affirmative action. As previously noted, even ,
l before assuming command of the Suffolk County Police Academy, I t
- had had a long association with the Academy. From December, 1972 until September, 1975, while holding the rank of Sergeant, I was i assigned to the Police Academy's Basic Recruit Training Program.
l Thereafter, I continued to lecture at the Academy until October, ,
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l 1981, when I became the Academy's Commanding Officer. I remained i >
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the Commanding Officer of the Academy until January 15, 1984.
During that time, I had general administrative responsibility for the operations of that facility and directed 33 full-time trainers. I also gave final approval to all curricula, certified satisfactory completion of courses to the State of New York, determined training needs, and ensured that all training programs met their objectives.
I have been certified by the New York State Bureau for i
Municipal Police as a Police Instructor, and since September, 1972, I have been an Adjunct Assistant Professor of Criminal Justice at Suffolk County Community College. I have conducted training classes for the Suffolk County Sheriff's Department, the Suffolk County Health Department and the Suffolk County Department of Social Services on the subject of interaction with
- members of the public. I have also conducted police training classes for the New York State Bureau for Municipal Police, the City of Kingston Police Department, the City of Yonkers Police Department, the Westchester County Sheriff's Office and the City of Syracuse Police Department.
I was at one time one of 13 New York Training Zone Coordina-tors responsible for Nassau and Suffolk Counties. I was formerly a member of the Training Committee of the New York State Associ- l ation of Chiefs of Police and served as a resource for questions to be used in police promotion examination by the New York State I
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Civil Service Commission. The statement of my qualifications and experience attached to this testimony as Attachment 2 summarizes my other qualifications and experience.
(Evans) I will not repeat the statements made in my Contention Ex 38/39 Testimony. My professional qualifications are Attachment 2 to that testimony. I will add, however, some brief comments regarding my experience related to training.
In more than 20 years as a senior executive of major newspapers, I have had extensive experience in the training of personnel. This has included responsibility for and administration of intern programs for college students interested in careers in journalism, training programs in the various printing crafts (typography, press, pre-press), and training programs for advertising sales people, and circulation department managers.
In a less formalized sense, I have had responsibility for career development of large numbers of employees who were working under my direction (400 at the Philadelohia Bulletin, 350 at the Wanhinaton Star, 700 at the Washinaton Timen). It was my responsibility to ensure that they were being given appropriate direction, guidance and, where necessary, counseling to enable them to perform their jobs satisfactorily and to advance in their careers. In that regard, I had to review on at least an annual basis formal evaluations of each employee's progress and, where appropriate, to recommend special remedial training.
(Dr. Perrow) I am a Professor of Sociology at Yale University, where I have taught since 1981. Before that time, I was: a Fellow at the Center of Advanced Study in the Behavioral Sciences in Palo Alto, California; & Visiting Professor at the London Graduate School of Business; a Professor of Sociology at the State University of New York at Stony Brook; a Visiting Professor at the Institute of Industrial Relations and School of Business Administration at the University of California, Berkeley; and a Professor of Sociology at the University of Wisconsin.2 During my teaching career, I have conducted research and
! written extensively on complex organizations, industrial society, high risk technologien, organizational dynamics and effective-neno, and technology and social change. In addition to my work in these areas, my research and writing have focused, among other things, on the characterintics of organizational design and i behavior. My writings have appeared in such journals an the Harvard Buninton Review, the American Journal of socioloay, Q12Anizational Dynamica, the Adminintrative Science _Quarteriv, 2 This list of teaching jobn geen back to the late-1960'st altogether, I have been teaching since 1959, when I was an instructor in the Department of Sociology at the University of
, Michigan.
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and the New York University Education Quarteriv. In addition, I .
have published several books and monographs and my book, Normal Accidentat Livina with Hinh Risk Technoloales, was awarded the i I
i George R. Terry Book Award of the Academy of Management in 1985.
l A further statement of my qualifications, experience and ;
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professional background is attached to this testimony as ,
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Attachment 3.
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(Rowan) I will not repeat the statements made in my l
contention Ex 38/39 Testimony. My professional qualifications l (
are Attachment 1 to that testimony. I do add the following, I however, regarding my experience in training matters. !
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j In addition to other services, I have provided training j services for more than a dozen corporate clients and for several ;
government agencies. This work has included helping l organizations to plan and train for emergencies and how to l s
! respond to actual crises. !
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In addition, I have conducted more than 100 training i
sessions for executives in the past two years to help them improve communications skills. Almost all of these sessions have f
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j had four goals: (1) to help personnel communicate more l 1 t effectively in crisis situations (2) to help personnel l
l communicate more effectively through the mass medias (3) to help l 1 !
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personnel communicate more effectively regarding risk and j t
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regulatory policy; and (4) to help personnel communicate more effectively with the general public and with politicians, workers, customers, plant neighbors and other relevant groups.
My firm has also developed crisis communications training programs for major chemical and manufacturing companies. The programs include sessions on (1) mitigation, (2) preparation, (3) response, (4) recovery, and (5) renearch. Crisis communic-ations workshops and drills, which I have conducted, cover both internal and external communications. The advanced training programs feature nimulations of emergencies. We utilize neveral methodologies:
1 The case method of examining real crinin situations, including videotaped examples.
Gaming, by using hypothetical scenarios and watching how managern grapple with realistic situations. 1 l
Feedback, which encouragon individual managers to critique their own performancen on videotape.
Group interaction, during which responnen are examined I and various approachen evaluated. ;
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- Instruction, using lecture, graphics and printed !
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- Socratic method of questioning and challenging assumptions through dialogue and debate.
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l (Lieutenant Streeter) My career in law enforcement covers ,
i more than 22 years, with approximately 20 years of that time as a r member of the Suffolk County Police Department. For the last 10 years, I have been assigned to the suffolk County Police Academy, ,
l where I have worked as a supervisor and manager of training. I i f
am a New York State certified police instructor and a graduate of L the FBI's Training Academy in Quantico, Virginia. I also hold a f graduate degree in political science and undergraduate degrees in behavioral selence and criminal justice. !
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! From 1978 through 1984, I was the commanding Officer of the [
j Police Academy's Decentralized Individualized In-Service Training j Program. In that position, I developed, administered and evalu- f I ated training needs, analyses, and training evaluation instru- [
] ments. I was also responsible for administering and evaluating f
instructional television programs for local, county, state and i t
j federal law enforcement agencies within Suffolk County. There- i after, until 1986, I was the Commanding Officer of the Police Academy's In-Service Training program. In that position, I had l responsibility, among other things, for directing the research, I t
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development, administration and evaluation of the Police Depart-ment's in-service training program for local, county, state and federal law enforcement agencies within Suffolk County. I was also the primary instructor for the Department'n " critical incidenta response" training,3 and I annessed training needs, evaluated training, and was the training coordinator for the Department's Mostage Negotiations and Emergency Services units.
i Since 1986, I have been the Executive Officer at the Police Academy. In thin position, I supervine the planning and execu- i tion of instruction given to entry invol pornonnel (recruits),
including but not limited to, instruction in the areas of traffic i control, crowd control, radio usage, first aid, and instruction designed to prepare the trainee to respond effectively in danger-oun and strens-filled nituations. In addition to cupervining the training of recruits, I overneo the evaluation of students' performance after training, and I continue to be responsible for '
3 The Academy's critical incidents renponse training con-stituten an intense and realistic drill / exercise program by which trainees are required, on a real-time basin, to respond to hypo-thetical emergency situations, particularly with scenarios involving unforeneen difficulties. This training emphasizes not only whether traineen know the procedures for responne (ligt, where to go, who to talk to, what to do), but also whether they I in fact can perform as required, ror instance, when a hazardous waste spill was simulated in one recent training session, the practice included all steps short of actually cleaning up the spill. Officero were required to get to the accident, get up l 1
restricted arean, reroute traffic, and do everything eine necessary to deal with the incident and its ramifications. All this was done via une of detailed mock-upo of actual streetn, buildingn, etc., in Guffolk County. It la tna kind of realistic "doing by learning" training which in discussed in greater detail
, later in thin testimony and which I find largely lacking in LERO's training program.
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directing the research, development, production, administration and evaluation of instructional television programs for recruits and continuous (in-service) training programs within the Academy and Suffolk County. I continue to be the primary instructor for critical incidents response training for recruits, in-service and supervisory police personnel. I also assess training needs and evaluate the training of new instructor 2. During 1986, my work s
at the Police Academy, specifically in developing an instruction methodology for the critical incidents response training, earned me the Department's Meritorious Service Award. '
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In the course of my work at the Police Academy, I have been i actively involved in the development, implementation and evalua-l tion of drills and exercises designed to train personnel and to test the effectiveness of personnel training. At the Academy we have structured rigorous criteria for evaluation of performance in drills and exercison and consider deficient performance in drills and exercison to reflect either a failure of individuals i to have the capability to meet our standards or, more likely given pre-drill / exercise selection, a deficiency in the training ;
programa due to failure to teach personnel how to respond appropriately. A further statement of my qualifications and
- experience is attached to thin testimony an Attachment 4. '
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i (Zook) After approximately 37 years in law enforcement, I have recently retired. Since my retirement, I have served as a (
consultant in matters involving law enforcement admi11stration, management and training. I have also remained active as a local, national and international criminal justice coordinator.
Attachment 5 to this testimony summarises my qualifications, background and experience. Briefly stated, my career in law enforcement began in 1949, when I joined the Little Rock, Arkansas, Police Department. Twelve of my 22 years with the Little Rock Police Depar* ment were devoted to designing and developing a training program for the Department, and then serving as a training officer and eventually exercising command over, the Little Rock Police Academy. I retired from the Little l Rock Police Department in 1971 as a Captain and the Commanding Officer of the Police Academy.
i rollowing my retirement, I acenpted an appointment with the United States Votorans Administration as a Regional Security Officer supervising approximately 500 Veterans Administration police officers in 17 states and the Commonwealth of Puerto Rico.
In addition, I was assigned the job of developing and itnplement-ing a National Police Training Center for Veterans Administration police personnel. After that job was performed, I became the !
Chief of the Veterans Administration Police Training Contor, !
where ! remained until 1970, when medical reasons forced me to i
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i resign. Today, the Veterans Administration Police Training
- Center provides law enforcement training to approximately 2,000 police personnel stationed in all Veterans Administration health
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care facilities, wherever located.
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I, In 1980, at the request of officials from the State of (
l Arkansas, I accepted the position of Executive Director of the j State Commission on Law Enforcement Standards and Training. In
- i j that position, I was responsible for regulating and approving all l 1
i law enforcement training which was conducted in the State of (
Arkansas. I also had responalbility for establishing procedures and standards for certifying tne levels of proficiency for i approximately 7,000 state, county and municipal police officers, f i !
During my tenure as Executive Director and later as the l Deputy Director of the Standards Division of the Commission,4 I f i l l became a member of the National Association of State Directors of [
Law Enforcement Training ("NASDLET"). NASDLET membership I consists of the State Director of Law Enforcement Training or his ;
i j designee from each of the 50 states. The 50 members of NASDLET ;
have authority to regulate and control all employment, training
] and certification or licensing of state, county and municipal law i i
i 4 During 1981, the operations of the State Commission on Law Entorcement Standards and the Arkansas Law Enforcement Training l Academy were consolidated. Although I was offored the position t 4 of Director of the new Commission, I declined the offer because
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of my desire to remain in Little Rock, rather than relocating. ! l q was then appointed the Deputy Director for the Standards Division !
j of the Commission. [
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i enforcement officers in the United States (approximately 500,000 officers). In 1982, I was elected to NASDLET's Executive Board and, in 1985, I was alteted President of the Association.
In 1986, medical reasons required me to resign from my position as Deputy Director of the Arkansas Commission on Law l Enforcement Standards and Training. Since my retirement I have remained active, however, in the areas of law enforcement training and standards, for example, I am currently serving as training coordinator and instructor for the United States Department of State, Offico of Counter Terrorinm, in the arean ;
including VIP security, X-9 operations, and SWAT operations. ,
Training in provided to foreign law enforcement executives and operational personnel and, in that regard, is nimilar to training that I am providing at the requent of the United States ;
) Department of Transportation Safety Institute to forelgn law enforcement officorn. I have also recently traveled to the Peoples Republic of China as a member of the United States Police Training delegation, to participate in a technical exchange of information and training techniques with Chinese police officers from the Minintry of Police Security.
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l Do you jointly oponsor this testimony?
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As Yes. Nonetheless, in a number of instances, we indicate the primary author or sponsor. Where no primary sponsor is noted, the portion represents a joint effort by the witnesses, although, even then, particular individuals on the panel may be more familiar with particular matters than other persons.
Messrs. Evans and Rowan contributed primarily to the Summary of Conclusions, the discussion in response to subpart r of contention Ex 50, and other instances where media-related l examples are discunned.
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- 8. EAmil.lAritv_W1tb LILCO'n Plan f
l Q. Are you familiar with LILCO's offsite emergency response plan (" Plan") for Shoreham?
A. Yes. Deputy Inspector Cosgrove, in fact, has pre-l viously testified before the Licensing Board which had jurisdic-l tion over offsite emergency planning issues for Shoreham. In that testimony, Deputy Inspector Cosgrove, and others, provided their opinions about and questioned various aspecto of LILCO's Plan.5 5 The prior tentimony covered such matters as LILCO's provi-sions for training non-LILCO personnel (Contentionn 24.8 and 98);
LILCO's assertion that its training program could compensate for the lack of emergency proparedness and responno experience among LILCO's personnel (Contentiono 40, 44.C, 44.r, 99 and 100), and (footnote continued)
l Since Deputy Inspector Cosgrove's earlier testimony in 1984, LILC0 has changed certain aspects of its Plan and implementing procedures (sometimes referred to hereafter as "0 PIPS").
Furthermore, LILCO has provided additional training to its l personnel relied upon to implement the LILCO Plan. We have reviewed changes in LILCO's Plan which relate to LILCO's training program. We have also reviewed those LILCO documents related to l training provided to the Governments by LILCo.6 rurthermore, we have attempted to gain an understanding of the events which took I
( place during the February 13, 1986, exercise of LILCO's Plan (the i " Exercise"), so that we could reach conclusions regarding how the
! Exercise results related to the adequacy of LILCO's training program. Thus, for example, we have reviewed the conclusions and j findings of FEMA, which are based upon its observations and evaluations during the Exercise, as set forth in the Post-l Exercise Assessment Report (what we call the " FEMA Report"), and l have also reviewed drill reports covering LILCO personnel which 1
l have been prepared since the Exercise.
I i
l (footnote continued from previous page)
- provide proper instruction in the use of emergency equipent
! (Contentions 41 and 44.0); and LILCO's proposal for dealing with
! attrition (Contention 39). Egg Cosgrove and rakler, ff. Tr. 8407 (Contention 24.8); Cosgrove 11 A1., ff. Tr. 13,083 (Contentions 39-41, 44 and 98-100); Cosgrove gi gl. (Supp.), ff. Tr. 13,083.
i 6 It is our understanding that LILCO refused during discovery
- to provide training documents that were used by LILC0 prior to
- the february 13, 1986, Exercise. Thus, our review of LILCO's
- training documents has of necessity been limited primarily to I those post-Exercise documents prov.,ded to the Governments by i LILCO.
i i
I
Q. As background for later discussions, please briefly describe the overall structure of LILCO's training program for offsite emergency response personnel.
3 A. (Congrove, Streeter) It is our understanding that the LILCO training program has three primary phases: classroom presentations; drills / tabletop sessions; and exercises. Plan at 5.1-2. First, information regarding the LILCO Plan and the tasks i expected to be performed by LILCO and non-LILCO personnel relied upon by LILCO in the event of a Shoreham emergency is presented to traineen in a classroom setting through videotape presentations, workbook materials and, in some instances,
. instructor discussions and demonstrations. According to the Plan, this portion of the LILCO training program is designed to provide personnel with an understanding oft
- Conoral emergency planning overview, including the emergency classification system and the history of emergency preparedneon since Three Mile Island;
- Shoreham specific overview;
- Radiation protection, including basic principals of radiation, health effects and exposure control; and Specific organizational tanko under LILCO's Plan.
Plan at 5.1-2.7
- 7 LILCO dividen its classroom training sessions into two segments. The first nogment consinto of information which LILCO considers important for all its offsite emergency response personnel. Thus, all LILCO personnel must attend the following 1 training nennions or modules (footnote continued) i l
The second phase of LILCO's training program consists of l
drills and tabletop sessions. During this phase, personnel discuss the concepts covered in the classroom sessions. As we understand LILCO's program, the purpose of these drills / tabletops may' vary, depending upon the level of training that has been provided, the degree of difficulty of a given task, and so ,
forth.8 During drills or tabletops that occur early in LILCO's (footnote continued from previous page)
General Emergency Planning Overview Site Specific Overview Radiation Protection Notification and Mobilization Communications Personnel Dosimetry Personnel Radiological Monitoring l
Plan at 5.1-3 thru 5.1-4 and Fig. 5.1.1.
The second segment is intended to provide job-specific training to LILCO's personnel. The subjects covered include:
EOC Activation l -
Public Notification Methods and Procedures Reception Center Operations i
Personnel Monitoring and Decontamination l- -
Contaminated / Injured Persons Traffic Control Operations (including Traffic Control Points, Road Logistics and Route i Coordination)
Protective Actions for Special Populations Transportation Operations Sociological Aspects of an Evacuation Security Operations Command and Control l
Public Information (including rumor control) -
Administration L Plan at 5.1-5. Egg also Fig. 5.1.1 of the LILCO Plan, which identifies the LILCO and non-LILCO personnel who are supposed to L attend particular sessions or modules.
l' 8 .
LILCO requires its personnel, but not non-LILCO personnel, to participate in drills and tabletop sessions on an annual 1
(footnote continued)
l t' raining process, for example, LILCO observers critique trainees as they go through the drill / tabletop sessions to correct inappropriate actions or to reinforce appropriate performance.
Later on, the same trainees may go through essentially the same drill or tabletop, but in this instance LILCO controllers and observers would record their comments rather than commenting upon performance during the drill / tabletop. Egg Plan 5.1-2, 5.2-1 f thru 5.2-6.9 We understand that LILCO conducted a large number of these drills / tabletops during November 1985-February 1986 as part of the training / preparation for the Exercise. Egg 7 Deposition of Jay Richard Kessler (February 2, 1987) at 14; 3
Deposition of Brian R. McCaffrey (January 7, 1987) at 24-25; Deposition of Elaine D. Robinson (January 7, 1987) at 12; Deposition of Richard J. Watts (December 3, 1986) at 20-21, 23-24.
(footnote continued from previous page) basis. Plan at 5.1-8. According to LILCO, " drills" are
" supervised instruction periods designed to test, develop and maintain skills in a particular response function" or "to provide maintenance checks of emergency response equipment." Plan at 5.2-2. Under LILCO's program, drills are often components of LILCO-conducted exercises, which LILCO defines as events which
" test ( ) the integrated capability and a major portion of the basic elements" existing within the LILCO offsite emergency response organization (the so-called "LERO" organization). Plan at 5.2-6.
9 LILCO drills are evaluated by LILCO-designated observers
- (gzg., personnel from Impell Corporation, a long-time LILCO consultant and contractor). Tabletop sessions, on the other hand, are generally conducted and " evaluated" by LILCO personnel.
These tabletop sessions, according to LILCO, are conducted in a 4' seminar type setting. They are used by LILCO to provide information to the participants about LILCO's procedures and modifications to the Plan and procedures. Plan at 5.2-3.
i
---m,~,.
The final phase of LILCO's training program consists of specific preparation for a FEMA graded exercise and the FEMA exercise itself. In preparing for an exercise, LILCO's Plan calls for the conduct of full-scale LILCO drills / exercises, or dress rehearsals, "as appropriate to meet the need(s] of (LILCO) in preparation for the graded exercise." Plan at 5.1-3. In this regard, we understand that during the two months prior to the February 13 Exercise, LILCO personnel participated in at least three full-scale dress rehearsal drills. Egg deposition of Dennis N. Behr (January 13, 1987), at 117-19.10 C. Purpose of Trainina Q. To provide perspective and background for your testimony, based on your experience, please explain the purpose of a training program.
A. A successful response to any complex emergency situation requires an organization to work in an integrated manner. That is, the individuals who comprise the organization 10 These pre-Exercise dress rehearsals were conducted in December, 1965, and late-January 1986. Those LILCO personnel chosen by LILCO to participate in the February 13 Exercise par-ticipated in these LILCO dress rehearsals, which in many respects were similar in scope to the February 13 Exercise. The only practical differences were that during the dress rehearsals, LILCO's personnel were not mobilized from their homes, there were no simulated traffic impediments of the scale that were inter-jected by FEMA during the Exercise, and there apparently was no wind shift. Deposition of Dennis N. Behr (January 13, 1987), at 235-38.
must work individually and together in an efficient and effective manner in confronting both the routine (expected) and nonroutine (unexpected) demands which may arise during the response to the emergency. " Training" is the process by which an organization and its constituent members learn to work individually and together to perform routine and non-routine tasks.
As hinted to above, " training" for organizations responding to a nuclear emergency includes an element which goes beyond the training required for some other organizations. Any organization must train to perform routine tasks -- those tasks which are foreseeable, repetitive, and which should be easily understood.
Under the LILCO Plan, there are some tasks which seemingly would fall within the definition of routine tasks, such as the physical ability to drive a bus, how to check a dosimeter, and how to make telephone calls. In an emergency situation, however, the training must also prepare personnel for the nonroutine or the unexpected -- for instance, the ability to respond to unanticipated road impediments, or the ability to deal with unexpected questions or complications learned about during
" routine" telephone calls.
(Perrow) Routines, or repetitive events, are the fundamental condition for having organizations.ll Organizations are set up 11 (Perrow) This was the message of the first great organ-izational theorist, Max Weber, writing in the early part of this century. It is accepted by the leading schools of thought, (footnote continued) because enough things have to be done over and over again that it is efficient to have specialized roles, people doing things that they can learn to do through training and repeated experience.
Thus, training mirrors the essence of organizations -- their routineness. Routines require training and experience.
It must be emphasized, however, that under the LILCO Plan for Shoreham, far more is involved than just the performance of routine activities. Rather, the anticipated response to a nuclear plant emergency must involve, of necessity, training in the routine performance of unexpected tasks -- that is, it must become " routine" for LERO/LILCO personnel to perform as necessary to deal with unexpected or non-routine events.
(footnote continued from previous page) including the bureaucratic " revisionist" theory of Stanford's James March, the most influential living organizational theorist, strongly emphasized in the evolutionary theory of organizations by economists Richard Nelson of Columbia and Sidney Winter of I
Yale's School of Organization and Management, and also utilized as the basis of my own work. See Max Weber, Economy and Society, ed. Guenther Roth and Claus Wittich, New York: Irvington Publications, 1968, vol. 1, pp. 215-225; vol. 3 pp. 956-1001; l Richard Cyert and James March, A Behavioral Theory of the Firm, Englewoods Cliffs, N.J.: Prentice-Hall, 1963; Richard Nelson and Sidney Winter, An Evolutionary Theory of Economic Chance, Boston:
Belknap Press, 1982, chapter 5, e.o., " Organizations remember by l doino" (pg. 99); Charles Perrow, Comolex Orcanizations: A l Critical Essav, 3rd edition, New York: Random House, 1985, especially chapter 1.
i l -. -
Q. How is training accomplished?
A. Training is accomplished at two levels: basic training (such as classroom instruction); and " learning by doing."
" Learning by doing" includes: training gained through experience (this may be called repertoire adjustment); training gained by learning to interact with others and respond to particular events; and training through drills and exercises. Part of the
" learning by doing" training also comes as a result of an organization and its members actually responding to the kinds of real life events for which it is trained.12 Q. Does LILCO's training program involve elements of basic training as well as learning by doing training?
l 12 The final element of effective training -- performance of emergency duties under real life conditions -- is necessarily the l most effective training that persons can receive. It is the essence of " learning by doing." LERO personnel can reasonably be expected to receive no such training, because they have not actually been called upon to respond to any nuclear emergencies and because LERO's members (unlike other persons such as policemen or firemen) do not as part of their regular day-to-day activities have occasion to perform together in other emergency situations from which important experience may be gained.
Accordingly, the training testimony presented herein will focus on the other training elements which LERO personnel may be expected to receive.
A. Yes, at least in theory, LILCO's training program does involve each kind of training (except for response to actual nuclear emergencies). But as will be discussed later, the Exercise revealed flaws in both LILCO's basic training and its learning by doing training.
Q. Please explain in greater detail what those levels of training are.
A. To learn to do predictable, repetitive events, one needs training. Some of this is very basic training, that can be done in a classroom with an instructor or a training film. This is the lowest training hurdle for LERO to clear: basic training, which involves little or no interaction with other persons.
Basic training for LERO would involve such things as how to operate a dosimeter, how to keep records of messages and phone calls, and so on. Since basic training involves the most basic tasks, one would expect in a good training program to find the fewest problems with training at this level.
Conversely, if one finds problems in the implementation of hasic training, one almost surely will thereafter find problems with the other essential levels of training. This is because 4 hose other training levels depend in the first i.nstance on a person's mastery of the relatively routine and mechanical subjects taught during effective basic training, particularly because during an actual emergency, personnel have little time to think about performance of routine matters -- this should be second nature so that attention can be devoted to the non-routine. If the basic training is not well understood, however, then a responder must devote attention to that, necessarily leaving less attention to the non-routine matters.
The next levels of training are necessary because members of organizations must be able to interact with each other and persons outside the organization, to deal with unusual events, and to perform necessary tasks that require communication, coordination, and cooperation. Very little in organizations is static, unchanging, purely predictable, and solely within the control of a single individual. This is particularly true of an organization like LERO, whose sole purpose is to respond to a novel emergency incident, as to which neither it, nor the other entities and individuals with which LERO must interact, have any actual experience.
All organizations confront exceptional events and problems that are not wholly routine. Organizational leaders know this; in fact, one of the jobs of a leader is to anticipate exceptions to the routines, and to design ways to respond to those exceptions which can be roughly predicted. And for situations
_ _ _ _ - . - _]
that cannot be' roughly predicted, a good training program will teach personnel the skills necessary for them to improvise and plan / respond during an emergency in an appropriate manner.
As noted above, learning by doing training can be conveniently divided into three components. First, most exceptions to the routine or new situations, are handled by incremental adjustments to routine procedures, which are slightly modified in the process. This may be called " repertoire adjustment," and involves the training gained through experience.13 Second, more serious exceptions, changes, and disturbances that are expected to occur, are handled by more advanced training. After the basic training is over, personnel continue with training, but now it focuses more upon the unusual events and human interactions that might take place, the problems that can't be readily solved by acting alone but might need the cooperation of others, or training in new equipment, or in a new organizational structure or set up. For example, if a new position of Traffic Engineer is created, mere classroom training will not suffice to integrate that individual into the LERO structure. Rather, there will be a need to educate the person and others with whom he or she must interact regarding the new 13 Experience broadens to include knowledge of the random variations that can be expected, the failures in some part of the system or its environment that can be expected, and the efficacy of a variety of adjustments. Doing a varie,ty of tasks under a variety of changing circumstances enlarges the repertoire of personnel that is available for the next novel event. In this way, assuming a sound program to begin with, learning by experience should occur.
structure and the possible interactions resulting therefrom.
. Third, learning;to deal with the most serious anticipated exceptions takes place in exercises, or drills, where more complex exceptions are simulated as in free play messages, or allowed to occur naturally.14 Q. Are there any common elements among repertoire adjustment, advanced training, and drills and exercises?
A. (Perrow) Yes. All three modes of coping with exceptions to the routine depend upon "doing" for their effectiveness. In fact, Richard Nelson and Sidney Winter emphasize that, in their words, oraanizations learn by doina.15 i
14 A drill.or exercise constitutes an important mechanism to test whether the constituent elements of an organization, i.e.,
its members, have the capability to implement that organization's plan, and to accomplish the overall task or goal. In this context,.an exercise is not designed solely to test an organization or its conceptual mode of operation. That should have been done in the pre-exercise planning phase. Rather, it is essential in an exercise to focus also on the individual skills of the members of the organization and the ability to integrate such skills as necessary to enable the organization as a whole to accomplish its assigned task. Thus, in an exercise, the issue is not just whether individuals can follow the procedures which are set forth in the plan (although such basic ability is important to be demonstrated), but rather an exercise must also be designed to test the individual members' performance of the functions which they would be called upon to be performed in an actual situation, including the ability to deal with the unexpected and unanticipated situations which may require new or different interactions among organization members not expressly contemplated by procedures.
15 Richard Nelson and Sidney Winter, An Evolutionary Theory of Economic Chance, Boston: Belknap Press, 1982, p. 99.
f j of course, we might say that individuals in organizations learn by doing, but since. organizations involve the interaction of individuals,. organizations learn by doing things together.
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r II. PURPOSES AND
SUMMARY
OF CONCLUSIONS A. Puroose Q. What is the purpose of this testimony?
A. This testimony addresses the matters raised in Contention Ex 50 (and the related contentions which the Board decided to consider in connection with Contention Ex 50) arising out of the Exercise of LILCO's Plan for Shoreham. A copy of Contention Ex 50 and the related contentions is Attachment 6 to this testimony.
B. Summarv of Conclusions
- 1. The Exercise Results Demonstrate Fundamental Flaws in LILCO's Trainino Procram O. Based upon your review of the Exercise results which relate to the issues raised in Contention Ex 50, have you reached conclusions regarding whether those results are indicative of any training-related deficiencies in LILCO's Plan?
A. Yes. In our opinion, the Exercise results demonstrate that LILCO's Plan is fundamentally flawed in that despite the extensive training program which is part of that Plan, LILCO's personnel are unable to carry out effectively or accurately the LILCO Plan. Thus, the results of the Exercise also provide an
answer to an-issue left open in the Licensing Board's April 17, 1985 Partial Initial Decision (hereafter, the "PID"):16 the Board cannot find that the Plan can be satisfactorily implemented with the LILCO training program because LILCO does not possess an adequate number of trained LERO workers and the Exercise results reveal that LILCO's training program is fundamentally flawed.
Thus, we believe that the training deficiencies identified during the Exercise preclude a finding that LILCO's Plan could and would be effectively implemented in the event of a Shoreham emergency.
Q. Gentlemen, you stated your belief "that LILCO's training program is fundamentally flawed." What do you mean by the term " fundamentally flawed?"
A. That is not a term which we normally would use in our writing. It is used in this testimony because it has been used by the Licensing Board and Commission. We use the term to mean extremely significant problems in the LILCO training program --
problems, indeed, which relate to whether LILCO's personnel are 16 The Licensing Board found that the "LILCO Plan training program meets the regulatory standards," but that conclusion was expressly:
made subject to confirmation by a finding, to be made by FEMA after a graded exercise, that the Plan can be satisfactorily implemented with the training program submitted and that LILCO possesses an adequate number of trained LERO workers.
21 NRC 644, 756. In the FEMA Report, FEMA made no finding along the lines referenced in the PID.
or can be trained sufficiently to implement the LILCO Plan.
Thus, the problems which we discuss in this testimony, when viewed in the context of the LILCO Plan, the LILCO training program, and the Exercise results, are in our opinion, serious problems which preclude a finding that LILCO's personnel are capable of implementing the Plan.
Q. Please be more specific in summarizing your evaluation of LILCO's training program.
A. The Exercise demonstrated that LILCO's training program is seriously inadequate in a number of crucial respects, which we detail in the testimony which follows. In summary, nowever, our conclusions are as follows.
Under the LILCO Plan, as previously explained, LILCO is responsible for the training and retraining of both LILCO and non-LILCO personnel in LERO. It is our understanding that training began in 1983 (LILCO Admission No. 214) and, since that time, has consisted of classroom instruction, drill and tabletop sessions, and LILCO-conducted full-scale drills or exercises, as already described by us. Plan at 5.1-1 thru 5.2-7 and Figs.
5.1.1, 5.2.1; OPIP 5.1.1, at 5. LILCO requires all LILCO members in LERO to participate in its training program on an annual basis. Plan at 5.1-1, 5.1-7 and 5.1-8; OPIP 5.1.1. At a minimum, this requires each LILCO worker in LERO, each year, to attend classroom instruction sessions on seven emergency response trainit.g modules 17 and to participate in at least one tabletop session or drill; on average, however, LILCO personnel appear to be required, each year, to attend classroom instruction sessions
, on nine modules and to participate in three tabletop sessions or drills. Plan, Figs. 5.1.1 and 5.2.1; OPIP 5.1.1, at 17-20.
Thus, as of the time of the Exercisc, many of LILCO's personnel in LERO (leaving aside new personnel) had already undergone about three years of training by LILCO involving, on average, classroom instruction on a total of 27 training modules and participation in nine tabletop sessions or drills. Furthermore, shortly before the Exercise, those LILCO personnel who were to participate in the Exercise underwent additional training, through their participation in at least three large-scale LILCO drills that served as dress rehearsals for the Exercise, as well as a number of tabletop / drill sessions.
Notwithstanding this allegedly extensive training and last-minute preparation and practice, a large number of training deficiencies were revealed during the February 13 Exercise.
These deficiencies, in our opinion, demonstrate that LILCO's training program has been ineffective. As a result, there can be no finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham emergency.
17 LERO emergency callers are an exception; they only attend three modules. Plan, Fig. 5.1.1.
Q. But don't you conduct exercises like that which occurred on February 13, 1986 in order, at least in part, to find I
training problems and then to be able to fix them?
A. To an extent, an exercise is designed to identify deficiencies or problems in training so that in post-exercise activities, appropriate remedial training and related activities can take place. Thus, the mere fact that a few training problems might be revealed in an exercise is not in and of itself i
determinative.
i However, with LILCO's Plan, a different conclusion must be reached. As described above, LILCO provided a large amount of
) training prior to the Exercise, including three full-scale dress rehearsals in December 1985 and January 1986 attended by the individuals who would participate in the FEMA Exercise. We find it significant that notwithstanding all of that training, there still were so many training-related problems that occurred at the Exercise -- including many problems involving the most basic kinds of matters. It is our opinion that if proper training had j proceeded prior to the Exercise, there would not have been i
training problems on the scale which was revealed on February 13, 1986.
i l
Q. Aren't a lot of the training deficiencies which were documented at the Exercise pretty trivial? How do they show that the LILCO training program is seriously flawed?
A. (Colwell, Cosgrove, Streeter, Zook) We disagree with the premise of the question. Training deficiencies, by definition, are not and should never be considered trivial.
Obviously, certain problems which may arise during an exercise which are attributed to deficiencies in the training program may lead to more serious consequences than other training deficiencies. But that is largely a fortuitous matter, since if there are deficiencies in a training program, one cannot be sure where the results of those deficiencies are likely to manifest themselves during a drill or actual emergency, or what the, ramifications would be.
A key factor in an effective training program is whether it produces an overall concept of operations and integrated capa-
, bility such that the organization, which exists and is capable of performing a task only via the sum of the performances of its individual members, can operate effectively. Indeed, the purpose of a training program is to instill not only knowledge and capability, but an integrated performance capability among all of the members. In this context, no training problems should ever be labeled as trivial. They represent a breakdown in the discipline which must be instilled through the training program to ensure that individuals follow rules and procedures and have developed the necessary capability to respond to non-routine ev.ents.
Finally, it must also be emphasized that during a drill or exercise -- including the Exercise of LILCO's Plan -- the relevant inquiry is not whether a person actually carries out his/her function, notwithstanding some errors along the way which reflect deficiencies in training. Such a " bottom line" approach is inappropriate when judging the effectiveness of a training program. A training program is designed to prepare individuals for a wide variety of events. The mere fact that in a drill or exercise people ultimately get things right (and perhaps even in a timely manner), is largely beside the point.18 i
18 The relevant inquiry is not whether there has been training ,
for a specific act which is then carried out during the drill or exercise, but whether the person understands how that act fits into many others, how it might have to be altered due to special circumstances (e.g., the dosimeter may need to be read more frequently if the wind is changeable), and whether the person has an understanding of the ultimate goal of his/her unit so that 4
he/she understands the importance of the act. For instance, in a real emergency some required behaviors will be extremely important, while others might not need to be performed, because more important ones take precedence, and there would not be any significant consequences from the lack of performance. No one >
can know, or anticipate, these kinds of necessary adjustments in advance, however. Therefore, no training problem can be labeled i trivial ahead of time; everything must be covered in training.
In that way, in an actual drill, exercise or emergency, well trained personnel will be able to properly and appropriately establish priorities if time or resources are lacking to do i everything.
1
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(Rowan, Evans) We wish to stress our agreement that training deficiencies can never be dismissed as trivial, particularly since many of the problems serve to highlight more fundamental problems in LILCO's training program, at least insofar as media relations are concerned. Among other things, the flaws revealed in the Exercise demonstrate LILCO's failure to understand the nature of communication with the media and to impart this understanding through its training program for its personnel. As discussed below (particularly in the discussion of subpart F), LILCO failed to appreciate the role of the media in disseminating information to the general public and the utility failed during the Exercise to meet the needs of reporters and photographers. The failures we describe below are partly the result of misconceptions about how reporters, photographers, editors and news producers think and function. The Exercise demonstrates that LILCO's training emphasized mechanized output (in the form of EBS messages, press releases and staged briefings), yet the utility was unable to provide accurate, timely and consistent information. Moreover, the emphasis on output caused the utility to overlook the impact of what was being said upon the media and the public.
- 2. LILCO Has Not Fixed its Trainino Problems Q. Has LILCO's training program changed significantly since the February 13 Exercise such that you might have confidence that the flaws in the training program which were revealed in the Exercise have been or are on the way to being eliminated?
A. No. We are aware that LILCO has made some changes to the training program. However, our review reveals that those changes are rather insignificant, and that LILCO's same basic approach to training which was in effect before the Exercise has continued. Egg deposition of Dennis N. Behr (January 13, 1987),
at 78-79.19 Thus, we have no reason to believe that the changes which have been made and which we describe later in this testimony, will cure the serious deficiencies in LILCO's training program that were demonstrated during the February 13 Exercise.
As a result, it is our opinion that the many persons who were generally unable to carry out effectively or accurately their functions and tasks under LILCO's Plan during the February 13 i Exercise will remain unable to perform as expected by LILCO in 4
implementing LILCO's Plan, thereby precluding a finding that LILCO could and would adequately protect the public in the event of an actual Shoreham emergency.
19 In SNRC-1269, dated June 20, 1986, LILCO outlined changes it was making to its training program. However, those changes are not significant -- they largely call for small changes in the training which already has been demonstrated to be inadequate.
2 111 discussion in Part III.H below 1
Q. Other than what occurred during the Exercise and the fact that the methodology and conceptual framework of LILCO's training program have not changed since the February 13 Exercise, are there any other reasons why you believe that LILCO's training program continues to be flawed?
A. Yes. We find confirmation in our conclusion because the same kinds of problems have occurred again and again during drills conducted since the Exercise.
Q. Please provide details relating to these drills.
A. Later in this testimony, we describe in greater detail particular problems in LILCO's training program that have been demonstrated during LILCO's training drills since the February 13 Exercise. We demonstrate how these problems since the Exercise serve to confirm the Exercise results: LILCO's training program is fundamentally flawed. For now, we only provide a summary description of the post-Exercise drills that have been held so that the significance of the problems revealed can be put in perspective.
It is our understanding that from the time of the February 13 Exercise through the end of calendar year 1986, LILCO conducted six relatively large-scale training drills. Egg Drill Report for June 6, 1986 (copy attached as Attachment 7); Drill Report for September 10, September 17 and October 1, 1986 (copy attached as Attachment 8); Drill Report for December 2 and 10 (copy attached as Attachment 9). The results of these drills demonstrate that the serious inadequacies in LILCO's training program that were revealed during the February 13 Exercise continue to exist.20 The June 6 drill was LILCO's first large training drill after the Exercise. It included personnel at the EOC, the ENC and the Riverhead Staging Area (in particular, the management staff, administrative support staff, dosimetry staff, and Traffic Guides). All other LERO personnel and facilities were simulated.
Shift 2 LERO personnel participated in the drill. Egg Attachment 7 at 1.21 20 We add, however, that even if particular problems which were revealed in the Exercise results did not reappear in the later drills, our conclusion would still be that the Exercise results demonstrate that LILCO's training program was and is fundamentally flawed. The drills since the Exercise have all been on a much more limited scale than the Exercise. Further, no outside organizations such as schools, bus companies, ambulance companies, etc., participated in any of the post-Exercise drills.
Thus, it would be wrong to read into the drills any " improvement" when compared to the Exercise results. As things turned out, however, we have found no significant basis to find any " improve-ment" in the drill reports vs. the Exercise results.
21 It is our understanding that Shift 1 LERO personnel participated in the February 13 Exercise. Deposition of Dennis N. Behr (January 13, 1987), at 119.
The scenario for the June 6 drill was essentially the same as was used during the Exercise.22 Despite the similarity, the j drill documents more failures by LILCO. Thus, the drill report i
i states: "[o]verall response by the participants (was) poor."
Attachment 7 at 6. This conclusion was based, in part, upon the following problems identified during the drill.
i At the EOC, the notification for early dismissal of the schools within the EPZ was not done efficiently, and it took 48 minutes to issue an ,
1 EBS message following the declaration of an Alert
, (Attachment 7 at 2); ,
The preparation of EBS messages took too long, and several of the messages missed the 15-minute ,
deadline required by the NRC's regulations ;
(including the message for the General Emergency l declaration, which took 25 minutes to issue)
(14.);
It took too long to get the word out to the'LILCO t i staging areas about the evacuation (1d.);
Messages were not written down, or were frequently l written on scraps of paper rather than on standard
- message forms (14. at 3);
Updating of status boards at the EOC was not timely (30 - 45 minute delays) (Id.);
There was a lack of cooperation between the EOC and the EOF (14.);
-- The Special Facilities Evacuation Coordinator delayed in proceeding with the deaf notification process and in evacuating the mobility-impaired ,
- (Id. at 4);
l i
22 There were several exceptions: the length of the drill was shortened from about 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; participants were prestaged at their respective facilities; and Revision 7, rather
- than Revision 6, of the Plan was used, meaning that the dispatch of Traffic Guides to the two-mile zone and the new position of Traffic Engineer were added to the scenario. Attachment 7 at 1.
t
.s
Traffic Guides were delayed in being dispatched (by at least 40 minutes) (Id.);
The response to the fuel truck road impediment was
" confused" and the response delayed because, among other things, no one individual was in charge, information relayed to the field about the impediment's location was wrong (Route 25A vs.
Route 25), requiring the players to be " prompted" on three separate occasions, and the Traffic Engineer was unsure about his responsibilities and-became mired in details (14.);
Press releases at the ENC were not distributed in a timely manner (failure of a copier machine, repair technician showing up two hours late, etc.)
(Id. at 5);
Buses were not dispatched by the Patchogue Communicator at the EOC until " prompted" by the controller (one-and-one-half hours after buses were to have been dispatched) (1d. at 6); and Several Traffic Guides were unclear about the procedure authorizing excess exposure (14.).
Based upon the foregoing, it is not surprising that the performance of participants at the June 6 drill was rated as
" poor." What is particularly troubling is the remarkable similarity between the performance of LILCO's personnel during the February 13 Exercise and the June 6 drills they were, simply put, equally poor. This supports our view that the deficiencies in LILCO's training program revealed during the Exercise were not an aberration but, rather, are representative of what must typically be expected in the performance of LILCO's offsite emergency response personnel, given the serious inadequacies in LILCO's training program that we have already generally discussed and will detail later in this testimony.
L l
Q. You mentioned LILCO training drills that were conducted in September and October, 1986. Did the performance of LILCO's personnel during those drills show significant improvement over the performance demonstrated during the February 13 Exercise or the June 6 drill?
A. No. During drills held on September 10, September 17 and October 1, 1986, problems continued with the performance of LERO's personnel, further confirming our concerns with the adequacy of LILCO's training program.
According to the report for these drills, all aspects of LERO participated in the September / October drills, except for the ENC on September 17 and the Reception Centers and Family Tracking on September 10. One-third of LILCO's field personnel partici-pated in each of the drills, from each of the three staging areas. The exception was LILCO's bus drivers, who were at that time undergoing special training due to the problems demonstrated during the February 13 Exercise regarding their lack of fami-11arity with the bus yards and transfer points relied upon by LILCO's Plan. Attachment 8 at 1.23 23 As in the June drill, however, no outside organizations participated and LERO workers were prestaged at their respective facilities. Attachment 8 at 1.
Shift 3 personnel participated at the September 10 and 17 drills; shift 2 participated at the October 1 drill.24 The results of these drills again support our opinion that LILCO's training program is seriously flawed since there were multiple problems which again were identified.25 The report does note that shift 3 personnel were better able to cope with the drill scenario and simulated emergency on September 17 than they were on September 10. Shift 2 personnel, on the other hand, did not perform as well, "primarily due to the fact that they had not drilled since June." Attachment 8 at 12. This supports our view that LILCO's training program has been unable to provide an ongoing level of readiness. It shows again that LILCO's program has not been capable of actually getting LILCO's personnel trained so that at any time, they are ready to respond to an emergency. Since LILCO's training program essentially requires only annual participation in LILCO's training drills, there is no 24 Shift 2 had participated in the June 6 drill. According to the report, the purpose of drilling shift 3 personnel on two con-secutive weeks was to allow the participants to use the first drill as a learning process and to allow new LERO members to become familiar with their positions. The second (September 17) drill was then conducted as a " hands off" drill. Attachment 8 at 1.
25 In this regard, we note that FEMA's witnesses appear to agree with our conclusion. For example, during the deposition of the FEMA witnesses on January 28-30, 1987, the effectiveness of LILCO's training program was described as "need(ing] to be increased." Deposition of Roger Kowieski 11 al. (January 30, 1987), at 114-16, 118. In fact, when asked his impression about the fact that the same deficiencies in LERO's performance demonstrated during the Exercise also occurred in post-Exercise drills, one FEMA witness commented that he was coming to the conclusion that LILCO's " approach to training is wrong." Id. at 123 (Keller).
reasonable prospect of improvement. And even when more than one drill occurs for the same personnel separated by more than one week, the performance is inadequate. Certainly, the performance j of Shift 2 observed during the June 6 drill is more realistic of what would occur during an actual emergency than the performance of Shift 3 on' September 17, since it is certainly unlikely that
' e LERO personnel will participate in a practice drill one week before an actual emergency occurs.
i
- Q. You mentioned several drills in December 1986. Did those drills demonstrate any significant improvement in LILCO's training program?
- A. No. First, we have been unable to devote as much analysis as we would like to consideration of the December drills. This is because the drill report from the December J
drills was not provided to counsel for Suffolk County until March 6, 1987, and thus there was no opportunity to ask questions of the authors of that report.26 Notwithstanding these limitations, however, we have been
! able to review that report sufficiently to determine that there is nothing in that report which would lead us to change our conclusions. In fact, our review of the December drill report i
26 The report for the December drills is far longer and in a j
different format than the earlier reports, thus underscoring why i
it would have been valuable to have been able to pursue questions on the report during discovery.
has strengthened our conclusion concerning the inadequacy of the LILCO training program. Many of the same problems revealed during the Exercise and in the other post-Exercise drills occu,rred again in the December drills.27 These problems are discussed in the contextaof particular subparts of Contention
~
Ex 50.. '
Q. Gentlemen,y'ouhUvesummarizedyourconclusionsgleaned from the drills LILCO conducted ins 1986 after the Exercise. Are you satisfied that those drill reports accurately reflect what
~
occu? red during those drills?
j - .-
.4 ,
A.- The reporls seem generally to reflect the underlying data,1[gt, the underlying evaluation reports prepared by drill obser yrirs/ evaluators. However, we also have reviewed the underlying evaluation reports and, if anything, we would have to conclude that t'ho repor'ts are somewhat less critical of LERO I performance than the actual obcerver forms which were' filled out ,
at the time the, drills took place.
Q. Did the dr'ill reports highlight any ot'ner problems with LILCO's training or its fibility to learn by doing?
, , i n!-
l
...._______i____.a,_ ', e ., ,
27 The December drills' included all sections of LERO exdept for Relocation Center and Reception Center personnel, and ebch drill
, ' included 1/2 of the field personnel. They were the first drills iniwhich Shift 1 had participated,since the Exercise. Attachment
' 9;a t 1. '
fW 9 50 -
i ,
'/ .. .
[ . -__ P[ _ ,
A. (Perrow). Yes, there is the problem of LERO personnel turnover. .The drill reports note that there have been problems during' post-Exercise drills due to new personnel, suggesting turnover in the LERO organization. Drill reports also note lack of training of new personnel in several instances. Egg Attachment 7 at 6; Attachment 8 at 2, 4, 5, 11, and 12. Training in LERO is certainly not limited to experience in the few drills
.that LERO holds; most of the training goes on outside of the drills; the drills are in part a check on the training. So the combination of new personnel and poorly trained personnel suggests that the modules, desk-top sessions, etc. are not doing 1
their job.
For instance, the report on the June 6, 1986 drill, notes that "many of the participants were new to LERO.and unfamiliar with their. procedures and job functions." Attachment 7 at 6.
Presumably the personnel had received basic and some more advanced training before the drill, yet they still were unfamiliar with the procedures and their jobs. For the September-10, 1986 drill, it is noted that "[t]he Coordinator of Public Information was participating in his first drill, as were many of the people on his staff." Attachment 8 at 2. Despite the fact that the new Coordinator would be expected to have had some training for his new position (unless he came on just before the drill in which case he should not have been permitted to participate in the drill), the situation was so bad at the EOC in 1
this drill that the " controller assigned to the area was forced to walk the players through their procedures." Attachment 8 at
- 2. This is hardly encouraging. At the least, if there is going to be turnover in key roles, LERO's training program should make sure that back-up coordinators are available if the Coordinator of Public Information leaves the LERO organization.28 The turnover problem highlights flaws in LERO's training program. A good and effective training program has constant training to ensure good performance by personnel, even with necessary turnover. The results since the Exercise show that LILCO's program has been unable to compensate for the turnover problem. This is a serious problem with LILCO's training program
-- learning by doing is essential but due to-LERO turnover, it is obvious that learning by doing training is not occurring to the degree that should be required.
28 Other examples of membership problems also exist. At the Patchogue Staging Area, the setting up of the facilities was slow and undirected due to "the lack of experience of the participants." Attachment 8 at 4. In the same drill, for the same reason, "the personnel at Riverhead were slow to activate the facility. The controllers had to prompt and train the personnel during the drill as to their duties." Attachment 8 at
- 5. A drill or exercise is no time to do basic training; that should be done through the videotapes, tabletop exercises, lectures and so on. Similar problems occurred in the October 1, 1986 drill. In one example, at the Port Jefferson Staging Area, it is noted that "(m]any personnel at the facility were new to LERO." Attachment 8 at 11. At Riverhead, it similarly is noted,
"(m]any of the players were new to "
their position and had to be walked through their jobs . . . . Attachment 8 at 12.
l i
Q. Are there any other reasons why LILCO has been incapable of providing effective training to its personnel?
A. Yes. LERO is an intermittent organization in terms of providing effective training. LERO personnel, both individually and in their LERO roles, have no opportunity to gain experience and readiness in emergency functions through real life experience as an organization. Thus, LERO must rely upon other training, such as drills and exercises, for development of its knowledge.
LERO, however, had only one exercise and a number of drills in 1986, and the drills involved only one shift and either one-third or one-half of the field personnel each time, and several facilities were nct involved. And as noted above, the effectiveness of these drills has been diminished due to turnover.
LERO would have to have exercises and drills much more often to have the range and amount of experience that would provide proper learning. And the public and the supporting organizations, such as the schools and hospitals that are relied upon by LERO, would have to be involved to make it reasonably realistic. In short, LILCO has not demonstrated even from a mechanical point of view that it can provide sufficient training to its personnel.
(Perrow)- Further, as detailed in Part III.H.2 ofJthis.
Testimony, the-Exercise results also demonstrate structural difficulties in LERO -- a highly centralized, tightly coupled structure which, as demonstrated during the Exercise, is inappropriate for responding to the kinds of non-routine events which must be anticipated in an emergency situation. Thus, even if LERO were capable of providing for more extensive and better training, we have substantial doubts that it could succeed.
l III. DISCUSSION OF CONTENTION EX 50 SUBPARTS A. Contention Ex 50.A: Training for Unanticipated and Unrehearsed Situations Q. Please state subpart A of Contention Ex 50.
A. That subpart states:
The exercise demonstrated that the LILCO program has not successfully or effectively trained or prepared LERO personnel to respond properly, appropriately, or effectively to unanticipated and unrehearsed situations likely to arise in an emergency. Exercise actions and events which support this allegation are described in Contentions EX 38, EX 39, EX 41, and EX 42, and in the following FEMA Comments: EOC-D-1; ENC-D-1; PSA-D-1; PSA-D-6; R-D-2; EOC-ARCAs-2, 3,, 9; ENC-ARCA-2; PSA-ARCAs-5, 7, 8, 9, 10, 11.
Q. Do you agree with subpart A?
A. Yes. In our opinion, the Exercise results demonstrated that L LCO's training program has failed to train personnel to properly respond to unanticipated and unrehearsed situations.
Q. Please explain what you mean by " unanticipated" and
" unrehearsed" situations.
l l
A. An unanticipated or unrehearsed situation is an occurrence that is not expected. It is the type of situation that is not specifically planned for. Thus, personnel have not practiced responding to the specific situation.
Q. Do you make any distinction between unanticipated and unrehearsed situations?
A. No. In the context of LILCO's training program and the types of situations presented during the February 13 Exercise and referred to in this testimony, no distinction needs to be drawn; they are quite similar.29 29 An unanticipated situation takes one by surprise. It is a situation not expected to occur. Since it was not expected to happen, it was not specifically planned or trained for.- For example, during the Exercise there was a simulated traffic impediment involving an overturned fuel truck. Egg FEMA Report at 36. Although LILCO's personnel certainly expected some type of traffic impediment to be part of the Exercise scenario, this specific impediment was probably not expected. Thus, the overturned fuel truck impediment was likely an unanticipated situation.
An unrehearsed situation is somewhat different in that it is an occurrence for which a response has not been practiced. In the above example regarding the fuel truck impediment, assuming that LILCO's personnel had never previously had to clear an over-turned fuel truck that was obstructing traffic, they never would have practiced handling this situation. It thus was unrehearsed.
Thus, they would have been forced to use their judgment when responding to such a situation, and to use the knowledge and skills they should have acquired during training in deciding what to do.
Contention Ex 50.A addresses those situations for which LERO personnel have not been specifically trained or prepared to respond. It deals with the kinds of non-routine situations likely to arise in an emergency where LERO personnel would be required to rely on their experience, knowledge and perhaps common sense, as opposed to explicit directions or instructions such as: "If A happens, then do B." The issue which arises is whether LILCO's training has prepared the LILCO responders effectively to improvise and adjust to handle such situations.
In our opinion, the Exercise results document that LILCO personnel have not been trained to handle such situations.30
- 1. The Importance of Being Trained to Respond to Unanticioated and Unrehearsed Situations Q. Why is it important for LILCO's personnel to be trained to respond in a proper, appropriate and effective manner to unanticipated and unrehearsed events?
A. During an emergency, LERO personnel will likely be called upon to respond to a large number of situations that they will not have specifically anticipated or rehearsed. Traffic impediments and inquiries from the press and public are just two examples. It is essential for the proper handling of an 30 Our testimony on subpart A of Contention EX 50 relates closely to that which we provide later on subpart E pertaining to the lack of training of LILCO personnel to use good judgment and common sense. The need to use good judgment and common sense is particularly acute in responding to unrehearsed or unanticipated situations.
emergency that personnel be trained to deal effectively with these types of events and situations, even though they might be unexpected or unanticipated.
An inability to handle unrehearsed and unanticipated events can be critical. For example, failure to deal appropriately with-unexpected road impediments could mean that the protective action recommendations for the public are wrong, because they may be based on incorrect evacuation time estimates.31 Similarly, a failure to communicate unanticipated information accurately and quickly to the EOC and ENC could result in conflicting and inaccurate information being passed on to the media, which, when broadcast, might contradict information contained in EBS 31 For example, during the Exercise the Radiation Health Coordinator was not informed on a timely basis of the traffic impediments and therefore was not able to take into account their impact upon evacuation time estimates prior to evacuation recommendations. Similarly, because of the delays in dealing with impediments and further delays in imparting information about those impediments to the appropriate public information personnel, it was not until 12:55 (nearly two hours after the second traffic impediment had been injected into the Exercise) that the Public Information Staff were asked to draft an EBS message announcing a traffic problem. Even after this request was made, it took nearly an hour for the message to be drafted and broadcast. The first EBS message (EBS No. 8) containing information about the traffic impediments, advising evacuees to avoid the intersections where the simulated accidents had occurred, was not broadcast until 1:45 p.m. Egg, Observer Data Log - ENC-Ronkonkoma. Again, proper and appropriate training would have made the LERO personnel who first learned of the impediments aware of the necessity to integrate their response with that of other LERO elements. This is an example of the failure of LILCO's training program to create an organization that knows how to work together to achieve a task. Thus, even if individuals in the organization followed their procedures to the letter, without substantial learning by doing, those personnel do not know how to interrelate with other members of their organization to accomplish the overall task.
l messages. Failure to provide appropriate information in response to unexpected inquiries from the public could lead to a proliferation of rumors or misinformation, thereby increasing the difficulty of having protective action recommendations believed and implemented. And the failure of LILCO's Traffic Guides to impart correct information in response to unrehearsed questions from evacuees could result in people taking inappropriate actions contrary to LILCO's recommendations.
Finally, being able to respond appropriately to unantici-pated or unrehearsed situations is extremely important because it is a critical demonstration of whether LERO personnel have had effective learning by doing training. The essence of learning by doing is the development of the expertise and performance capability in personnel so that they have the judgment and common sense necessary to respond to non-routine events. Since emergency situations are characterized by non-routine occurrences, it is this demonstration which, in our opinion, constitutes the most critical test in terms of Exercise results regarding whether LILCO's training program for offsite response personnel has been effective. As described below, it is our conclusion that the LILCO training program has been demonstrated through the Exercise results to have been ineffective.
- 2. Examples of LILCO's Lack of Training To Respond Properly, Appropriately or Effectively to Unanticipated or Unrehearsed Events Q. What' occurrences during the Exercise lead you to believe that LILCO's training program has not successfully or effectively trained workers to handle unanticipated and unrehearsed events?
A. Before providing examples, we need to stress that there were not a great number of major unrehearsed or unanticipated events during the Exercise. Besides the two road impediment situations injected by free play messages, as well as several other events,32 there was relatively little in the Exercise which called upon LILCO to demonstrate its ability to respond appropriately and effectively to unanticipated or unrehearsed events. We find it significant that notwithstanding the relatively low challenge presented to LILCO, with respect to almost every unrehearsed or unanticipated event, some aspect of the LILCO performance was defective. This is a strong indication that the LILCO training program for such events is seriously deficient.
32 For example, the Ridge School free play message and some of the press inquiries appear also to constitute unrehearsed and unanticipated events.
I I
L (a) Road Imoediment Examoles Q. Describe the road impediments example.
A. The first example of training deficiencies concerns the manner in which LERO personnel responded to the two simulated road impediments during the Exercise. These impediments were interjected by FEMA by way of two " free play" messages. The first message, involving a loaded gravel truck and three passenger cars (hereafter, the " gravel truck impediment"), was injected at approximately 10:40. The second message, involving an overturned fuel truck (hereafter, the " fuel truck impediment"), was injected at approximately 11:00. FEMA Report at 36. LILCO did not know that these particular impediments were going to occur, and its personnel apparently had not practiced handling such impediments prior to the Exercise.33 As a result, LERO personnel were left to draw from their experience, knowledge f
j and common sense -- and, particularly, from what they had learned in pre-Exercise training -- in handling the situations as they developed.
l An examination of how these two traffic impediments were handled by LILCO reveals a major problem with the LILCO training 1
program. LILCO's personnel were unable to respond to either l
33 LILCO had attempted prior to the Exercise to convince FEMA to tell LERO players about the need to deal with impediments and re-routing. FEMA refused. Egg Deposition of Roger Kowleski, 21 11. (January 28, 1987), at 283.
L___.____._.__
traffic impediment in an appropriate manner. Rather, LILCO's responses were untimely, ineffective, and confused. And, even after LILCO had been " prompted" by FEMA to respond to the impediments, its response remained inadequate.34 For example, once LILCO finally got around to responding to the gravel truck impediment, it employed an inadequate and improper scheme for rerouting traffic around the impediment, demonstrating a lack of training on the part of LERO personnel.
Egg Teatimony of Assistant Chief Richard C. Roberts 11 al. on Behalf of Suffolk County Regarding Contention Ex 41 (Feb. 27, 1987) (hereafter, " Contention Ex 41 Testimony"), at 37, 50-55, 63-64. Furthermore, LILCO sent only one tow truck to the scene of the impediment, and no scraper was sent to remove spilled gravel from the road (nor was any simulated determination made as to whether any gravel had in fact been spilled). FEMA Report at 37, 65; LILCO Admission Nos. 158, 159. According to the FEMA 34 LILCO's attempted response to the gravel truck impediment did not actually begin in any real sense until sometime after about 12:13, when FEMA " prompted" LILCO's Evacuation Coordinator about the impediment and LILCO's failure to respond up until that time. FEMA Report at 36; LILCO Admission No. 155. As of 12:13, traffic had not been rerouted around the impediment, nor had LILCO even discussed whether there was a need to reroute traffic. Similarly, equipment sufficient to remove the gravel truck and the three disabled cars had not been dispatched, or even readied for deployment. Egg FEMA Report at 36-37. If FEMA had not " saved" LILCO by bringing the gravel truck impediment to the attention of a higher level LERO position (the Evacuation Coordinator) than the position at which the " free play" message had initially been input (the Evacuation Route Coordinator),
LILCO's response to the impediment certainly would have been even worse.
Report, the LILCO Road Crew sent to the scene of the impediment I was not even informed that the impediment involved a multiple-vehicle accident. FEMA Report at 65.
Not having anticipated the gravel truck impediment, and thus not having rehearsed or practiced responding to this type of j situation, LILCO's personnel were forced to use their knowledge, skill and judgment in responding to the impediment. Since this situation was not a routine event, LILCO's personnel had to use what they had learned in other contexts from their training, and then apply such learning to an unanticipated and unrehearsed
- situation. In this they failed, and the result was that LILCO's personnel responded in an ineffective and inappropriate manner.
i' This demonstrates, in our opinion, that LILCO's training program has been ineffective in training personnel to respond to unanti-cipated and unrehearsed situations. An effective training pro-gram would have trained personnel in the basic steps necessary to 1
remove impediments to traffic, and thus to implement effectively I
the protective action of evacuation.35 LILCO's training program, i i
however, falls far short of this result, and the consequence
. during the Exercise was reflected in LILCO's inadequate response to the impediment.
I 35 (Cosgrove, Streeter) For instance, the critical incidents response training we have discussed earlier specifically teaches personnel how to respond effectively and appropriately to road impediment situations. There was no indication in the Exercise
- performance by LILCO personnel that LILCO has provided any comparable training to its personnel.
l
Similarly, the manner in which the fuel truck impediment was handled by LILCO during the Exercise again demonstrates flaws in LILCO's training program. Although that impediment was simulated to occur at 11:00, it was not until either 1:57 (according to LILCO) or approximately 2:10 (according to FEMA) that the LILCO Road Crew directed to respond to the impediment first arrived at the scene. Egg LILCO Admission No. 160; FEMA Report at 36, 57; FEMA Admission No. 166. Thus, it took approximately three hours for LILCO to send a Road Crew to clear a major and potentially dangerous impediment. Even then, LILCO's response was only after FEMA had " prompted" LILCO's Evacuation Coordinator about the impediment at about 12:13 (the same time that LILCO was prompted about the gravel truck impediment). FEMA Report at 36; LILCO Admission No. 155. FEMA's " prompt," of course, again likely spared LILCO from even greater delays and difficulties in responding to the impediment.
Moreover, even after LILCO had been prompted to respond to the fuel truck impediment, its response remained ineffective, untimely and inappropriate. For example, after being told of the impediment, LILCO's Evacuation Coordinator discussed LILCO's response with his staff. Notwithstanding this FEMA-prompted discussion, however, as late as 1:48, LILCO's Road Logistics coordinator had not dispatched needed equipment to the fuel truck impediment site. LILCO Admission No. 157. Furthermore, LILCO employed an improper, untimely and inadequate scheme for rerouting traffic around the impediment (age Contention Ex 41 Testimony at 47-48, 55-62, 63-64), and it sent only a single tow truck to the scene of the impediment; this was clearly an inadequate vehicle, which underscores that LILCO's training had not prepared LILCO personnel to deal with real problems.36 LILCO's inadequate response to the fuel truck impediment leads us to the same conclusion about LILCO's training program that we reached in light of LILCO's response to the gravel truck impediment: LILCO's personnel, not having anticipated the types of impediments presented to them during the Exercise, and not having practiced or rehearsed how to respond to them in the context of LILCO's training program, were incapable of handling I the impediment situations in a proper, appropriate or effective manner. Forced to deal with situations that were not antici-pated, LILCO's personnel were incapable of responding adequately or effectively. Indeed, they failed to carry out a host of actions that should have been virtually second nature if their training had been effective: follow-up to ensure that instructions were being carried out; redundant communications 36 Indeed, it appears that the LILCO Road Crew sent to the scene of the fuel truck impediment was not even dispatched to l
that location until 1:50, over an hour and a half after LILCO was l
prompted into action by FEMA. Egg FEMA Report at 37. Moreover, l it was not until 2:15 -- about three hours after LILCO learned of the impediment -- that LILCO first contacted Hess 011 Company to request that it send an empty tanker truck to off-load the overturned fuel truck. FEMA Report at 37. Obviously, this call l should have been made much earlier (if only to get Hess on notice as to the possible need to dispatch a truck), since LILCO had been informed in the initial FEMA " free play" message that the overturned fuel truck was a fire hazard.
along parallel channels to ensure that communications got throught getting people to the scene to verify the logic of re-routing schemes; and verification that proper equipment had been sent.
Q. Do you believe that the kinds of impediments injected on February 13, 1986 -- the gravel and fuel truck mishaps -- were realistic in terms of the kinds of events that should have been anticipated and prepared for?
A. Yes. Capable response personnel who are to be in a position to redirect or guide traffic in the event of an emergency must be prepared for unexpected events. Major blockages of routes are certainly the kinds of impediments to evacuation that must be planned for.
(Cosgrove, Streeter) Moreover, major truck impediments, including fuel truck or gravel truck impediments, are certainly not far fetched. Indeed, in our experience as police officers, we repeatedly have been confronted with situations requiring prompt action to deal with such blockages. It is standard operating procedure to ensure that protective actions are quickly implemented, that the proper rerouting is immediately considered f
1 f
j (whether it is actually implemented or not), and that the proper I
equipment for dealing with such impediments is dispatched immediately to the scene.37 l i Q. Why does LILCO's performance in handling the simulated roadway impediments during the February 13 Exercise demonstrate, in your opinion, a failure in LILCO's training program to 1
i successfully train personnel to respond to unanticipated and unrehearsed situations in a proper, appropriate or effective
! manner?
r j A. Given the number of mistakes that were made in the
! handling of the two roadway impediments, and also qhe nature of f those mistakes, the most plausible explanation is that such l i
i mistakes were made as a direct result of LILCO's inadequate !
training program. If LILCO's personnel had been provided better [
j training, so many mistakes would have been unlikely.
I i
1 I i i
6
- 37 We emphasize the need for proper equipment. It serves no good purpose to deploy a tow truck in the event that a bulldozer is what is required for the response. That knowledge is some-thing which is gained by detailed training and experience. The i
fact that LILCO's personnel so utterly failed in their efforts during the Exercise, having had advance warning that impediments 1 to evacuation constituted one of the objectives of the Exercise, further underscores our view that the LILCO training program is j seriously deficient.
67 - i
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Based upon our experience as trainers, we have learned that when mistakes are made, they usually reflect on how well the individuals who have made the mistakes were trained.38 In our opinion, the manner in which the impediments were handled by LILCO's personnel leads us to the conclusion that LILCO's training program has been inadequate in preparing LERO personnel to respond to unanticipated and unrehearsed situations, such as the roadway impediments presented by FEMA during the February 13 Exercise.
(b) Rumor /Public Incuirv Examoles Q. What is LILCO's rumor /public inquiry system and describe briefly how this relates to training.
A. That system has been described in Suffolk County's Contention Ex 38/39 Testimony (see pages 110-15) and will not be i repeated here. In sum, even absent copier problems experienced during the Exercise, that system is cumbersome, which makes it almost inherent that there will be delay in providing responses to public inquiries.
38 We recognize that some people can be trained more easily than others, and some people possess differing levels of competence. Thus, it cannot be assumed automatically that an entire training program is inadequate because of a few mistakes by a few individuals. However, when there are as many basic mistakes as were evidenced during the Exercise, and when such mistakes are made by so many different people, then the most reasonable conclusion in that the training program in question in flawed.
Because of the inherent delays in the system as net up, however, the training of individual personnel who are on the firing line with the public is all the more important. Thus, with respect to obvious questions which should not require major research to answer, those personnel should be able to provide answers very promptly, if not immediately. This is not to say
( that there may not be instances of complicated or detailed issues specific to a particular individual as to which an operator may need expert advice from someone higher up in the response organization. However, during the Exercise any operator with proper training should have been able to say, in immediate response to a public inquiry, that the plant had not been taken over by Arab terrorists, or that the cooling towers had not blown up.
An described below and in the Contention Ex 38/39 Testimony, however, such prompt responsen did not occur. This reveals deficient training in that personnel never thought to employ alternative means to obtain updated information once it became clear -- very early in the emergency -- that they were getting information which was very late. They should have come up with a different way of getting the information since the copier machinen and the computers were not doing the job. They didn't bother to do that; they went by the bcok and proceeded to give out inaccurate and out-of-date information which, in a real emergency, could prove very dangerous. Egg Contention Ex 38/39 l \
l Testimony for a discussion as to what would happen in a real emergency given the actions of poorly trained rumor control '
1 operators.
l l
l Q. Please describe rumor /public inquiry examples from the Exercise that demonstrate that LILCO's training program has.not prepared LERO personnel to respond properly, appropriately, or f effectively to unanticipated and unrehearsed situations likely to l l
r l arise in an emergency.
A. We will discuss only a few. Additional examples are i discussed in the Contention Ex 38/39 Testimony, particularly at 120-35. In one instance, a rumor message inquiring whether the caller, from Be11 port, should evacuate was given to the Patchogue call Board operator at 12:05; a response was not relayed to the l
caller until 1:00. LILCO Admission No. 103. In another >
instance, a rumor message inquiring if lobsters caught off the ;
Shoreham jetty that morning were safe to eat was received by the Riverhead District Office at 11:30; a response was not relayed to I the originating party until 12:28. LILCO Admission No. 106.
l These are just two examples of the long time period it took LILCO personnel to respond to public inquiries during the Exercise.
- Q. Why does the length of time that it took LILCO's i personnel to respond to public inquiries demonstrate problems in LILCO's training program? !
l
A. An adequate training program would have trained LERO personnel to respond in a more timely fashion. Such training, for example, would have emphasized the need for prompt responses to inquiries from the public, as well as the need to ensure that responses are accurate, consistent and coordinated with LILCO's other public information activities. LILCO's training program, however, apparently failed to address these concerns. This is demonstrated by the fact that when faced with the public's unanticipated inquiries during the Exercise, LILCO's personnel were unable to provide timely responsen (or for that matter adequate and appropriate responnen). In our opinion, the fact that LILCO's personnel, not having anticipated the contents of the inquirien made and thus not having rehearned their responses, were unable to respond in a proper manner, demonstraten a failure of the LILCO training program to succennfully train personnel to respond properly to unanticipated and unrehearned situations. If their training had been adequate, LILCO's personnel certainly would have been able to respond more quickly, and prenumably also in a more reasoned and appropriate "anhion.
O. Do untimely responnen to unanticipated inquirien for which responnen have not been rehearned necennarily demonstrate inadequate training?
4
A. Based on the number of simulated inquiries from the public for which responses by LILCO personnel were untimely, and the fact that LILCO personnel took as long as they did in responding, the answer is yen. One untimely response to an inquiry would not necessarily support a conclusion that the training program an a whole was deficient. What occurred during the Exercise was quite different. The many instances of untimely responses reported during the Exercise lead to the conclusion 1
l that LILCO's personnel had not been adequately trained to handle the kinds of unanticipated and unrehearsed situations that must be expected when dealing with the public, especially during an emergency.
Q. Except for their failure to provide timely responsen, did LILCO's personnel otherwise respond appropriately and effectively to the public inquiries and rumors simulated during the February 13 Exorcino?
l A. No. The responnon LILCO'n personnel provided to public inquirien, in addition to taking too long, were frequently l
l inappropriate. For example, in response to an inquiry (at 7:51) 1 l from a person who "han trucks going to Suffolk," as to how extensive the annumed evacuation would be, the Ilicksv111e Call l Board operator responded (at 8:20) that the only protective action was the closing of schooln, and that there had been no evacuation recomme*;ded. LILCO Adminnion No. 114. As of 8:20,
- 12 ~
however, LERO was already beginning to " pre-stage" for an evacua-tion, and a Site Area Emergency had been declared. FEMA Report at 25. It thus was inappropriate to advise the simulated callor to proceed as planned with sending trucks into the EPZ. And even if no site Area Emergency had been declared, a more prudent and common sense response would have been to defer coming to Suffolk County until further data regarding the event had been compiled.
However, apparently not having anticipated this inquiry,39 and thus not having rehearsed a response, LILCO's personnel provided inappropriate information. This in thus anorner example of how LILCO's training program failed to teach LERO personnel to rnopond appropriately to unanticipated and unrehearsed events.
If the LILCO Call Board operator had been properly trained, it would be reasonable to expect that he would have promptly responded to the inquiry made at 7:51 in a manner that would have provided accurate, up-to-date information to the caller.
Inntead, however, the operator took almost half an hour to respond and the renponne, once made, was contrary to common i senne. LILCO's training program for those peraonnel responsibio for responding to public inquirien during a Shoreham emergency ,
therefore in called into question.
39 We believe that auch an inquiry should have been anticipated b LILCO'n training program. The fact that it apparently was not
( iven the inap repriate res is add.tional idicationoffawninLILCOponsetotheinquiry) a training.
)
i i
Q. Are there other examples of inappropriate responses to inquiries?
L A. Yes. The " Dan Rather" inquiry has been described in earlier testimony. Egg contention Ex 38/39 Testimony at 133.40 ;
The suggestion that. .joing to the plant was inadvisable but f nonetheless possible was incorrect, and such a suggestion, combined with the giving of road directions to the plant, indicated poor judgment. Proper training would have taught the LILCO operator how to handle such an inquiry -- suggest to the
- reporter that he come to the LERO ENC. LILCO's training program, however, as demonstrated by the Exercise, has been unsuccessful in providing trainees with the knowledge or skill necessary to ;
i deal with such inquiries. The result, during an actual Shoreham ;
i I emergency, would be that LILCO personnel likely would give :
misinformation or improper advice to the public, thereby impeding [
LILCO's ability to implement adequately whatever protective i measures are necessary to protect the public.41 i .
{ 40 During the Exercise a message was simulated at 11:45, purportedly from Dan Rather, who wanted "to take a TV crew into
- the Shoreham plant," and inquired how to get there. In responso,
- the rumor control responder stated: "We don't advise going to ,
the lant. There is a Site Area Emergency. You will be in the l way.p'.
plant LILCO's LILCO responder, Admission No. 119. however, On the day then of thegave directions to th Exercise, however, a General Emergency had been declared as of 9:39, and, as of 11:45, LILCO was recommending that almost all of the EP2 be ,
evacuated. FEMA Report at 25. (At 11:46, the decision was made ;
to evacuate the entire 10-mile EP2. FEMA Report at 26.) l l 41 Activities of LERO personnel during the press briefings held i durina th !
1 training.e Exercise also reveal inadequate and deficientFor example, as discus ;
j (footnote continued) l i
l
- i
- - . . ~ ~ . _ _ - _ - i
(c) Other Examoles Q. Are there any additional reasons for your opinion that LILCO's training program has been unsuccessful in training personnel to properly, adequately or effectively respond to unanticipated and unrehearsed situations?
A. Yes. The responses made by LILCO's Traffic Guides during the Exercise demonstrated training flaws. Those personnel, for example, were incapable of responding adequately to simulated inquiries from the public, which were likely unanticipated and unrehearsed because they had not been expressly discussed in connection with LILCO's " Traffic Guide Procedure,"
as set forth in OPIP 3.6.3.42 For example, only one Traffic Guide out of the 14 interviewed by FEMA during the Exercise from (footnote continued from previous page)
Ex 38/39 Testimony (see pagen 94-100), in response to questions !
from news media, the LCHO spokesperson was unable to provide detailed information concerning the traffic impediments or traffic conditions, rather than merely repeating the only information the spokesperson had -- 2122, that a truck was "down" and that another impediment had been " removed." If LERO training had been adequate, the spokesperson would have been on the phone or used other means to obtain all the pertinent and up-to-date facts relating to those incidento in order to report them to the media. Instead, the spokesperson appeared content to hand out incomplete or unintelligible information. For the reasono described in the Contention Ex 38/39 Testimony, that would have been disastrous in a real emergoney.
42 This clearly documents a flaw in that procedure. LILCO traffic guiden are to be visible, up-front responders, who should be expected to have direct contact with the public since they in theory will be providing guidanen to motorists regarding evacuation routen, etc. LILCO should have anticipated and !
rehearsed for thin situation. Tne fact that LILCO did not i further underscores tne deficiencies in the training program. ;
l
. t l the Patchogue Staging Area knew the location of the Nassau !
t i Coliseum Reception Center, and one Traffic Guide believed that the general public was to be directed to LILCO's Emergency Worker l Decontamination Facility during an actual emergency. FEMA Report i
at 64.
l Q. Why does this failure among LILCO's Traffic Guides to know pertinent information demonstrate a failure in craining?
- f j A. As in the previous examples, the results of the j i
! Exercise demonstrate that LILCO's training program has failed to train personnel to respond to unanticipated and unrehearsed l situations or events. From the last example cited, it can be
! t l
concluded that LILCO's training program has inadequately prepared l j LILCO's Traffic Guides to handle public inquiries that were not j j specifically anticipated and rehearsed. If training had been ;
adequate, it could be fairly expected that the large majority of Traffic Guides would have been able to respond to the kinds of I simple, simulated inquiries from the public presented to them i I during the Exercise, even if they had had no reason to anticipate the specific inquiries which were made or to practice or rehearse .
t l
! their responses. During the Exercise, however, it was demon- l i
l strated that the majority of LILCO's Guides were unable to respond properly to such inquiries. The most likely reason for l the widespread problema encountered must lie with LILCO's i
training program. An adequate training program would have l l !
' i E
f l
n i
i provided LILCO's Traffic Guides with the knowledge, skill and experience necessary to enable them to respond to inquiries from
! the public, whether such inquiries were anticipated or not, or rehearsed or not. In a real emergency, it would be essential for LILCO's Traffic Guides to be able to respond to inquires from evacuees and other members of the publics otherwise, any j possibility that LILCO's Traffic Guides would be obeyed or their advice followed would be severely undermined. LILCO's training program has failed to achieve this. j l !
l Finally, LILCO's training program must also be blamed for ;
i not training the Traffic Guides to obtain the necessary )
l: information promptly if asked a question whose answer they did l not know. By getting information promptly, the Guides would have '
, r l demonstrated some ability to use good judgment and common sense. !
l !
j The Exercise results show that they did not even do this !
t l
- instead, they answered the FEMA questions and did no more -- a l
\
- demonstration of the fact that LERO responded to the February 13 t
} " accident" in a very mechanical way. The training they had received prior to the Exercise -- including the dress rehearsals I l
- j. -- had clearly been inadequate. }
i ,
! [
i j )
- ? -
r% i q . ,.
- M ..~
/
- 3. The.LILCO Failures.t6' Respond Appropriately to Ungg:icioated EventsWere Not UnexDected
/ ,
,, Q2 Based on your' knowledge of LILCO's training program, would you have expected'LILCO's personnel to have been better
'~
l -
ablen.to Eespond to u$ anticipated and unrehearsed events than was b'
., [,, demonstr.2ted duri Jg'the Exercire?
A.
No. The Exercise demonstrated what we would have
, , .. c expected. We'have seen no indication from our review of LILCO's training progras"that LILCO's personnel have been trained realistically to respond to unanticipated and unrehearsed attuations. Thus, it must be expected that when faced with such situations, LILCO,'o personnel will be unable to respond prropriately or adequately.
, Rather tran providing persennel the type of realistic
./ training and post-training experiences that are essential to enable them to respond appropriately and effectively to unanticipated and unrehearsed situations, LILCO's training program consist.s primarily of classroom sessions and routine drills. During this " training," LERO personnel are generally not required to solve unexpected problems. They are trained in procedures, tot performance. They are not trained to handle surprisen, and demonstrated during the Exercise that if the response is not laid out in the procedure (L L., "if A, then do B"), they were not capable of an effective response. Yet, T:
D e unexpected situations are the " routine" to be expected in emergency situations; this is the very kind of training which is critical in developing the ability among trainees to handle unanticipated and unrehearsed situations.
Q. What type of training would enable personne] to respond appropriately and effectively to unanticipated and unrehearsed situations?
A. Training alone is not the best method of teaching 6 personnel to respond to unanticipated and unrehearsed situations.
This is because even the best training program cannot substitute completely.for the real-world experience which is essential for truly effective performance.43 However, a good training program s
can help prepare personnel for the unanticipated and unrehearsed situations they are bound to encounter when dealing with an emergency.
h
!)
4 43 Experience is especially important in teaching personnel to respond to unanticipated and unrehearsed situations. No matter how well an instructor describes what it is like to perform tasks such as crowd control or traffic control under emergency conditions, the trainee cannot fully appreciate and understand what is required to perform those . tasks under emergency r conditions until he is called upon to perform. Experience also
-enables emergency workers to perform anticipated tasks routinely or out of habit. This is crucial if the emergency worker is to make decisions quickly-and confidently, leaving him free to deal with the unanticipated and unrehearsed situations that invariably arise under emergency conditions.
s s
l 'A
To successfully train personnel to handle unanticipated and unrehearsed situations, training drills should be designed to force trainees to make decisions under pressure, 12g2, to be called upon actually to perform under conditions as close to "real" as can be achieved. Trainees then can be forced to improvise, to depart from procedures when they no longer apply.
Exercise simulation games and role-playing are accepted techniques for generating discussion and helping participants develop insight into and understanding of real-world emergency problems.
For example, in police training, extensive use is made of role playing and simulated situations to provide trainees with the opportunity to develop the ability to make quick decisions.
In these role play exercises, recruits are confronted by experienced training officers who realistically play the roles of civilians, presenting the recruit with unexpected difficulties.
The recruit is graded on his or her ability to resolve unanticipated and unrehearsed problems. This type of training is the first step in teaching a trainee to respond to unanticipated and unrehearsed situations. By practicing responding to the unexpected, the recruit is exposed to many of the situations that can arise, as well as how to respond properly to such situations.
Such training teaches the trainee "how to think on his feet" and how to make critical decisions in a timely manner.
(Cosgrove, Streeter) Similar to role playing is the use of a critical incidents response board -- a training technique utilized heavily at the Suffolk County Police Academy. As used at the Academy, the critical incidents response board amounts to a scale model of a community. Most typically, this training device involves having the entire class stand around the board, with particular recruits assigned as " active participants." The active participants are assigned miniature police vehicles with specific numeric designations. They are then given information (the same type of information that they would be given by a police dispatcher) concerning, for example, some type of critical traffic accident, such as an overturned fuel tanker, and then they are instructed to respond to a certain location (e.a., an intersection) on the critical incidents board. The active participants ther poeition their vehicle, develop a plan for responding, and coordinate with back-up units and support personnel. Other persons play the roles of these responders and thus a great deal of human interaction is achieved.44 44 It should not be suggested that Suffolk County Police are fully trained just on the basis of critical incidents response board training. When a police recruit in Suffolk County graduates from the Police Academy, he has already received a great deal of training necessary to prepare him to handle unanticipated and unrehearsed events in the field. Nevertheless, immediately after graduating, the rookie officer spends the next three months working exclusively with experienced field training officers; he is observed and evaluated under real conditions.
This enables him to gain experience in handling unanticipated and unrehearsed situations under the supervision of the more experienced police officer.
l 1
1 (Zook) The City of Little Rock, Arkansas, has developed what is known as the " Emergency Mobilization Exercise." This exercise is a simulation of a major disaster in which emergency response personnel are called upon to respond as if an actual emergency had occurred. The exercise serves both as a training tool and as a method of evaluating the effectiveness of the training which emergency response personnel had previously received.45 The Emergency Mobilization Exercise demonstrates what can be expected when emergency personnel have been successfully and effectively trained. For example, during one Emergency Mobilization Exercise, the collapse of a large section of bleachers at the local football stadium was simulated. Under the exercise scenario, this incident resulted in over 100 persons being trapped and injured. Power lines were knocked down and gas pipes were ruptured. Injured victims were role played by volunteers. The injured had every type of injury imaginable; some were suffering mental or psychological shock.
45 Although there are similarities between the Emergency Mobilization Exercise and the Exercise of the LILCO Plan, there are also major differences. For example, contrary to the LILCO Exercise, in which Shift 1 knew they would be called, knew it would be on February 13, and knew the Exercise objectives in advance, the Emergency Mobilization Exercise occurs without the participants knowing what is going to occur or when the emergency will be staged. Further, the Emergency Mobilization Exercise
, requires emergency personnel actually to respond and perform most emergency tasks under nearly realistic conditions, rather then to simulate them as during the LILCO Exercise. In addition, all facets of an emergency response are exercised and evaluated, from schools to hospitals, unlike the situation during the LILCO Exercise.
=
The exercise began with a call to an ambulance company by a
" hysterical" individual, who related what had happened at the stadium. Following this call, over 500 emergency response workers from organizations as diverse as utility companies, hospitals, ambulance companies, and taxi cab companies responded to the accident. Truck drivers, the press, police and fire fighters all responded.
Throughout the exercise, personnel responded to what was an unanticipated situation in a manner which demonstrated an effective emergency response. Immediately after the ambulance company was called, the police arrived at the scene (having been called by the ambulance company). Off duty and auxiliary police personnel were quickly called in, and emergency personnel were requested from the local power, gas and telephone companies.
Ambulance, taxi and trucking companies were also requested to send available vehicles to assist. These requests were communicated in a prompt and efficient manner, resulting in necessary emergency personnel and equipment arriving at the scene of the emergency shortly after the event had begun.
Hospitals were also notified of the accident and doctors and nurses were sent to the scene. Vehicles were dispatched to pick up these medical personnel. Further, the power and gas companies were contacted and quickly turned off the downed power lines and shut off the gas leak. Emergency telephone lines were set up at I
the accident scene by the phone company. The exercise continued
, until all of the injured had been taken to hospitals for treatment. Afterward, the performance of emergency personnel was I critiqued, and the results conveyed to the participants.
i This exercise, and others like this one which are periodically held in Little Rock and by other organizations with which I am familiar, demonstrate that, with proper training, knowledge of job responsibilities, and' sufficient energency response experience, acceptable performance can be expected to occur. When individuals know the tasks they are to perform and are properly trained in how to perform them, they can be put into an unanticipated, crisis situation and perform successfully.
The type of training provided by such techniques as role playing and critical incident response boards helps prepare trainees for the many kinds of unanticipated and unrehearsed situations that they may face in the real world. They force the trainee to respond to high pressure situations that have never been rehearsed, practiced or anticipated. Through such training, the trainee can begin to learn how to respond quickly and effectively to unanticipated and unrehearsed situations. The more training of this nature that is provided, the better prepared the trainee will be for the many different types of i
situations with which he may be faced in an actual emergency.
LILCO personnel, by contrast, were unable to respond during the Exercise in an adequate manner, despite three years of l training. However having reviewed the LILCO training program, it seems clear why this occurred. Quite simply, LILCO's personnel have not been adequately trained to respond to an emergency situation. They have not been taught how to perform their tasks, and they appear to have little idea about what their responsibi-lities are in relation to the overall LILCO Plan. Most importantly, LILCO's personnel lack any real experience in responding to emergency situations.
LILCO's training program, as previously discussed, fails to provide anything like the type of training we have just described. Probably closest to what we are referring to are the LILCO " tabletop sessions." However, rather than being ways to compel LILCO's personnel to practice unanticipated and unrehearsed events, these tabletops are merely seminar-type sessions. Thus, LILCO's personnel might talk about procedures or describe how they think they would react to posited problems.
But they would not be given the opportunity to learn by doing --
to perform. LILCO's tabletop sessions, therefore, could perhaps help to teach the Plan to trainees; they could not, however, teach job performance. LILCO's failure to provide the type of training which allows for on-the-spot, innovative decisionmaking
by trainees largely explains in our opinion why LILCO's personnel performed so poorly when faced with unanticipated and unrehearsed events during the Exercise.
Q. Are you saying that LILCO, irrespective of the quality of its training program, could not train workers to respond to unanticipated and unrehearsed situations?
A. No, although we have very real doubts in that respect.
What we are saying is that a training program such as that contained in LILCO's Plan, can only go so far in achieving this goal, and as demonstrated during the Exercise, it clearly has not gone nearly far enough. Since LILCO does not offer its personnel actual field experience, it needs to compensate by otherwise ensuring that its training program is of the highest possible caliber. The LILCO training program, however, not only is not of the highest caliber, it is inadequate. Rather than having numerous realistic drills that require trainees to respond to the unanticipated and unrehearsed situations which they likely would face in a real emergency, LERO personnel participate only infrequently in drills, and even those they do participate in are i
most often unrealistic, with little consideration given actual
- performance in the kinds of unexpected and unanticipated l
situations that may arise in an actual emergency.
Thus, it is clear from the Exercise results that there has been very little " learning by doing" training by LERO. The examples we have discussed should not have occurred if there had been substantial learning by doing training. Further, the examples below also reflect problems which should have been identified and fixed before the Exercise if LERO had established a rigorous and effective program for learning through experience.
The fact that these problems arose in the Exercise is strong additional evidence of fundamental flaws in LERO's program --
that LILCO's training program has failed to train by experience and doing.
The first set of problems deals with resources and physical changes needed to make LERO operate properly.
- An unreasonable amount of time was required to cover one area simulated to have a siren failure (FEMA Report at xiv, xv, xvii, 57);
A disruptive public address system at Riverhead (FEMA Report at xvii, 72);
- Lack of mileage indications on map for Route Alert Driver (FEMA Report at 74, 75);
- Insufficient space on status boards in the EOC, resulting~in the mixing of DOE RAP and LILCO field monitoring team data (FEMA Report at 30, 40);
- Poor maps for finding mobility-impaired individuals (FEMA Report at 66);
- Insufficient staff for the Bus Dispatcher at Patchogue (FEMA Report at 66);
- Need to have additional room to reduce dosimetry distribution time for bus drivers, and additional staff (FEMA Report at 62);
- Shortage of equipment and absence of equipment at i
Patchogue (FEMA Report at 64).
Revision of Message Form was needed to reflect which items are "new" items (FEMA Report at 72).
Many of these examples may seem minor, and many perhaps could be easily corrected. But, they are significant evidence of the flaws in LILCO's training problem. If there had been vigorous, realistic practice sessions involving well-trained LERO personnel, LILCO would have detected these problems long before the Exercise. The fact that they apparently went undetected during three years of training highlights that LILCO's training program has not prepared its personnel for the practical needs involved in responding to an emergency. This is particularly true since even the February 13 Exercise only revealed deficiencies in the relatively few areas of LILCO's performance actually observed by FEMA.
Next, are some problems with procedures disclosed in the Exercise; they reflect in large part the lack of experience training in the field, and the kind of common sense adjustments that only an organization with more experience or much better training can make.
Patchogue Staging Area personnel did not request sufficient information regarding impediments to evacuation (FEMA Report at 65);
A radiological exposure team stopped within the plume to radio results, thus incurring unnecessary exposure (FEMA Report at 51, 52);
- Posting of status board information did not reflect time of posting (FEMA Report at 72);
- Numbering scheme needed to reflect order of messages (FEMA Report at 71);
- Failure to read dosimetry levels by bus driver during 75 minute trip (FEMA Report at 59);
- Security problems as revealed at Patchogue Staging Area (FEMA Report at 61).
There also were communication, control, notification and briefing problems in the Exercise that should have been corrected prior to the Exercise if LERO had learned through experience.
- Four LERO members failed to verify their initial notifications on the automatic verification system and the Lead Communicator had to take time out to contact them by telephone (FEMA Report at 28);
- Confusion existed about notification of the FAA, and it was not clear where the procedures for this were located or that they even existed (FEMA Report at 29, 39; LILCO Admission No. 200);
I I
}
l Inadequate provisions for handling messages to the Director of Local Response when he is not at his station (FEMA Report at 31); ,
Projected data were reported as actual data for two and one half hours (FEMA Report at 33);
Unclear procedures on notification systems could lead to confusion (FEMA Report at 34);
Lack of alternative notification and response procedures for field impediments (FEMA Report at 37, 38);
Extraneous and possibly confusing information (clearly marked for deletion) in EBS messages was left in for the press to see (FEMA Report at 53);
- Inadequate means to assure that the Bus Drivers arrive at the proper Transfer Point (FEMA Report at 66).
Finally, there were problems with technical information that have a similar character.
- Complex information on the use and meanings of dosimetry readings poorly or wrongly communicated and acted upon by those who needed them (FEMA Report at 68);
- Existence of two scales for measuring distance (feet and meters) led to conversion errors that could have been serious, and a delay in correcting the error (FEMA Report at 33);
- Mistake in stating thyroid dose level requiring evacuation by the Health Services Coordinator (FEMA Report at 33).
To repeat, these are some of the items in the Exercise that suggest that a great deal of repertoire adjustment, and opportunity for the various elements and individuals in the LERO organization to work together under realistic emergency conditions, would be needed in order to have an emergency organization capable of performing its assigned task. These items are important because emergency tasks such as deciding upon and' communicating protective action recommendations to the public, controlling an evacuation, and implementing relocation following a radiological emergency are highly interactive and highly time dependent operations, particularly in a highly-centralized, tightly-coupled organization such as LERO. Many things must mesh in order to succeed; small delays, misunderstandings, information errors, etc., could trigger a wide range of subsequent failures. The failures revealed during the Exercise all support our view that the LILCO personnel have had little effective training. In particular, the foregoing problems
i
]
all document the failure of the LILCO training program to prepare LERO personnel for real implementation of the Plan. Accordingly, the training program is fundamentally flawed.
- 4. LILCO Has Not Corrected its Failure to Provide Training in Responding to Unanticipated and Unrehearsed Events Q. In the June, September, October, and December drills which have been referred to previously, did LILCO provide its personnel with any greater opportunity to learn to respond to unanticipated and unrehearsed events?
A. No. Notwithstanding the poor performance at the Exercise, the subsequent drills have continued to be largely unrealistic in terms of this sort of training. For instance, the June drill used fuel truck and gravel truck impediments.
Although some of the players in the June drill were different from those in the February Exercise, they must surely have known the parameters of the earlier scenario. Thus, this was no real opportunity to learn to respond to an unanticipated or unrehearsed event.
4 l
r
l Similarly, in most of the other drills, the " unanticipated" and " unrehearsed" events included gravel truck impediments and fuel truck impediments. Such a lack of variation by LILCO underscores the fundamental deficiencies in LILCO's training program.46 What is most significant about LILCO's training program since the Exercise, however, is that LILCO has failed to learn that not only must there be unanticipated events with which to practice, but that the practice in the drills or exercises must include performance. Rather, LILCO continues to run its scena-rios and drills in a mechanical manner that purports to have people go to locations and follow procedures and to conclude from 1 that " demonstration" that there is adequate performance. That is not the case. There must be an opportunity for actual performance of emergency functions -- such as in the critical incidence response board utilized by the Suffolk County Police Academy -- before there can be any basis for any confidence in the ability of personnel to perform. Since LILCO has continued 46 In the December drills, LILCO introduced four impediments.
They involved a brush fire, a duck truck, a cement mixer truck, and a cesspool truck. In our opinion, these small additions to the list of unanticipated events do not compensate for the overall lack of realism in LILCO's training program. This is especially true since despite the poor performance by Shift 1 in responding to traffic impediments during the Exercise, the expedited dispatch of field personnel in response to traffic impediments was not even an objective of the December 10 drill. at 48.
to ignore the need for actual performance, one must conclude that LILCO's ability to respond to unanticipated and unrehearsed events remains as it was during the Exercise -- deficient.
+
Q. - You draw a distinction between practicing procedures and. performance. What do you mean?
A. Following procedures is important, since it is part of the basic training that provides the necessary foundation for more advanced t' raining.47 But, following procedures is not enough, particularly in the context of unanticipated events. No
, set of procedures can anticipate all contingencies. What is necessary, therefore, is a training program that forces trainees to think, not just to follow procedures. This is accomplished by performance -- actually responding to free-play events such as we have previously discussed. Only in that manner can trainees gain realistic understanding regarding what an actual emergency response may entail.
Q. To the extent LILCO has included road impediments in its post-Exercise drills, has its performance been adequate?
A. No. In the June 6 drill, LILCO personnel responded to a simulated road impediment, which was essentially identical to the fuel truck impediment that was simulated during the Exercise.
47 In the next section of this testimony, we discuss LILCO's
- failure to train its personnel to follow procedures.
LILCO's performance was described in the LILCO's own drill report as " confused" and the response to the impediment was " delayed."
Attachment 7 at 4. Specific comments included the following:
o .The Transportation Support Coordinator should have done a better' job of keeping control and managing his group during the road impediment scenarios. No one individual was assigned to be in charge of handling these impediments. Because practically all groups in the EOC need to be made aware of such a problem it is important that one individual be responsible for coordinating this effort.
o The RHC (Radiation Health Coordinator] was not made aware of the impediment to evacuation until 2:15 PM; 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 30 minutes after the event had occurred.
o The EBS message telling of the road impediment was issued at 1:29 PM; almost 45 minutes after the
- ' event had occurred. In addition this important piece of information was included with the entire EBS message and might have been missed by the general public. A special EBS message should have been issued.
o The message for the second road impediment was called into the EOC and was properly logged on c message form, however when the information was relayed to the field, the wrong road was mentioned; Route 25-A vs. Route 25. The word came back from 1
the controller, simulating a route spotter, that i there was no impediment at the location indicated.
At that time it was assumed that the impediment was either a false alarm or had been cleared, and no i follow up action was taken. It was not until the controller in the EOC prompted the players three times to review the original message that any action was taken.
Attachment 7 at 4-5.
i As with the Exercise, therefore, during the June 6 drill the lack of practical, hands-on, learning-by-doing training resulted in LILCO personnel being unable to respond to a simulated road 1
impediment in a timely or effective manner. This repeated problem further underscores that LERO's personnel have been inadequately trained to implement the LILCO Plan.
This is further demonstrated by LERO's performance in later drills in which similar impediments were simulated. For example, during the September 10 drill there was approximately a one-half hour delay at the Road Crew Communicator's desk in transmitting the message to respond to one of the impediments. Attachment 8 at 3. In fact, the problem with road crews was so bad that despite repeated requests from the Traffic Guide at Traffic Control Post #45 for a road crew to respond to a traffic impediment, the road crew never arrived. Attachment 8 at 5.
During the September 17 drill, problems occurred concerning the generation of rerouting information and the determination of new evacuation time estimates. Attachment 8 at 6. Performance during the October 1 drill also was flawed. According to the drill report, the Traffic Engineer had to be prompted to develop revised evacuation time estimates. Attachment 8 at 9. In addition, problems were noted concerning the flow of information into the public information office. Attachment 8 at 9.
Finally, the December drills further demonstrated the inadequacy of training to handle unanticipated events. For j example, in response to the gravel truck impediment during the l
1 t
December 2 drill, a heavy duty wrecker necessary to clear the impediment had not arrived over one hour and fifteen minutes after it was requested by a Road Crew. Attachment 9 at 26-27.
More problems were reported on December 10. In responding to a simulated brush fire that had blocked the entire Long Island Exprescway as well as another major artery, critical information was not communicated. For instance, in communicating the message to the EOC, LERO personnel at the ENC failed to mention the roads that were blocked. Attachment 9 at 4. Demonstrating their lack of training and experience, EOC personnel failed to note this at the time and thus did not request the critical information. In fact, it wasn't until prompted by a controller to recontact the ENC that the Traffic Group acquired the information. Attachment 9 at 4. Further, the Traffic Group did not even begin investigating rerouting or the fire's effects on evacuation time estimates until over half an hour after learning of the fire. at 4. In addition, in response to a duck truck impediment, long delays and improper communications were noted. at 10. Further, the drill report indicates that the time it took a road crew to arrive at the scene of the duck truck impediment after it was dispatched (57 minutes) was "less than adequate". Attachment 9 at 31.
Thus, the post-Exercise drills support what the Exercise demonstrated -- inadequate training, lacking practical, learning-by-doing experience, resulted in LERO being unable to take necessary actions in a timely manner to protect the public.
It must be emphasized that the repeated failures by LILCO in the post-Exercise drills came after the FEMA Report, after SNRC-1269 (Attachment 10) detailing LERO's adjustments in response to the FEMA Report, and after, presumably, extensive remedial training.
What these failures do, therefore, is emphasize again the fundamental flaws in LILCO's training program.
B. Contention Ex 50.B: Failure to Train Personnel About Basic Knowledge and Information Essential to Imolement the Plan and Procedures
- 1. Introduction Q. Please state subpart B of Contention EX 50.
A. Subpart B states:
The exercise demonstrated that LILCO's training program has been ineffective in instructing LERO personnel to follow and implement the LILCO Plan and LILCO procedures, and in imparting basic knowledge and information essential to the ability to implement such procedures. Exercise actions and events which support this allegation are described in Contentions EX 36-39, EX 41, EX 42, EX 45, EX 49, and in the following FEMA conclusions: EOC-D-1; ENC-D-1; R-D-2; PSA-D-6; EOC-ARCAs-2, 5, G, 7, 9; PJSA-ARCA-1; PSA-ARCAs 3,4,7,8, 9, 12, 13, 14, 15, 16; R-ARCAs 4, 5, 6; RC ARCA 1.
1 1
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l Q. Do you agree with subpart B?
'A. Yes, the Exercise demonstrated that LILCO's training program has been ineffective in instructing personnel to follow and implement the LILCO Plan and procedures. It has also been ineffective in imparting basic knowledge and information to personnel essential to their ability to implement such procedures. Our conclusion is based upon the numerous occasions during the Exercise where LERO personnel failed to follow and implement LILCO's Plan. Such failures demonstrate a major f problem with LILCO's training program. When personnel, after three years of training, are not able to follow and implement the Plan that they have been trained to implement and cannot demonstrate even the most basic knowledge necessary to implement established procedures, it becomes clear that whatever training has been provided has failed. Indeed, an inability to implement a plan and procedures after so much time constitutes strong l evidence of an unsuccessful training program, since, if anything, training individuals to follow a plan is one of the simplest, yet j most important, things for which people can be trained. ;
This failure of LILCO's training program is serious for two 1
other related reasons as well. First, the demonstrated inability to follow the Plan and procedures involves an area which has received primary emphasis in the LILCO training program. Thus, while earlier we discussed the failure of the training program to t
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address the crucial aspect of emergency performance of dealing with unexpected and unanticipated events, the deficiencies discussed in this section relate to areas obstinately covered, and covered extensively, by LILCO's three-year training program. !
Thus, the LILCO training failure is particularly serious.
j.
Second, as we discussed earlier, it is extremely important for LERO personnel to learn basic aspects of LILCO's Plan. This 1'
is the " routine" training. The routine tasks -- which include
! following the Plan and procedures -- must be really well known, in order to enable the emergency personnel to deal with all the l non-routine things they are going to have to deal with. During a j real emergency, people are not going to have time to have to think hard about whether or not they need to read their dosimeters, how to write down messages, etc., because they are :
going to have to be thinking hard about how to deal with I unexpected situations. Therefore, if the " routine" tasks cannot
.be done by rote, performing them will take up all the time and i
intellectual energy that the LERO personnel have, leaving none to
) deal with immediate non-routine problems of a real emergency.
i Thus, it is crucial for LERO personnel to be able to follow the LILCO Plan and to be able to implement its procedures since
! the Plan contains the guidelines and methods that LILCO has devised for handling an emergency at Shoreham. If those individuals responsible for responding to an emergency at ,
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- - _ _ _ . - _ _ __, . - . . , _ . - - . . _ , _ _ _ _ , - . _ _ ~ . _ - _ , . _ . ,
Shoreham cannot follow the guidelines established for carrying out their functions, there would obviously be no assurance that LILCO could adequately protect the public's health and safety.
Further, we repeat that an ability to follow and understand the Plan and procedures is absolutely critical if LERO personnel are to be able to then improvise to respond to unanticipated and unrehearsed situations. Without such basic understanding, the ability to respond to these more difficult situations will be lacking.
- 2. Examples of LILCO's Failure to Provide Effective Training to Provide Personnel with Basic Knowledge on How to Follow and Imolement the Plan and Procedures (a) Introduction Q. Can you provide examples from the Exercise that demonstrate the ineffectiveness of LILCO's training program in teaching LERO personnel basic knowledge essential to follow and implement the LILCO Plan and procedures?
A. Yes, there are many. The following events or occurrences support our conclusion about the ineffectiveness of LILCO's training program in instructing personnel to follow and implement the LILCO Plan and procedures. Many of them also document LILCO's failures to teach its personnel even the most basic information about the anticipated emergency response.
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i
l The difficulties experienced by LILCO's Bus Drivers in locating residences and going to wrong locations (e.g., FEMA Report at xv, xvi, 65 and 66);
-- Erroneous announcements of pertinent information by personnel (e.g., FEMA Report at 33, 68 and 69; FEMA Admission No. 174);
-- Mr. Brill, the BNL scientist assisting LILCO at the ENC, provided answers inconristent with the EBS messages (Videotapes of Press Briefings held at ENC during the Exercise);
Inadequate use and readings of dosimetry equipment and failure to know excess exposure levels, excess exposure authorization procedures, KI ingestion procedures (e.g., FEMA Report at 59, 68-70, 76, and 77);
Excessive route alerting times (e,q., FEMA Report at xiv, xv and xvii);
Delayed dispatching of personnel (e.g., FEMA' Report at xvi, xviii, 37, 41, 57-58, 62, 66-67, 74-75; LILCO Admission Nos. 132, 140, 173);
Use of wrong security procedures (g2gt, FEMA Report at xv, 61 and 63);
Incorrectly completing message forms (e.a., FEMA Report at xvii, 42, 71-73);
Excessive time in monitoring personnel (e.a., FEMA Report at xviii, 80-81; LTLCO Admission No. 195; FEMA Admission No. 180);
Confusion in contacting the FAA (e.g., FEMA Report at 29, 39; LILCO Admission No. 200);
-- Pertinent information not included on message forms (e.g., FEMA Report at 30, 37, 39, (5, LILCO Admission Nos. 152, 153, 154);
Untimely internal communications of information (e.g., FEMA Report at 36-37, 39; LILCO Admission No. 155);
-- Failures to provide press information in timely manner (e.q., FEMA Report at 52-53; LILCO Admission Nos. 74-79, 91 and 93);
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Extraneous information included in EBS messages (e.a., FEMA Report at 53);
Dissemination of out-dated information by rumor control personnel (e.o., FEMA Report at 53; LILCO Admission Nos.96-100);
Traffic Guides not knowing. location of reception center or where public was to be directed for monitoring and decontamination (g2gt, FEMA Report at 64; FEMA Admission No. 168);
Personnel not reporting to assigned locations or where directed to go (gigi, FEMA Report at 64-65; LILCO Admission Nos. 174, 175);
Failures to update status boards (e.o., FEMA Report at 72, 73);
Personnel directed to wrong places by their superiors (e.g., FEMA Report at 65, 67; FEMA Admission No. 175).
(b) Communications Problems in Dealing With Traffic Imoediments
- 0. Did LILCO's handling of the traffic impediments indicate a failure to train personnel in basic knowledge essential to follow the Plan and procedures?
A. Yes. LILCO not only was unable to respond to the unanticipated aspects of those events, it also was unable to follow basic procedures that were applicable. In fact, the response of LILCO's personnel to the impediments involved numerous instances where the LILCO Plan and procedures were not followed or implemented.
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_ _ _ _ _ _ _ _ _ _ _ _ )
Q. Please give examples.
4 A. First, according to the Plan, the Evacuation Coordinator directs LERO's actions in the areas of traffic control, transportation, and evacuation. OPIP 2.1.1, p. 26.
However, during the Exercise, the Evacuation Coordinator was never informed by LERO personnel of either of the two FEMA " free
, play" impediment messages. FEMA Report at 36. This was contrary
- to OPIP 3.6.3, which requires such communication. This failure to advise the Evacuation Coordinator of the two simulated impediments, as well as the lack of status updates and other necessary communications between and among other LERO personnel, l including the Evacuation Route Coordinator, the Traffic Control Coordinator, the Road Logistics Coordinator, the Transportation Support Coordinator, Lead Traffic Guides, Road Crews, Evacuation Route Spotters, and Evacuation Support Communicators, were violations of LILCO's Plan and procedures, which these personnel
- ~
had supposedly been trained to follow. This failure to follow -
the-Plan or implement its procedures led to substantial delays by
) LILCO in responding to the impediments.
[ Second, LERO personnel at the EOC failed to include essen-1.
tial information communicated to them via the " free play" impediment messages on LERO message forms, nor did they otherwise i
l communicate such critical data to the other LERO personnel expected to respond to the impediments, as required by OPIP 3.6.3 I
t
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w -,,.,-,-cr,- r ,-~ , r-,,-., , , . , ~ - - , - , - -.m-r-- - , . . . , .r,n --.n,---, ,-.n ---,-.---_---,.---,,,,,,-----c._e-
and OPIP 4.1.2. Egg FEMA Report at 30; FEMA Admission No. 71.
For example, important information was not included on the 10:45 LERO message from the Evacuation Route Coordinator to the Evacuation Support Communicator for Route Spotters / Road Crews regarding the gravel truck impediment, including the fact that three passenger cars were involved in the accident. Similarly, essential information was not included on the 11:06 LERO message from the Evacuation Route Coordinator to the Route Spotter / Road Crew Communicator regarding the fuel truck impediment, including the facts that fuel was leaking, that there was the possibility of fire, and that both shoulders of the road were blocked. Egg FEMA Report at 30. LILCO's Plan requires that such information be communicated. OPIP 3.6.3 at 12.
4 a
Because LILCO's training program was unsuccessful in instructing personnel to follow the Plan and procedures, and in imparting basic knowledge and information essential to their ability to implement such procedures, the equipment eventually I
sent to respond to the gravel truck impediment was inappropriate and inadequate to remove the simulated obstruction. Similarly, the equipment eventually sent to respond to the fuel truck
- b. impediment was so substantially delayed that LILCO's response was t
not even observed by FEMA. Egg FEMA Report at 37, 39, 57-58.
Q. Were there any other communications problems pertaining to the impediments situation?
o
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a
"9 l
" A. Yes. There were at least four others. First, the
. s+ Evacuation Coordinator and other LERO personnel were not properly informed concerning.a " visual check" of the simulated fuel truck impediment received by the Transportation Support Coordinator from the Bus Dispatcher at the Patchogue Staging Area. Appro-priate actions therefore were not taken in response, contrary to OPIP 3.6.3, 3.6.4 at 2, until more than three hours after the
" free play" message regarding the impediment had been injected.
Egg FEMA Report at 30, 57.
W
, Second, LERO personnel were unable to locate, communicate with, or timely dispatch a Route Spotter to investigate and verify the simulated fuel truck impediment. They were also un-able even to determine whether a Route Spotter had actually been a
dispatched. Thus, at about'11:15, the Route Spotter / Road Crew Communicator requested the Port Jefferson Evacuation Support Communicator to determine whether a Route Spotter had been dispatched as required under the Plan, and as apparently assumed by the LERO players. The Route Spotter was not in fact dispatched until about 12:02. Egg FEMA Report at 37; FEMA Admission No. 69.48 l
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l 48 LILCO has indicated that the Route Spotter was dispatched at 11:40. LILCO Admission No. 53. At any rate, there clearly was confusion and delay with regard to dispatch of the Route Spotter.
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Third, although the FEMA controller had informed the Evacuation Coordinatoriof the gravel and fuel truck impediments at about 12:13 (FEMA Report at 36; LILCO Admission No. 155, as of 12:40), the Transportation Support Coordinator had not been
~
informed that-bus evacuation route M-1 was potentially blocked by the gravel truck impediment. Egg FEMA Report at 36; FEMA-Admission No. 68; kn1 agg LILCO Admission Nos. 52 and 161. Thus, the initial errors, omissions, and failures to follow procedures and accurately transmit information were compounded by additional errors even after the first errors had been identified for LERO by FEMA.
Fourth, as a result of the numerous failures to follow the Plan and the resulting delays in internal LERO communications, information concerning the road impediments and the need to avoid the blocked evacuation routes was not communicated to the public until about 1:45, when EBS message number 8 was simulated. LILCO Admission No. 163.
Q. Why do these examples-of communications mistakes that occurred during the Exercise in response to the two traffic impediments demonstrate that LILCO's training program has been ineffective in instructing LERO personnel to follow and implement the LILCO Plan and procedures?
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A. The fact that LERO personnel failed to follow the Plan and its procedures in relation to communicating pertinent information in a timely manner indicates that they were not effectively trained. LERO's personnel had received three years of training and Pad participated in dress rehearsal drills
~
immediately prior to the Exercise. If, after three years of training and dress rehearsals, LERO personnel could not follow the Plan and communicate basic information as required under the Plan, it is reasonable to conclude that whatever training they had been provided had been unsuccessful. An effective training program which had achieved any measure of success in teaching LERO personnel the Plan and procedures and in imparting the necessary knowledge to enable such personnel to implement the Plan and procedures would have reduced dramatically the number of mistakes that were made by LERO personnel during the Exercise in communicating information relating to the road impediments. When other mistakes made by LILCO in handling the road impediments are also considered,49 the failure of LILCO's training program becomes even clearer.
In. addition, several other comments are in order. First, I
l the FEMA free-play message was injected at the EOC, not in the field. This meant that only one-half of the LERO communication 1
, network had to function. (If the mesrage had been injected in l
'the field, the communications would have had to go from the field 49 Egg, e.o., our earlier testimony regarding Contention Ex 50.A; Contention Ex 41 Testimony.
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to the EOC and back to the field; in the Exercise, it only had to go from the EOC to the field. Egg Contention Ex 41 Testimony at 32-33, 42. Despite this somewhat less demanding scenario, LILCO's training was still not adequate.50 Second, the communications difficulties reveal training deficiencies because the LILCO personnel should have figured out alternative means of coping with the problems and failures of communication. For instance, after having received the first FEMA prompt, the Evacuation Coordinator and/or other coordinators should have followed up/ double checked /given redundant orders, etc., to assure that the same kind of failures didn't happen the second time around. In fact, they did happen again. Thus, the point is not only should LERO personnel be trained to follow the procedures, but they should be trained to understand that if the procedures don't work or are not followed, they must come up with other ways of achieving the desired result. Thus, these difficulties underscore that LILCO's training program has failed to teach LERO personnel to handle real life interactions and complexities.
50 ~~~heunderstandthatLILCOhassuggestedthat injecting the message at the EOC was unrealistic. However, news of impediments often is learned about by headquarters personnel via phone calls, rather than by field personnel.
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_(c) Failure to Follow Plan and Procedures in Dealino with the News Media Q. Does LILCO's performance during the Exercise in dealing with the media provide bases for your support of subpart B of Contention EX 50?
A. Yes. The inability of LILCO's training in instructing personnel to follow and implement the LILCO Plan and procedures is further demonstrated by the manner in which LERO dealt with the media during the Exercise. On numerous occasions, LERO personnel were unable to provide timely, accurate, consistent and non-confusing information to the news media at the ENC. Thus, they failed to implement the LILCO Plan (particularly at pages 3.8-4 thru 3.8-6) and procedures (particularly OPIP 3.8.1). This is discussed extensively in the Ex 38/39 Testimony-(pages 26-29; 66-79; 81-85;92-100 in particular). Thus, the details will not be repeated here.
Q. LILCO has stated that it was untimely in providing information to the news media because'of copier problems.
Assuming the hardware could be replaced or improved, would that affect your opinion concerning LILCO's ENC performance during the Exercise or its training program?
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.. . . -- . . - . . - - - . - -_ .- - - . . -- .~
' t A. No, it would not, for several reasons. First, hardware problems had nothing to do with decisions, made.by the " trained" LERO personnel at the ENC, to tolerate long delays in providing ,
information to the media or even deliberately to withhold information from the media. Specifically, the almost 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />
- delay in activating the ENC was of no apparent concern to the LERO personnel, since no alternate means of providing information to the press -- even in lieu of having officially set up the ENC I-
-- were implemented during the Exercise. Similarly, the decision by the LERO spokesperson to withhold information about the general evacuation advisory until the next press conference had nothing to do with copier problems.
Second, hardware problems at the ENC persisted even in subsequent drills after the hardware " fixes" had supposedly been implemented. The fact is'that a well-trained emergency response team would be in a position to deal with hardware problems because they are inevitable. If adequately trained, they should be able to implement alternative methods of transmitting I important information. Yet, time after time, the LERO personnel demonstrated their inability to do so effectively.
Third, the copier problems also have nothing to do with the 4
apparent unawareness by the " trained" LERO personnel of how the
. media operates and what its reactions would be to the types of f failures that occurred. As discussed in the Contention Ex 38/39
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E. u_ ; _ . _ _ ... ,..., _ _ _ __ _ , _ _ . _ , _ , _ . , _ . . _ _ _ _ _ _
Testimony, which we will not repeat here, the media will not tolerate the kinds of delays which LERO consistently demonstrated during its drills.- In a real emergency, such delays would render the ENC irrelevant because the media would seek other sources of information, whether they were informed sources or not.
Q. LILCO has also argued that deficiencies revealed at the ENC during the February 13 exercise are trivial because the most important matter was getting the EBS messages to the public, not-providing information to the media. What is your response to that argument?
A. From the training perspective, we absolutely disagree.
We do not address here the ramifications upon the public information program of LILCO's failures. That is discussed in the Contention Ex 38/39 Testimony. From a training perspective, however, the failures of ENC personnel are significant, even if one were to assume, incorrectly in our opinion, that those ENC activities are irrelevant to an overall emergency response. The fact remains that there are public ir. formation provisions in LILCO's Plan and procedures, and it has purportedly trained its personnel to implement those provisions and to do so properly.
The Exercise revealed that those personnel were incapable of doing so. Therefore, our point remains valid regardless of whether one considers providing information to the media important or not.
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What must be emphasized, however, is that LERO's
. demonstrated lack of concern during the Exercise for the untimely distribution of information to the media demonstrates a fundamental unawareness by LERO -- and a fundamental failure of the LILCO training program -- to understand the importance of timely distribution of data to the media. The media would not be content during an actual emergency to await LERO's schedule in providing information about the course of the accident. Rather, the media would be insistent about receiving up-to-date information about the accident. In our experiences, we have learned that in emergency situations there often is no time to prepare written reports. The media will not tolerate such delay.
The media will only stay at an emergency news center as long as it believes that it is being provided with the most current and accurate information available. If the media is not receiving such information, it will leave the news center and respond to other areas of activity in order to obtain the information.
(d) Other Examples of LILCO's Failure to Train Personnel in How to Follow and Implement the Plan and Procedures Q. Are there additional examples which support Subpart B of Contention Ex 50?
A. Yes, there are a number of other examples. First, the response of LERO personnel to the Ridge Elementary School " free play" message further supports our concerns regarding the
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inadequacy of LILCO's training program and the inability of LERO's personnel to follow the Plan. We address this in more detail in our discussion of subpart C (Section III.C.1 below).
Second, communications relating to release data and dose projections were not handled properly or accurately during the Exercise, as required by OPIP 3.6.1. For example, LERO personnel failed to designate clearly on the EOC dose assessment status boards the distinctions between DOE RAP monitoring data and LILCO field monitoring data. Egg FEMA Report at 29-30. This failure demonstrates not only an inability to effectively communicate important dose information and potentially significant distinctions between the information from the two sources as required by OPIP 3.6.1, but also the failure of the training program to teach the significance of that distinction, contrary to the requirements of OPIP 3.6.1.51 51 Similarly, during the Exercise downwind distances of sample readings by field monitors were incorrectly reported as 7000 meters instead of 700 meters for a thyroid dose. This error resulted in an initial calculation of thyroid dose as 900 mrem /hr at 4.3 miles downwind, instead of 9000 mrem /hr at about 0.5 miles downwind. Egg FEMA Report at 33. Furthermore, at the EOC, several extrapolated doses at various distances were reported as actual measurements rather than as projected data on the dose assessment status board -- an error that took two and one half hours to identify and correct. Egg FEMA Report at 33. These failures indicate an inattention to detail and accuracy in recording, processing, and communicating data critical to the accident assessment and protective action recommendation pro-l cesses which are at the core of an emergency response and are required by the LILCO Plan.
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Third, LERO personnel at the staging areas evidenced an inability to accurately, appropriately, or in a' timely manner obtain, record, transmit, or act upon emergency data, in violation of OPIPs 4.1.2, 3.6.3, 3.6.4, 3.6.5,_and 3.9.1. For example:
(i) Personnel at the Riverhead Staging Area did not ,
properly record or appropriately identify event status .informa-tion on Emergency Event Status Forms or on status boards as j required by the. Plan. Sag FEMA Report at 72.
, (ii) The. Bus Dispatcher at the Patchogue Staging Area, in violation of the Plan, repeatedly made inaccurate and
! misleading announcements to bus drivers concerning the dose levels at which-they were to call in. These incorrect instructions concerning such important information led to confusion on the part of the bus drivers. Egg FEMA Report at 68, 69.
l i
(iii) The Transfer Point Coordinator at the Brookhaven National Laboratory Transfer Point was unable to follow instruc-
- tions and transmit information and directions from the staging i area to bus drivers. For example, he directed a bus driver to i-l the EWDF despite the fact that a message from the Bus Dispatcher i
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j to all Transfer Point Coordinators had directed that all drivers arriving at transfer points before 4:00 should be directed to the Nassau Coliseum Reception Center. Ege FEMA Report at 65, 67.
Finally, LILCO's Traffic Guides were uninformed about important information required for Plan implementation. For example, only one Traffic Guide out of the 14 interviewed by FEMA from the Patchogue Staging Area knew the location of the Nassau Coliseum Reception Center, and one Traffic Guide believed that the general public was to be directed to LILCO's EWDF. FEMA Report at 64. LILCO's Traffic Guides also did not fully understand the chain of command for authorization of exposures in excess of the general public PAGs. In addition, some Traffic Guides indicated to FEMA that they might question the authorization of other LILCO personnel (specifically, the Lead Traffic Guides) regarding excess exposure. FEMA Report at 69.
This lack of knowledge on the part of LILCO's Traffic Guides highlights the failure of LILCO's training program to impart necessary knowledge to LERO personnel to enable them to implement the LILCO Plan and procedures. Certainly, LILCO's Traffic Guides have received " training" during the past three years regarding the chain of command for exposure in excess of the general public PAGs, the procedure regarding authorization for excess exposure, and the location of facilities relied upon by LILCO for monitoring and decontaminating evacuees. Notwithstanding this
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I t.
1 1
\
E " training", however,.the Traffic Guides evaluated by FEMA during the Exercise were uninformed and generally unable to answer i
questions concerning basic information in LILCO's Plan.
Accordingly, one must conclude that the LILCO training program has been ineffective in instructing LERO personnel to follow LILCO's Plan and procedures. Equally clear is the conclusion that such training as-has been provided has failed to impart basic knowledge to LERO's personnel necessary to implement the LILCO Plan.
- 3. LILCO Has Not Corrected its Failure to Train 4
its Personnel in Basic Knowledge Necessary to Imolement the Plan and Procedures
- Q. Has anything occurred since the Exercise that changes your opinion about the inability of LILCO's training program to instruct LERO personnel to follow and implement the LILCO Plan and procedures?
A. No. In fact, the performance of LERO personnel during drills held since the Exercise reinforces our conclusion that LILCO's training program has been unsuccessful in instructing personnel to follow the LILCO Plan and implement its procedures.
i For example, during the February 13 Exercise, some personnel failed to demonstrate a clear understanding about procedures .
regarding allowable exposure levels, i.e.,
. Sig FEMA Report at 68, 76. Now basic training, if provided i
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i
properly, should be able to take care of that. But, the same problem emerged in the later drills. For example, during the June 6, 1986 drill, several Traffic Guides were still not clear about the procedures. Attachment 7 at 6.
Q. After at least two warnings in the area of measuring and acting upon exposures, in the February 13, 1986 Exercise and the June, 1986 drill, did LILCO take action to insure that everyone was trained?
A. We assume LILCO tried, but it was clearly not success-ful. During the September 10 drill, "of the 9 Traffic Guides questioned most of them were not aware of the maximum allowable
' dose, and the proper procedures governing the use of KI."
Attachment 8 at 4-5. One week later, after debriefing and presumably some training, the Traffic Guides were reported to be knowledgeable about proper radiation and exposure control.
Attachment 8 at 8. So it appears possible for LERO to provide basic training that will last at least a week in such matters, which are really quite predictable and routine matters. But the problem in this area, which goes back at least to the February 13, 1986 Exercise, keeps appearing. The same dosimetry I
problem appeared in the September 10 drill with Road Crews, two of whom, dispatched from Riverhead, "were not aware of the proper i
procedures regarding the use of dosimetry and maximum exposure allowances." Nor were they " properly informed to take their KI i
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tablets." Attachment 8 at 6. And then, the report on the October 1 drill reports the problem again affecting traffic guides: "Of the 5 Traffic Guides questioned, all were unclear as to the maximum allowable doses." Attachment 8 at 11.
The maximum allowable dose is not a trivial matter for these individuals, or the organization as a whole. However, the underlying principle is what is most important: the failure to train individuals in this matter, after repeated warnings that the training was not adequate, documents a fundamental failure of the LERO training program. After all, this is a relatively easy task compared to others that LERO will confront in an emergency.
Also, one can reasonably expect that of all the material presented in a training program, the trainees would make the greatest effort to learn those procedures involving their personal safety. If these are not learned, other material not as crucial to personal safety surely have not been learned.
Nevertheless, even after several failures, the problem still appears.
Q. Are there other examples from the later drillo that further demonstrate the ineffectiveness of LILCO's training program in instructing LERO personnel to follow and implement the Plan and procedures?
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A. Yes. During the September 10 drill, for example, an EBS message was broadcast without the simulated sounding of the sirens. Attachment 8 at 2. However, the LILCO Plan requires that EBS messages be broadcast in coordination with the activation of LILCO's sirens, to ensure that the public is alerted to the need to listen to an emergency broadcast station.
Plan at 3.3-4. This failure to follow the Plan was, according to the drill report, the result of poor coordination between the Director of Local Response and the Coordinator of Public Information. Egg Attachment 8 at 2. Such lack of coordination clearly reflects inadequate training.
Also during the September 10 drill, the Radiation Health Coordinator ordered the ingestion of KI prior to performing the required calculations necessary to justify this action.
Attachment 8 at 3. This was a violation of the LILCO Plan and illustrates again the failure of the LILCO training program to effectively instruct personnel to follow the Plan.
Another example from the September 10 drill which illustrates the fact that LILCO's training program has been ineffective in instructing personnel to follow the LILCO Plan and procedures is that LILCO's personnel who reported to establish the EWDF during the drill were not familiar with their jobs and took no action until prompted by the controller. Further, these LILCO personnel were unfamiliar with the location of the storage i
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rooms for EWDF equipment and the equipment checklist was not used as set out in LILCO procedures. Attachment 8 at 4.52 In a real emergency, the fact that LERO personnel had not been effectively trained to set up the EWDF and to follow procedures in checking emergency equipment could result in the EWDF not being functional or available to emergency personnel.
Further, during the September 10 drill, personnel at the.
LILCO staging areas were slow to activate their facilities.
According to the drill report, "the controllers had to prompt and train the personnel during the drill as to their duties."
Attachment 8 at 5.53 The fact that personnel were not trained effectively in how to set up the staging areas, requiring that they be trained during the drill, is an obvious indication.that 52 This does not appear to have been an isolated problem.
During the September 17 drill, the Emergency Preparedness group failed to fulfill their role in properly checking equipment at the EWDF. This resulted in several pieces of faulty equipment being used to monitor emergency workers. Attachment 8 at 7. In addition, contrary to LILCO procedures, during the September 17 drill dosimetry equipment was issued at the same time that dosimetry briefings were held. This resulted in some emergency workers not receiving adequate briefings. Attachment 8 at 8.
53 Similar problems arose on October 1. Thus, "the Lead l
Traffic Guides needed guidance to perform their function and implement their procedures." Attachment 8 at 11. In addition, personnel at the Riverhead Staging Area "had to be walked through their jobs either by more experienced people or by the control-1ers." Id. at 12. These failures to have personnel knowledge-able about their jobs demonstrates a serious flaw in the LILCO training program. Obviously, when personnel have to be walked through their jobs, a training program has been unsuccessful in instructing them how to follow and implement the Plan and procedures.
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LILCO'sLtraining program has been ineffective in instructing personnel in ongoing readiness and in how to follow and implement the LILCO Plan and. procedures.-
Q.. Did similar problems arise in LILCO's December drills?
A. Yes.- Both drills contain numerous examples of personne1~failing to follow and implement the Plan and its procedures. During the December 2 drill, for instance, there were delays in the pre-staging of bus drivers because procedures were not followed. Attachment 9 at 11. Rather than follow procedures and pre-stage buses at the appropriate time, the Manager and Evacuation Coordinator wanted to wait until all bus drivers arrived at the staging areas to issue the order, even though this would result in the late dispatch of the drivers.
Attachment 9 at 11.54 The December 10 drill demonstrated problems as well. This is especially troublesome since the same personnel that were drilled on December 2 were drilled on December 10, and the December 2 drill was designed to teach personnel the procedures.
54 Further, during the December 2 drill, the Patchogue Staging Area Coordinator failed to fill out OPIP 4.1.4, Attachment 4, as
- required under LILCO procedures. Attachment 9 at 16. And the
- Lead Controllers at Patchogue failed to follow procedures by not l- documenting critical actions and decisions. Attachment 9 at 16.
Also on' December 2, traffic guides were frequently dispatched l much too late, resulting in their not arriving at their posts until over an hour after the EBS message recommending evacuation i was issued. Attachment 9 at 19-20, 21, 24, 27-28.
1.
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t
Egg Attachment 9 at 1. Thus, despite receiving training one week earlier, some personnel still failed to follow the LILCO Plan and its procedures.
For example, during the December 10 drill, critical informa-tion concerning the roads being blocked by a traffic impediment was not properly communicated, resulting in delays in responding to a simulated impediment that blocked the Long Island Expressway and another major artery. Attachment 9 at 4. Further, despite a requirement to confirm the delivery of messages from family members of LILCO personnel back to the family tracking center, this was not done. Attachment 9 at 12. In addition, in direct violation of procedures, the Director authorized exposure of up to 10 REM for a field worker without consulting the Radiation Health Coordinator. Attachment 9 at 12. Finally, as with the December 2 drill, traffic guides did not arrive at their posts within one hour after the issuance of the EBS message to evacuate. Attachment 9 at 32, 35, 39-40.
Q. Please summarize your conclusions concerning the effectiveness of LILCO's training program in instructing personnel to follow and implement the LILCO Plan and procedures.
A. LILCO's training program is seriously flawed in this regard. When what occurred during the Exercise and what occurred f during the drills are examined, the seriousness of the problem i
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becomes clear. The many mistakes made and the many examples that exist of failures by LERO personnel to follow and implement the LILCO-Plan and procedures demonstrate that the deficiencies revealed during the Exercise were not the exception, but the rule. This is particularly significant since the LILCO training program concentrates on the LILCO Plan and Procedures as the basic training material. The drills reveal, however, that despite the training, personnel have still not been successfully trained to carry out the functions they are assigned under the LILCO Plan and procedures. As a result, it must be concluded that LERO personnel would be unable to implement the actions called for by LILCO's Plan and necessary to protect the public health and safety in the event of an actual emergency at Shoreham.
C. Contention Ex 50.C: The Exercise Results Demonstrate that LILCO has Failed to Teach Personnel to Communicate Effectivelv Q. What does Contention Ex 50.C (along with Contention Ex 23 and the bases of Contention Ex 45) allege?
A. Subpart 50.C and the other cited contentions allege that the Exercise demonstrated that the LILCO training program has not successfully or effectively trained LERO personnel to communicate necessary and sufficient data and information, to inquire and obtain such information, or to recognize the need to do so. Specifically, subpart C states:
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t
The exercise demonstrated that the LILCO training program has not successfully or effectively trained LERO personnel to communicate necessary and sufficient data and information, to inquire and obtain such information, or to recognize the need to do so. Exercise actions and events which support this allegation are described in Contentions Ex 34, 36, 38, 39, Ex 41, Ex 42, Ex 45, and in the following FEMA conclusions: EOC-D-1; ENC-D-1; EOC-ARCAs 4, 5, 6, 7, 9; ENC-ARCA 2; PSA-ARCA 8, 9, 11, 12; R-ARCA 1.
Contention Ex 23 and the bases of Contention Ex 45 are found in Attachment 6.
Q. Do you agree with Subpart C and the other contentions considered with it?
A. Yes. A review of what occurred, and perhaps even more importantly, what did not occur during the Exercise, indicates that the LILCO training program has not successfully or effectively trained LERO personnel to communicate necessary and sufficient data and information, to inquire and obtain such information, or to recognize the need to do so.
- 1. Examples of Lack of Communication Training Which Were Reflected in the Exercise Results Q. Please give examples of lack of communication training as reflected in the Exercise results.
k
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A. There are numerous examples of communications difficulties which arose in the Exercise which reflect a lack of training. Perhaps the most glaring example has already been discussed in some detail -- the communications difficulties arising out of LILCO's handling of the free play impediments events. Egg Section III.B.2.b above and also the County's Contention Ex 41 Testimony, especially pages 33-38. We will not repeat discussion of the handling of these impediments.
In our opinion, the communication failures discussed in the cited testimony, demonstrate an ineffective and unsuccessful training program. Presumably, LILCO attempted to train its personnel to communicate the kinds of information involved in LILCO's responses to the two simulated impediments during the Exercise and such communication is clearly required by the LILCO Plan. Nevertheless, the manner in which communications were handled in response to the traffic impediments during the Exercise indicates that such training was ineffective and unsuccessful.
Q. Are there additional examples of breakdowns in communications between and among LERO's personnel which you believe demonstrate a failure in LILCO's training program?
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i
A. Yes. Another example relates to the response of LERO personnel to the Ridge Elementary School " free play" message.
The message requesting LERO to provide a bus'and driver to assist in transporting 40 children from Ridge-Elementary School was given to the Evacuation Coordinator at the EOC at approximately 10:30. The request was communicated to the Special Population Bus Dispatcher at the Patchogue Staging Area within about 10 minutes, but the staging area personnel did not respond appropriately or quickly in processing the communication. As a result, the bus driver was not even dispatched to a bus yard to pick up a bus for 40 minutes. Egg FEMA Report at 38, 66.55 Furthermore, there were no apparent efforts by LERO personnel to follow up on their dispatch orders during the approximately three hour period prior to the report that the driver had arrived at the school.
An effective training program would have taught LILCO's personnel the importance of obtaining and communicating information in a timely manner. It would also have instilled in LILCO personnel the need to follow up on communications. Based on the Exercise performance, however, LILCO's training program has apparently failed to instruct workers in how to perform
, communications tasks, has neglected to teach workers the necessary skills to enable them to perform these tasks, and has
! 55 We note that LILCO has claimed during discovery that the
- message was given to the Public School Coordinator, not the Evacuation Coordinator, and that the bus was dispatched in 34 rather than 40 minutes.
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not provided personnel with enough follow-up practical experience to allow them to learn the skills necessary to communicate effectively. Further, LILCO's training program has not taught personnel the importance of following up on communications and making sure that tasks are completed. This is a serious flaw of the LILCO training program, since, in our opinion, little is more-important to an effective emergency response organization than effective, timely communications.
The foregoing communications problems pertaining to the Ridge Elementary School, as well as the others already discussed, also provide additional examples of the failure of LILCO's program to teach " learning by doing." If the LILCO program had been effective, LILCO personnel would have had sufficient experience such that they would recognize the need for prompt and timely communications and follow-ups thereon. It is elemental to proper emergency response that communications work swiftly and efficiently and that the personnel in charge of responding understand the necessity for such timely and efficient communications. LILCO's performance during the Exercise leads to the conclusion, however, that its personnel communicate in a mechanical manner, attempting at best to follow procedures, without demonstrating any clear understanding of the purposes of the communications and the importance of prompt follow-ups.
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i.
E Q. Are there further examples from the Exercise which demonstrate the ineffectiveness of LILCO's training program in teaching personnel to communicate necessary and sufficient data and information, and to recognize the need to do so?
A. Yes, there are many, including the following:
LERO was unable to notify or communicate emergency information to the FAA in order to have air traffic diverted from the EPZ (ggg FEMA Report at 29);
The Long Island Railroad was not contacted during the Exercise in order to divert trains from the EPZ (Egg FEMA Report at 29);56 Communications relating to release data and dose projections were not handled properly or accurately (for example, LERO's failure to designate clearly on the EOC dose assessment status boards the distinctions between DOE RAP monitoring data and LILCO field monitoring data (agg FEMA Report at 29-30),
l downwind distances of sample readings by field monitors were l
l incorrectly reported as 7000 meters instead of 700 meters for a thyroid dose (agg FEMA Report at 33), and several extrapolated l doses at various distances were reported as actual measurements l
l 56 Although such communication was not specified by LILCO's Plan, it should have been obvious that there was a need for LILCO to divert trains from the EPZ.
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l l
l rather than as projected data on the dose assessment status board l
-- an error which took two and one half hours to identify and correct (agg FEMA Report at 33)).
The LERO Director apparently left the " command room" on several occasions, and therefore was not available to take calls over the RECS telephone or the dedicated telephone -- a situation that was made worse by the fact that his secretary (who took the calls in the Director's absence) merely told the callers that the Director would call back, and failed to take a message in writing and carry it to the Director immediately upon completion of the transmission. Egg FEMA Report at 31, 42; LILCO Admission No. 210.
LERO failed to have key events or evacuation status boards in the EOC command room. Thus, updated information on the status of the emergency situation was not visible to LERO workers in those areas at all times. Egg FEMA Report at 30.
In our opinion, these failures indicate a failure of training. The inattention to detail and accuracy in recording, processing, and communicating data critical to the accident assessment and protective action recommendation processes which are at the core of an emergency response would not have occurred had training -- particularly learning by doing training -- been successful. Similarly, these failures to obtain or communicate
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vital data, and to have updated information available and visible in the command room, could have impaired the ability of command personnel to perform their duties in a real emergency. LERO personnel should have been effectively trained to ensure that these problems did not arise. If training had taught personnel the realities of an emergency and stressed _the importance of proper communication, these problems probably would not have arisen.
The failure of LILCO's training program to effectively train
, personnel in communicating necessary and sufficient data and information was also demonstrated during the Exercise by the fact that LERO personnel at the staging areas evidenced an inability to accurately, appropriately or in a timely manner obtain, record, transmit, or act upon emergency data. For examples
-- Personnel at the Riverhead Staging Area did not properly record or appropriately identify event status informa-tion on Emergency Event Status Forms or on status boards (agg i
FEMA Report at 72);
-- The Bus Dispatcher at the Patchogue Staging Area i repeatedly made inaccurate and misleading announcements to bus drivers concerning the dose levels at which they were to call in ,
(ggg FEMA Report at 68);
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The Transfer Point Coordinator at the Brookhaven Transfer Point was unable to follow instructions and transmit information and directions from the staging area to bus drivers during the Exercise (for example, directing a bus driver to the EWDP despite the fact that he had been directed to send all drivers to the Nassau Coliseum Reception Center (ggg FEMA Report at 65).
Q. Are there any other communication examples demon-strating inadequate training?
A. Yes. A final example that demonstrates the failure of LILCO's communications training, as evidenced by the Exercise, is the fact that LERO personnel at the EOC and staging areas were unable to transmit consistent or accurate information concerning j
alleged assistance from the Suffolk County Police Department
("SCPD") to each other during the Exercise. The facts appear to have been roughly as follows.
.J At 9:19, the LERO Manager was informed that no County resources would be available to assist LILCO during the Exercise.
Egg LILCO Admission No. 178. This fact was confirmed at 10:15, 10:26 and 10:36, according to the logs kept by the LERO Manager and Director. However, at 9:20, the Evacuation Coordinator recorded in his log that the SCPD had offered to provide LILCO whatever assistance was required, and the Traffic Control l
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C - _ _.---_---_--------- --J
e Coordinator was advised of this purported information at 9:35.
At 10:02, the Evacuation Coordinator notified the staging areas
~
that the SCPD had offered assistance on traffic control, route alerting, and route spotting, and that police officers would be dispatched to the staging areas for briefings. Egg LILCO Admission No. 181. And, between 10:02 and 10:15, the Traffic Control Coordinator informed: (i) the Riverhead Staging Area to expect 39 SCPD officers to report for assignment to traffic control and route spotting functions; (ii) the Port Jefferson Staging Area to expect 74 SCPD officers; and (iii) the Patchogue Staging Area to expect 37 SCPD officers. These messages, all of which conflicted with the facts known and recorded by the LERO Manager and Director, were in turn transmitted to Lead Traffic
. Guides, Dosimetry Recordkeepers, and other staging area personnel. The erroneous information which had been communicated I /. to.the staging areas was not corrected until approximately 10:50, b approximately an hour and a half after the information first came to the LERO Manager.57 This example demonstrates again severe deficiencies in LILCO's communications training. Clearly conflicting information had been communicated to LERO command personnel. But the false
,s, '
informacion was not corrected for over an hour. In a real emergency, such misinformation could obviously have resulted in 57 LILCO has stated that the corrections were made between
.10:26 and 10:50. LILCO Admission No. 182.
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serious problems. It could cause LILCO responders to count on assistance when, in fact, none was on the way, thus delaying the overall response.
If there had been strong learning by doing training, we are confident.that the various parts of LERO would have learned of their interrelated functions and would have established means of ensuring that such false information was quickly_ stopped. LERO's failure in promptly correcting the data during the Exercise leads us to conclude that the training for LERO personnel had been ineffective.
- 2. The Communications Deficiencies Which Were Demonstrated Durina the Exercise Are Sianificant Q. Why do the foregoing examples lead you to conclude that the LILCO training program has not successfully or effectively trained LERO personnel to communicate necessary and sufficient data and information, to inquire and obtain such information, or to recognize the need to do so?
A.- Given an effective and successful training program, and .
particularly one that had exposed personnel to realistic learning by doing experiences, we would not expect the number of communications mistakes made during the Exercise. The fact that mistakes were made by such a large number of LILCO personnel in relation to so many different events throughout the Exercise leads us to conclude that LILCO's communications training has
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E
been ineffective, particularly since the information on the number of communications problems is largely limited to those items observed or identified by FEMA evaluators during the Exercise.
Q. Are the training deficiencies related to communications important in your opinion?
A. Yes. Based upon our experience in emergency response situations, we cannot stress enough the importance of timely, accurate, and common sense communications during an emergency situation. Indeed, such communications provide the backbone of a successful response, not only in terms of the abilities of the emergency response personnel to perform their tasks, but also in terms of the media and the public having confidence in those responses.
In short, without accurate and timely communications which have credibility, an emergency response is doomed to failure. In this regard, we also emphasize that there are no da minimus communications problems. Communications, to be successful, depend upon detailed training and extensive learning by doing experience. Indeed, for police personnel, effective
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communications are perhaps the most difficult task to be learned, requiring. repeated learning by doing experiences before an adequate proficiency level is reached.58 Based upon our review of the exercise data, it is clear to us that LILCO's personnel have not come close to. reaching a proficient level in the communications area. This must be attributed to their training deficiencies, since it is only by effective (often tedious and repetitive) training that adequate communications skills can be learned. Furthermore, the repeated failures in communicating essential information, and in following the procedures which expressly require such communications, also indicate to us that the LILCO training program has failed to instill in LERO personnel any sense of the importance of accurate, timely, complete and appropriate communications during en emergency. This is an extremely serious flaw in the training I
58 (Cosgrove, Streeter, Colwell, Zook) In our experience as trainers, we have learned the necessity for indepth, detailed communications training. Through the use of role-playing, trainees learn just how easily communications can get fouled up.
For example, one technique that has been used effectively in training recruits in proper communications skills, is to have the instructor tell one recruit a story involving numbers, dates, etc. .The recruit then tells the story to a second recruit, who tells it to a third recruit, and so on. This entire process is videotaped. The results the first time this is done are distortion of critical information due to inattention to detail and failure to listen. The students also learn the consequences of their mistakes. However, further training emphasizes these skills through frequent, almost daily, role playing, drills, and written exercises. This training enables the recruit not only to learn the proper methods of communicating, but also the consequences of improper communication.
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_ . __ . _ _ _ ._.~._
program, because absent an understanding of the importance of effective, accurate communications, LERO personnel can never be expected to perform well.
- 3. LILCO's Communications Training Program Has Not Been Fixed Q. Has your review of drill reports since the Exercise changed in any way your conclusions concerning Contention Ex 50.C?
A. No. Our review of the drills since the Exercise has reinforced our view that the LILCO training program has been 4
unsuccessful in the area of communications.
Q. Do examples from the June 6, 1986 drill support your view?-
A. Yes. For example, during the June 6 drill personnel frequently failed to write down messages. And, in those instances when they were recorded, they were often written on scraps of paper and then transcribed onto the standard message form. Also, during the drill the EOC ran out of message forms.
When this occurred, messages were not written down at all.
Attachment 7 at 3. The failure to write down messages on message forms, as LILCO procedure dictates, could result in information being miscommunicated or not communicated at all, allowing critical information to go unattended. This problem, as
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documented below, has occurred'in every drill since the Exercise.
If personnel cannot be taught the simple task of writing down messages on message forms, then the communications training ,
clearly has been unsuccessful.
In addition, during the June 6 drill, key information was frequently communicated in an untimely manner or not communicated at all. For example, it took between 10 and 15 minutes to inform
- the staging areas about the evacuation. Attachment 7 at 2.
Further, the Patchogue Communicator at the EOC did not transmit the message to dispatch buses until prompted by the controller in Patchogue. This was one and one half hours after the message was given to him by the bus coordinator. Id. at 6. As a result of these problems, the report concluded that "(i)nformation flow to other groups within the EOC . . . was almost non-existent." 14
~
Clearly, such failures to communicate information in a. timely
, manner, or at all, demonstrate a training program that has been ineffective in instructing personnel to properly communicate
. essential information.
Another example that illustrates the continued failure of the LILCO training program in the area of communications relates to the handling of the fuel truck impediment during the June 6
- 2. drill. The Radiation Health Coordinator was not informed of the fuel truck impediment until one and one half hours after it had occurred. Attachment 7 at 4. Further, the message for the fuel i
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e -,--c - --e- ,w.- ,,--. ,m,, - . , , , - . , , + .-----------,--,---,r- , , - , , . , . . ,-,--,v,-.
truck impediment was not relayed accurately to the field. In fact, similar to what occurred during the Exercise, the responders were directed to the wrong road. This created the assumption that the impediment was a false alarm. If the j controller had not three times prompted the players to review the original message, LILCO personnel would never have noticed their mistake. 14 In addition, during the June 6 drill, information was not provided to the public in a timely fashion. According to the drill report, "(t)he response by the public information group in getting the information out to the general public was not as rapid as it should have been." Attachment 7 at 6. For example, it took 48 minutes for LILCO personnel to issue an EBS message following the declaration of the Alert. This resulted in the early dismissal of schools being unnecessarily delayed. Id. at
- 2. Further, it took 25 minutes to issue the EBS message for the General Emergency following the decision to initiate protective actions. Id. Finally, the EBS message informing the public of the road impediment was not issued until almost 45 minutes after the impediment had occurred. Id. at 5. LILCO's delays in the issuance of EBS messages led to the conclusion that "(t)he preparation of EBS messages took too long," with several of the messages missing the 15 minute deadline by a significant amount of time. Id. at 2.
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l
! In sum, therefore, the results of the June 6 drill strongly
[
support our conclusion that LILCO's communications training is I
flawed. The kinds of fundamental errors which occurred during l
that drill should never have occurred if effective training had been provided.
l 1
L Q. Have you reviewed the September 10, September 17 and October 1, 1986 drill reports in connection with your testimony on Contention Ex 50.C?
A. Yes. There are many additional examples which support our conclusion that LILCO has failed to train LERO personnel to communicate necessary and sufficient data and information, or to recognize the need to do so. For example, during the September 10 drill, the EBS messages for the simulated traffic impediments were again slow in being generated, and the wording was ambiguous and was not concise. In addition, as noted previously, one of the EBS messages was broadcast without the sounding of the sirens. Attachment 8 at 2.
Further, due to communications failures, the dose assessment staff in the EOC had difficulties in obtaining data from the dose assessment staff in the EOF during the September 10 drill.
Attachment 8 at 3. Moreover, during that same drill, messages were not transmitted in a timely matter. For example, in one instance there was an approximately one half hour delay at the
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Road Crew Communicator's desk in getting a message transmitted.
Id. In another instance, the dispatch of the Route Spotters from the Riverhead Staging Area was delayed because the message from the EOC took 20 minutes to go from the Administrative Sup-port Staff to the Lead Traffic Guide. 14. at 5. These delays, in our opinion, illustrate that LILCO's training continues to be unsuccessful in instructing personnel to communicate essential information in a timely manner -- a problem that was also demon-strated during the Exercise and in other LILCO drills since the Exercise. Certainly,-there is no basis from the September 10 drill (or the later ones) to conclude that LILCO's communica-tions/ training deficiencies have been fixed.
Further, as with the June 6 drill, the September 10 drill report concluded that "(t)he use of message forms needs to be improved."' Attachment 8 at 3. Many personnel were observed using scraps of paper to transmit messages. This resulted in appropriate copies not being-distributed and messages being incorrectly transcribed on message forms. Id.59 These same types of communications problems occurred again during the September 17 drill. For example, messages took too long to reach where they were supposed to go because of the failure of personnel to communicate information in a proper 59 The report also noted that during the September 10 drill,
, briefings were not conducted frequently enough to keep personnel informed of important information. In fact, some staging areas
- failed to have any briefings. Attachment 8 at 4, 5.
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I l
I manner. Messages were frequently left on a communicator's desk j 1
for 10-15 minutes before being transmitted to the proper individual in the EOC. Attachment 8 at 6-7. In addition, although the announcement that an Alert had been declared was made at 10:14, the message indicating this was not sent to the LILCO staging areas until about 10:38. Id. at 7.
Another communications problem that occurred during the September 17 drill was that the phones of key coordinators were not answered when these individuals were at staff meetings. at 7. Further, as with other drills, messages were not written on the standard message forms created for that purpose. Rather, many messages were written on plain paper and later transcribed onto a message form. Id. According to the drill report, "(t)his caused delays in delivering the message to the appropriate party and caused transcription errors and erroneous information being transmitted." Id. Again, the LILCO training program has shown itself to be incapable of instructing personnel effectively about the importance of exercising great care in the handling of communications.
Even during the October 1 drill, the same kinds of communications problems continued. For example, "(t)he distribution of RECS messages to the EOC staff was very slow" during the October drill. Attachment 8 at 9. Further, "(t)he information flow into the public information office could have
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l l
1 l
been improved so that they would have information immediately available to them to generate the EBS messages." Id. And,
"(t)he information flow from the EOC to the Staging Area was slow and as a result the field personnel were working with information and data that was up to 30 minutes old." Attachment 8 at 10.
Moreover, during the October drill messages were communi-cated too slowly and personnel were not dispatched quickly. For example, a message concerning the fact that sirens had failed was transmitted to the Staging Areas by the EOC at 9:48. However it was not until 10:25 that the Route Alert Drivers were dispatched.
Attachment 8 at 11. In addition, a message to dispatch preassigned Traffic Guides did not arrive at the Staging Areas until 13 minutes after the information relative to the evacuation was known at the EOC. Id. This, as well as confusion due to three separate dispatch messages being sent to the LILCO staging areas within a few minutes, resulted in the slow dispatch of Traffic Guides. Id. Further, a message to dispatch bus drivers did not arrive at the staging areas until 1:30, despite the fact that a simulated release of radiation had occurred at 12:35. And this information was only received after being requested by the Bus Dispatcher. In fact, the staging areas were not informed of the 12:35 release until 1:40. This resulted in the bus drivers being dispatched into the plume without their knowledge. 14. at 12.
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i
Finally, as with other drills, LERO staff briefings were not held often enough and information was frequently not written on message forms. In fact, during the October drill, there were many instances where information was not written down at all.
Attachment 8 at 9-11.
Q. Were there additional communications problems noted during the December drills?
A. Yes, there were. During the December 2 drill, as with all previous drills, messages were frequently not written down on standard message forms. Attachment 9 at 3. In fact, some messages again were not written down at all. Attachment 9 at 15.
Another problem related to the fact that status reports contained conflicting information. Attachment 9 at 4. Further, they were not properly updated. Attachment 9 at 15, 16. This could result in personnel being misinformed about critical events and about the status of the emergency.
Further, individuals receiving family tracking calls in Brentwood failed to return confirmation of delivery of the messages to family tracking. Attachment 9 at 12. This occurred despite the obvious need to confirm delivery and the fact that
- such confirmation is required by the LILCO procedures.
l l Attachment 9 at 12.
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l
Another communications problem evidenced in previous drills was the fact that communications were so slow that field person-nel were frequently dispatched much too late. For instance, traffic guides frequently did not arrive at their posts for well over an hour from the time the protective action recommendation was made. Attachment 9 at 19-20, 24, 27-28. Further, communication between traffic guides and the staging areas, once the traffic guides arrived, was inadequate. For example, three traffic control points were unable to communicate with the Port Jefferson Staging Area. Attachment 9 at 20. And one traffic control point needed for rerouting after the fuel truck impediment could not be reached by the EOC, the Port Jefferson Staging Area or another traffic control point. Attachment 9 at 21.
The performance during the December 10 drill was not any better, despite the fact that personnel had participated in a drill just one week before. One problem experienced during the December 10 drill was that critical information necessary in order for LERO to take actions to protect the public was not communicated. For example, ENC personnel failed to include the names of the roads blocked by a brush fire when communicating this information to the EOC.60 Attachment 9 at 4. This resulted in delays in responding to this major impediment. Attachment 9 at 4. Further, it took 24 minutes from the time the EOC was 60 It is unclear from the drill report why the ENC rather than the EOC had initiated the message. Attachment 9 at 4.
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notified about the fire for the Evacuation Coordinator to instruct the Evacuation Route Coordinator to send a route spotter to check on the fire. Attachment 9 at 9.
Concerning another impediment, one involving a duck truck, the Evacuation Coordinator was not informed of the impediment for-23 minutes after it was injected into the drill. Attachment 9 at
- 10. Further, there is no indication in the drill report that personnel questioned whether ducks were loose despite the obvious need to acquire such information.
Another communications problem exhibited during the December 10 drill was the fact that field personnel frequently failed to communicate with staging areas. Attachment 9 at 29, 35, 40. In addition, the Riverhead Staging Area was unable to communicate with two of the road crews. Attachment 9 at 39. And, finally, as with the December 2 drill, slow communications resulted in traffic guides not arriving at their posts in a timely manner.
Attachment 9 at 35, 39-40.
Q. What conclusions have you drawn based upon your review of the Post-Exercise drill reports?
A. In our opinion, the communications problems demon-strated during and since the Exercise are indicative of serious flaws in the LILCO training program. Indeed, the fact that the
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same types of communications problems occurred over and over again can demonstrate little else except that the LILCO training program -- which had three years and at-least three dress re-hearsals and many drills / tabletops prio'r to the Exercise in order to train personnel -- has been ineffective in training personnel to communicate information properly. Indeed, the repeated instances of communications difficulties show a failure to instill necessary communications discipline -- another indication of a flawed training program. If discipline cannot be learned during drills and exercises where there is no real-world tension, there is little likelihood of a proper response to an actual emergency. Thus, we conclude that the Exercise demonstrated fundamental flaws in LILCO's training of personnel in the fundamentals of effective emergency communications. Nothing since the Exercise leads to any change in that conclusion.
D.. Contention Ex 50.D: Training to Follow Directions of Suoeriors Q. Please state subpart D of Contention Ex 50.
A. Subpart D states:
The exercise demonstrated that LILCO's training program has not successfully or effectively trained LERO personnel to follow directions given by superiors during an emergency. Exercise l
actions and events which support this allegation l are described in Contentions Ex 41, Ex 42, Ex 45 and in the following FEMA conclusions: EOC-D-1; PSA-D-6; PJSA-ARCA 1; PSA-ARCAs 9, 13, 16; R-ARCAs 4, 6; RC-ARCA 1.
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Q. Do-you agree with subpart D?
A. We are not in a position to agree or to disagree because there are insufficient data. There are at least several instances;where it seems clear that LILCO. personnel failed to follow instructions of their superiors. For example, a number of LILCO bus drivers failed to read their dosimeters every 15 minutes throughout the course of the Exercise, despite the fact that they were instructed by their supervisors during briefings to do exactly that. jhtg FEMA Report at xiv, xviii, 59.
Similarly, a LERO person at a bus transfer point told a bus driver to go to-EWDF despite instructions to tell drivers to go to Coliseum. Sgg FEMA Report at 65.
However, on the basis of two examples (and perhaps several others as well),61 we cannot conclude, overall, that the LILCO 61 For example, at about 11:15, in response.to the fuel truck impediment, the Route Spotter / Road Crew communicator at the EOC requested the Port Jefferson Evacuation Coordinator to dispatch a Route Spotter to the impediment scene. The Route Spotter,
-however, was not dispatched until 12:02. FEMA Report at 37; FEMA
. Admission No. 69; but see, LILCO' Admission No. 165. In the June 6 drill, the report noted that the Patchogue communicator at the EOC failed to transmit the message to dispatch buses until 1-1/2 hours after he had been instructed to do so by the bus coordinator. Sag Attachment 7, at 6. Further, during the
-September 10 drill, some of LILCO's personnel were so incapable of following instructions regarding the performance of their duties that they had to be " walked through" the drill. Egg Attachment 8, at 2. However, this second deficiency from the September 10 drill may not constitute a failure to follow instructions but, rather, be indicative of a more general failure in the entire LERO training program to have communicated effectively.
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training program has been unsuccessful in training LERO personnel to follow directions given by superiors.
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Our lack of support for this subpart of-the contention should not be construed to constitute an agreement by us that the
-LERO training ~ program has been successful in this regard.
Frankly, we would be surprised if that were the case, particularly given our overall findings as described in this testimony that the LILCO training program has been seriously deficient. However, on the basis of the data available to us, we cannot provide additional bases in support of this subpart of Contention Ex 50.
E. Contention Ex 50.E: LILCO Has Failed to Train Personnel to Exercise Good Judgment and Use Common Sense Q. Please state subpart E of Contention Ex 50.
A. Subpart E is as follows:
The exercise demonstrated that LILCO's training program has not successfully or effectively ;
trained LERO personnel to exercise independent or good judgment, or to use common sense in dealing with situations presented during an emergency or in implementing the LILCO Plan and procedures.
Exercise actions and events which support this #
allegation are described in Contentions Ex 34, 36, 38-43, Ex 45 and in the following FEMA conclusions: EOC-D-1; PSA-D-1; R-D-2; EOC-ARCAs-2, 3,, 9; ENC-ARCA-2; PSA-ARCAs-5, 7, 8, 10, 12; R-ARCA 1.
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Q. Do you agree with subpart E?
A. Yes. The Exercise demonstrated the inability of LERO's personnel to exercise independent or good judgment, or to use common sense, in dealing with situations presented during an emergency or in implementing the LILCO Plan and procedures. As a result, we have concluded that LILCO's training program is inade-quate in the training of LILCO's emergency response personnel.
- 1. Examoles of LILCO's Trainino Failures Q. Please provide examples from the Exercise that demonstrate LILCO's failure to train personnel to exercise independent judgment or good judgment, or to use common sense in dealing with situations presented during an emergency or in implementing the LILCO Plan and procedures.
A. Our discussion of some examples will be brief to avoid repetition of some of the earlier examples which support other subparts of Ex 50 as well.62 Consider, for example, the following events and occurrences, all of which occurred during the Exercise:
62 The examples of LILCO's failure to handle unanticipated or unrehearsed situations as discussed in our Ex 50.A Testimony are largely also indicative of LILCO's failure to train persons to exercise independent or good judgment or common sense. Many of the examples cited in the Contention Ex 38/39 Testimony also j provide support for this subpart.
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The failure by LILCO's personnel, in handling the simulated roadway impediments, to request specific information about the impediments (e.o., FEMA Report at xvi, 37, 39, 65); or to explore alternatives for the verification of the impediments (e,q., FEMA Report at 37-38); or to exercise prompt judgment regarding the kinds of equipment which would be needed to respond to the impediments (FEMA Report at 37, 65).63 63 For example, with respect to the gravel truck impediment, only one tow truck was sent to clear the impediment, which involved a loaded gravel truck and three cars. LILCO failed to send a scraper or bucket-loader, or even to inquire as to whether there was gravel spilled on the road. Moreover, one tow truck would have been inadequate to clear this impediment. FEMA Report at 65. Even employing conservative estimates about the size of the gravel truck and the extent of the damage to the disabled cars, most likely several trucks and a scraper or bucket-loader would have been necessary to clear the impediment. LILCO,.
however, sent a 10,000 pound truck to clear this impediment. Egg Deposition of Walter F. Wilm (January 8, 1987), at 56. This type of truck is not designed to tow a large, loaded gravel truck.
See Contention Ex 41 Testimony at 38. Thus, LILCO's response demonstrated poor judgment on the part of LILCO's personnel.
With effective training, perhaps LILCO's personnel would have thought through the problem they faced before acting. LILCO's personnel, however, had not been effectively trained. The result was that improper and insufficient equipment was sent to clear the gravel truck impediment -- a result which, in a real emergency, would have likely led to substantial delays in clearing the impediment.
LILCO's response to the fuel truck impediment during the Exercise was no better. Again, the equipment sent to clear the impediment was inappropriate and insufficient, demonstrating poor judgment and lack of common sense on the part of LILCO's person-nel. LILCO again sent one 10,000 pound tow truck (sgg deposition of Walter F. Wilm (January 8, 1987), at 58-59) to clear the impediment. This tow truck would have been too small to remove an overturned tanker. Further, LILCO failed to request immediately that an empty tanker be sent to off-load the overturned truck. FEMA Report at 37. This demonstrated poor judgment on the part of LILCO's personnel, since this step would have been necessary in order to remove the fuel remaining in the overturned tanker.
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The decision by the LILCO Evacuation Coordinator to decide upon a traffic rerouting strategy without consulting with persons familiar with the roadways in the area of the impediments showed poor judgment and resulted in a decision to employ a rerouting strategy which was illogical and would have resulted in more evacuation delay. Egg Contention Ex 41 Testimony at 50-64.
The fact that a field monitoring team stopped to report dose assessment data while still within the area of the plume (agg FEMA Report at 51-52);
The fact that a simulated evacuee, while being monitored at the Nassau Coliseum Reception Center, was told to put on protective rubber booties before he was advised to put on anticontamination gloves, even though LILCO's monitor was aware that the evacuees's hand was " contaminated" (see FEMA Report at 81).
Q. Are there other examples as well?
A. Yes. For instance, the manner in which LERO personnel responded to simulated inquiries from the public during the Exercise demonstrates the lack of training of LERO's personnel to
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exercise independent or good judgment, to use common sense in dealing with emergency situations, or to implement LILCO's Plan.
Consider, for example, the following64:.
(1) During the Exercise, in response to an inquiry from a person at 7:51 who "has trucks going to Suffolk," and as to how extensive evacuation would be, the LILCO Hicksville Call Board operator responded at 8:20 that the only protective action was the closing of schools, and that there had been no evacuation recommended. Egg LILCO Admission No. 114. It was poor judgment to suggest that the caller should proceed as planned with sending trucks into the EPZ area, since, among other things, such a response would have increased traffic within the EPZ, when the goal should have been to have as few persons as possible within that area. Presumably, since no evacuation had been ordered, the operator or the supervisor who provided the operator with the response, assumed that there was no reason to tell the caller not to send trucks into the EPZ. This response, however, was inappropriate under the circumstances. At best, the operator used poor judgment or failed to exercise independent judgment in his response.
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i 64 The examples are discussed only summarily here, since they are discussed in greater detail in other testimony, primarily the Contention Ex 38/39 Testimony at 132-34.
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(ii) In response to an inquiry at 11:30 whether lobsters caught that morning on the Shoreham jetty were safe to eat or touch,'the Riverhead Call Board operator responded at 12:28 that there was no reason,to believe, and no data to indicate, that anything was wrong with the lobsters. Sag LILCO Admission No. 116.- Even if the likelihood was that the lobsters were safe, a response advising caution would have enhanced LILCO's credibility. Further, responding to this call without even inquiring as to when that morning the lobsters had been caught demonstrates a lack of judgment and common sense on the-part of the operator.
(iii) During the Exercise, a rumor message simulated at 11:45 was received, purportedly from Dan Rather, who wanted "to take a TV crew into the Shoreham plant," and inquired how to get there. In response, the rumor control responder stated "We don't advise going to the plant. There is a Site Area Emergency. You will be in the way."~ The responder then gave directions to the plant. LILCO Admission No. 119. The responder gave out misinformation concerning the status of the emergency, and used poor judgment.in providing directions to the caller and indicating that it was possible for the television crew to go to the plant. A more appropriate response would have been that television crews would not be allowed onto the Shoreham site, but that they were welcome to come to the ENC. The suggestion that going to the plant was inadvisable but nonetheless possible, i
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combined with the giving of road directions to the plant, indicates a training program that has been unsuccessful in instructing personnel to use good judgment or common sense.
(iv) There was an obvious need to have the LIRR divert its trains from the EPZ. Yet, LILCO personnel failed to contact the LIRR. LILCO's personnel should have used independent judgment in deciding to contact the railroad.
(v) Many errors in judgment were shown at the ENC, again reflecting inadequate training. First, the ENC was ready for activation at 8:08 a.m. However, the Emergency News Manager delayed activation -- and continued to hold the media upstairs --
until 8:25 a.m., because one staff member had not yet arrived.
There is no indication that the missing staff member was in any way critical to the enterprise. The Emergency News Manager showed extremely poor judgment in delaying the entire operation until roll call was complete.
Second, the LILCO spokesperson withheld, for 25 minutes, the information that an evacuation of the entire EPZ had been ordered. An EBS message about the evacuation was " broadcast" at noon. According to the notes of the ENC Head Controller, the LILCO spokesperson had this information at 12:22 p.m. Yet she, apparently unilaterally, decided to wait until the 12:47 p.m.
press briefing to inform the media at the ENC of the complete
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l evacuation. ~The County has described in its Contentions Ex 38/39 Testimony (pages 85-91) the media's probable reaction to finding out that such information was not given to them promptly. There was no reason for the delay; it was an error in judgment and reflective of defective training.
Third, another error in judgment reflecting bad training was displayed by Dr. Brill when, in his comments to the press, he effectively countermanded LERO's evacuation recommendation. Egg discussion in Section III.G.1 below. Suffice it to say here that, whether or not it was Dr. Brill's considered opinion that he probably would ignore the recommendation to evacuate, he showed poor judgment and reflected a lack of training in the use of good judgment in relaying this opinion to the press corps gathered at the ENC.
Fourth, employees displayed a lack of common sense and good judgment in their handling of the copying problems at the ENC.
First, any good manager would have checked the compatibility of the electrical system at the ENC with his equipment prior to an emergency -- or prior to a graded evaluation. Second, assuming that such a check were not done, or revealed no problems, common sense -- and good management practice -- dictate that compensating measures should have been taken once a problem arose. Perconnel at the ENC should have held more frequent briefings, or immediately relayed information obtained from the
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EOC orally, and also made an attempt to obtain different equipment in order to compensate for the failure of their xeroxing machines. Instead, LILCO personnel permitted the failure of the xerox machines to sabotage their efforts. The failure even to attempt any compensating measures in order to get needed information to the media, demonstrates poor judgment, poor management, and a lack of common sense.
Fifth, yet another example of poor judgment exercised by LERO ENC personnel was the decision to hand out to the press copies of EBS messages full of illegible writing, confusing inserts, and information crossed out or partially crossed out.
The messages were not only unprofessional in appearance, they were confusing and, in part, illegible, gag FEMA Report at 53; Contention Ex 38/39 Testimony, Attachment 8. Common sense should have dictated that cleaned up, clear, and professional looking hard copy should have been handed out to the media to avoid confusion and inaccurate reporting, not to mention reduction in LILCO's credibility resulting from the appearance of incompetence communicated by the sloppy handwritten messages actually out.
(vi) A final example of poor judgment, exercised by the public information staff at the EOC, related to their preparation of EBS messages during the February 13 Exercise. Specifically, l
those personnel chose to take almost verbatim the " sample" EBS l
l message contained in the LILCO Plan, with the fill-in-the-blank format, even though this resulted in an unintelligible or very
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confusing statement. Sgg EBS Message No. 2. An exercise of common sense and good judgment would have dictated the rewriting of the message to tailor it to the specific situation at hand, rather than to use a fill in the blank form which resulted in an incoherent and confusing message.
- 2. The Importance of Training Personnel to Exercise Good Judament and to Use Common Sense Q. Why is it important, in your opinion, for emergency personnel to be trained to exercise independent judgment?
A. During an emergency, many things will likely arise that were not planned for (agg our Contention Ex 50.A Testimony). In order to be able to handle these unexpected occurrences, emergency response personnel must be able to use and exercise independent and good judgment. They must be able to "think on their feet." Further, during an emergency, personnel must be able to think of and implement whatever actions are required, whether or not they are specifically planned and provided for.
It must be emphasized that the essence of an adequate emergency response is the capability of persons responding efficiently and in a timely manner to non-routine, unanticipated, and unrehearsed events. Instead of demonstrating that L capability, LILCO demonstrated a rigidity of organization which
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inhibits-LILCO personnel from performing efficiently in response to unforeseen events which require the exercise of sound judgment.
Q. Why do you believe that LILCO personnel failed to use independent and good judgment or common sense during the Exercise?
A. Based upon our review of LILCO's training program, it is our opinion that LERO personnel are given little training with regard to how'to exercise independent or good judgment, or for that matter common sense. LILCO's training program is limited in its scope. Further, the training program is so procedure specific that workers are taught, if anything, not to use independent judgment. To effectively train personnel to respond to an emergency, however, personnel must be taught the importance of thinking on their own. They must be taught enough about the overall goals of the emergency response organization so that they can understand exactly how they fit into that organization and the importance of their particular job functions to the overall organization. In these respects, LILCO's training progcim is seriously flawed.
Q. Do you believes that LILCO's training program is capable of teaching LERO personnel to use independent and good judgment?
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q A. Probably not. LILCO's highly centralized organiza-tional structure impedes the use of individual judgment.- This matter is dealt with in connection with our testimony on
' Contention Ex 50.I and will not be repeated here.
- 3. The Post-Exercise Drills Support the Allegations of Suboart E Q. What. impact, if any, did your review of the post-Exercise LILCO drills have on your conclusions concerning Contention Ex 50.E?
A. The drill reports and underlying documents confirm our conclusions. Many of the examples from those drills have already been discussed in connection with our testimony on subparts B and C of Contention Ex 50. These examples will not be repeated here.
Consider, however, the following additional examples:
During the June 6 drill, personnel in the EOC respon-sible for communicating information about the evacuation to the staging areas were criticized for failing to use their desk phones to communicate this information quickly; thereafter, they could have followed up with written messages (Attachment 7 at 2-3).
During the June 6 drill, the Special Facilities Coordinator believed there was a one hour delay, after the notification to evacuate had been received, before evacuation of
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5 a
'f 4 '
t the mobility-impaired. Attachment 7 at 4. If anything, however, this LERO coordinator should have realized that the mobility-N
' q', impaired require more time, not less, to evacuate. This response n. .
therefore demonstrated poor judgment and a lack of common sence by LILCO's personnel.
4 8 f' Also during the June 6 drill, the Special Facilities Evacuation Coordinator delayed proceeding with notification of the deaf until a copy of the EBS message identifying those zones advised to evacuate had been received. Attachment 7 at 4.
Again, this demonstrated lack of good judgment and common sense
,, by this LERO coordinator because the information was readily available elsewhere.
During the June 6 drill, LILCO's personnel, after checking the supposed location of an impediment to traffic,
- assumed there had been a false alarm and no follow-up action was E
taken. Attachment 7 at 5. In fact, these personnel had reported to the wrong location (Route 25A instead of Route 25). They then 90 had to be prompted on three separate occasions before any follow-up action was taken. Id. This failure to take follow-up action indicates a failure to exercise independent or good judgment.
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During the September 10 drill, the Radiation Health Coordinator ordered the ingestion of KI before he had performed the necessary calculations to justify his action. Attachment 8 at 3. This action was a clear example of poor judgment by a key LERO coordinator.
During the September 17 drill, the phones of key coordinators went unanswered when they attended meetings.
Attachment 8 at 7. This practice is indicative of poor judgment by LILCO's personnel. It also calls into question their common sense.
Also during the September 17 drill, the EBS message issued for a traffic impediment was much too detailed and specific. Attachment 8 at 6. The use of good judgment would have resulted in a more general message which would have instructed evacuees,to follow the directions provided by traffic
- guides. Attachment 8 at 6s 3
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During the December 2,dri?1 .hr :oad crew informed of the fuel truck accident was told that the fuel company would handle it and thus not to go to the scene of the accident.
Attachment 9 at 16. This demonstrates poor judgment since it might take longer'for the fuel company to get a truck there,
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especially considering that an evacuation was taking place. Good judgment would have resulted in a road crew being sent to the scene at least as a backup.
Also during the December 2 drill, no one questioned a message from an individual thought to be outside the area of the radioactive plume indicating that he had received four rems.
Attachment 9 at 18. The failure to follow up on this message demonstrates poor judgment on the part of LERO personnel since this information, if accurate, could mean that LILCO's assessment of the situation was incorrect.
During the December 10 drill, it took 25 minutes for the protective action recommendation to be made by the Director
't after the EOF had made its recommendation, and then only at the prompting of the controller. Attachment 9 at 5. The reason for this was that the Radiation Health Coordinator and Nuclear Engineer were waiting for data from the EOF in order to make an independent assessment. Since the individuals.in the EOF were in a meeting, "the RHC and nuclear engineer were content to wait."
Attachment 9 at 5. Good judgment would have caused them to interrupt the meeting rather than delay an evacuation recommendation. Further, under such circumstances, it was poor judgment for the Director to simply do nothing. He either should have acquired the data or made the recommendation based on the EOF's assessment.
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Q. What is your overall conclusion on Contention Ex 50.E?
A. Our overall conclusion with respect to subpart E of Contention Ex 50 is clear: there are repeated instances docu-menting that LILCO's training program has failed to teach LERO personnel to use good judgment and common sense. The LERO response to the Exercise scenario was largely mechanical. There was a lack of initiative and good common sense and a lack of the kind of informed judgment that would lead emergency personnel to innovate and take necessary actions when unforeseen or -
unanticipated events occurred.
The proposed changes to the LILCO training program indicate no basic change in LILCO's approach to training, and during the drills during 1986 subsequent to the Exercise, we discern no trend toward greater LILCO proficiency in the use of independent judgment and common sense. In short, therefore, we believe that the LILCO training program is flawed, as demonstrated at the Exercise, and that there is no basis to believe that there has been any significant change in that program since the Exercise.
l (Perrow) Further, for reasons described elsewhere in this l
testimony, we believe that effective LERO training is highly unlikely, given LERO's centralized organizational style, the rigidity and mechanistic approach to training which is inherent in its program, and the intermittent character of its
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organization. LILCO, in fact, may be expecting the impossible from its personnel: to work part-time as emergency workers, involving only a few drills a year; yet to perform in a first-rate manner during a nuclear power plant emergency. At a minimum, such expectations require an innovative and highly effective training program. The Exercise demonstrated that LILCO' does not have such a program.
F. Contention Ex 50.F: LILCO has Failed to Train Personnel to Deal Effectively with the Media and the Public Q. Please state subpart F of Contention Ex 50.
A. Subpart F states:
The exercise demonstrated that LILCO's training program has not successfully or effectively trained LERO personnel to deal with the media or otherwise provide timely, accurate, consistent t
and nonconflicting information to the public, through the media, during an emergency. Exercise actions and events which support this allegation are described in Contentions Ex 37, Ex 38, Ex 40.C, and Ex 43.A and in the following FEMA conclusions: ENC-D-1; ENC-ARCAs 2, 3.
Q. Do you agree with Subpart F?
A. Yes. We have reached this conclusion by reviewing what
, occurred during the Exercise, as well as by reviewing underlying documents regarding the LILCO training program, including post-I Exercise training documents and drill reports.
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- 1. Examples of LILCO's Failure to Train Personnel to Deal with the Media Q._ Please provide examples from the Exercise which demonstrate'LILCO's lack of effective training of personnel.to deal with the media.
A. We will keep.our examples short and mention only-several, because the facts.related to these and other examples have previously been discussed in the County's Contention Ex 38/39 Testimony.
- 1. LILCO's ENC was not declared operational until 8:25, and'there was apparently no contact with the media by LERO
_ personnel at the ENC until after that time.. Egg LILCO Admission No. 37. In a real emergency,65 such a delay'would have likely resulted in substantial confusion, speculation, rumor generation, lack of confidence in LERO's ability to deal with the emergency, and refusal to believe information, advice or instructions subsequently disseminated by LERO personnel, for all the reasons we have stated in Contention Ex 38 Testimony. If LILCO's training program for dealing with the media had been adequate, it 65 The Exercise was unrealistic in assuming that no attempts would be made-by the media to contact LERO or LILCO until after the ENC was declared operational at 8:25 a.m. The first EBS message had been broadcast at 6:52 a.m., more than 1-1/2 hours prior to the time that the ENC was operational. Based upon our experience, we are confident in an actual emergency that the media would have been pressing LILCO for data from 6:52 a.m. on.
The-Exercise scenario was highly unrealistic in deferring any media contacts.
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would have prepared LERO to set up the ENC no later than 6:52 a.m., since that is when a flood of media inquiries would have started. The fact that LERO then delayed for 1-1/2 hours before the ENC was actually set up reflects a lack of adequate training - plus a substantial lack of good judgment. Egg subpart E of Contention Ex 50 Testimony.66
- 2. LERO News Release No. 1, announcing an Alert condition and the alleged fact that there had been no release of radiation, was not provided to the press by the ENC until 8:21. Egg LILCO Admission No. 57. By that time, however, the ENC had been informed that a Site Area Emergency had been declared (at 8:19),
a minor release of radiation had occurred, and LILCO had recomntended that dairy animals be placed on stored feed. Egg FEMA Report at 25, 26. The time between ENC notification of the Site Area Emergency at 8:19 and the time that the ENC released its first news release at 8:21 was very short. Thus, it might be somewhat explainable why the press release was issued without reflecting the site area emergency data. What is not excusable, however, is that there was no prompt correction of that 66 (Rowan) I have seen how delays in communicating with the media can worsen relations with the media and result in confusion, speculation and sensationalistic reporting. As a reporter covering the incident at Three Mile Island, I saw how the delays in providing information to the press increased tension. The resulting coverage centered on hypothetical worst case scenarios. Since Three Mile Island it has been recognized that there is a need to train utility personnel to expect great media interest in radiological emergencies and to be prepared to provide information rapidly. LILCO failed in this regard.
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information via a follow-up announcement to the media at the ENC that new data were available which superceded some of the data in News Release No. 1.
- 3. Although the Site Area Emergency, radiation release, and dairy animal recommendation was announced by EBS broadcast at 8:41, and despite the fact that the decision to issue that EBS ,
message was made by the LERO Director by 8:37 (FEMA Report at 26), LERO News Release No. 2, which included the information in that EBS message, was not approved by the Director until~9:00.
Egg Public Information Log. Further, as of 9:15, it had still not been distributed to the press. Egg LILCO Admission No. 72.
- 4. Although the ENC received LERO Press Release No. 3 at 10:15, it was not posted at the ENC for the press until 11:10.
Egg LILCO Admission No. 74.
- 5. LERO Release No. 4 was received by the ENC at 10:45, but was not posted until 11:56. Egg LILCO Admission No. 75.
- 6. LERO Release No. 5 covered the 10:24 evacuation recommendation for zones A-M, Q and R. It was approved by the LERO Director at 11:02, but did not even arrive at the ENC until 11:36, and was not made available to the press until sometime later. Egg LILCO Admission No. 76.
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- 7. LERO Release No. 6, approved by the LERO Director at 12:25, was not posted at the ENC.until 2:10. Egg LILCO Admission-No. 77.
- 8. LERO Release No. 7, approved at 1:11, was received by the ENC at 1:47, but not posted for the press until 3:07. Egg LILCO Admission No. 78.
- 9. Although the LERO Director decided to recommend evacuation of the entire EPZ at 11:46, and the recommendation was announced to the public in a 12:00 noon EBS message (FEMA Report at 26), the ENC did not inform the media of the Director's deci-sion, or the content of the 12:00 EBS message, until 12:47. Egg-LILCO Admission No. 79.
- 2. LILCO's Failure to Provide-Effective Media Trainino is Sionificant O. Why do these examples demonstrate inadequate training?
A. Throughout the Exercise, as demonstrated by these examples, LERO personnel were unable to provide timely, accurate, consistent, and nonconflicting information to the public through the media. This is a crucial task under any emergency response plan. Quite simply, during an emergency the ability to provide timely and accurate information to the media is essential in order to ensure that the public is kept informed concerning the l
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~1 status of the emergency and whatever protective actions are being recommended. In the event of a radiological emergency, the necessity of keeping the public informed and up-to-date regarding the status of the emergency would be even more crucial, given public fear about nuclear hazards. In a climate of fear, only rational, credible, accurate and timely information can persuade people to follow instructions and not react irrationally.
These failures as set forth in the foregoing examples implicate the LILCO training program because it is only through detailed practice and training that any person can come to an understanding of how to deal effectively with the media. One needs to learn how to exercise good judgment and common sense and to be apprised about how the media operates so that the emergency response personnel can provide the kinds of data upon which the media relies in informing the public. LERO personnel, however, seemed during the Exercise to be uninformed about media needs or how the media operates. LERO personnel mechanistically went about performing their functions with no apparent understanding of the practical realities of how they needed to intermesh with the media. Only a well designed and carefully implemented training program could in any event succeed in such a task. The repeated examples of failures of LILCO's training program lead us to conclude that that program is certainly flawed.
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O. . Gentlemen, you seEm emphatic that you believe it was a serious training deficiency for LILCO to have failed to have prepared its personnel to set up the ENC by the time the first EBS message was broadcast. Can you explain the reason for your strong feeling in this regard?
A. Yes we can. In our work experience, we have frequently confronted situations where immediate media contact is likely, and therefore we have trained respondents to be in a position to deal with the media on that kind of very rapid basis. These kinds of situations range from natural disasters, to hostage-taking situations, to technological disasters such as chemical fires. We have learned that in such situations, the media immediately seeks out officials who are in charge of the response and demand information from them regarding what happened, what to expect in the future, etc. As a result, training of personnel who are supposed to deal with the media must take these realities into account and prepare those personnel to respond appropriately to the media demands. If the officials are not prepared to respond immediately to media inquiries, the media broadcasts such lack of preparation, and also seeks other, potentially unreliable, sources of information, sometimes causing rumors and casting doubts about the credibility or capability of the responding agencies.
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i
The-same thing is likely to occur in a Shoreham emergency due to LILCO's lack of training. Good judgment and good training would absolutely require that the ENC be set up at the earliest possible time. Notwithstanding that, LILCO set up the ENC during the Exercise with almost casual slowness. From our review of the documents, there was no sense of urgency or understanding of how important it was to have the ENC operational at the earliest possible time during the simulated Shoreham accident, nor was there any consideration given to any meaningful alternative means to communicate with the media prior to ENC activation. This lack of understanding on the part of LERO personnel demonstrates how inadequate LILCO's training has been.
We reiterate, adequate training would have stressed to LILCO personnel the need to seize the initiative -- to take charge of the information flow to the news media almost from the minute the first EBS message was broadcast. In a real emergency of the sort simulated in the Exercise, the first EBS message would have triggered almost instantly the following responses: (1) phone calls to the utility from newspapers, radio and television stations; (2) dispatch by news organizations of reporters to the plant, utility office, ENC, and government, fire, police and/or civil defense headquarters; (3) activation by broadcast news organizations of their standby capability to cover events live by dispatch of microwave mobile units; and (4) implementation by broadcast news organizations of their airborne (helicopter / fixed
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4
wing) news gathering capability. Within minutes of the first EBS message, news organizations would be mobilizing to cover the event.
This would be an opportunity for well trained personnel to take charge. LILCO's casual slowness in preparing for the press onslaught would have resulted in news coverage -- including live coverage beamed to people in the region -- focusing not on what LILCO wanted the public to hear and do, but -- in the absence of LILCO leadership -- on what reporters were finding out on their own. Good training would have equipped LILCO to establish itself as a credible source of timely information, but the Exercise shows it was not. Furthermore, the Exercise revealed that LERO personnel had not even been trained to realize or understand the importance of appearing to be a credible source, or how one goes about presenting that image to the media.
Q. Why do you believe LILCO's training program has failed to successfully instruct personnel to provide accurate and timely information to the media?
A. There are several reasons. First, LILCO's training i program is lacking in any real instruction or practice which is necessary to teach personnel these tasks. In order to be able to l deal appropriately with the media, personnel must be trained how l
to communicate information as soon as it is available, how to 1
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t
check information for accuracy, and how to respond to media questions. Personnel must know enough about the overall emergency, the response being made, other events related to the emergency, and the response so that they can provide accurate and timely information to the public through the media.
Personnel must also be trained about the media and how it operates, particularly in emergency situations. In order to gain such skills and knowledge, personnel must do more than simply sit through a classroom training session and watch a videotape.
Personnel must have actual experience in dealing with the media, or at least be exposed, during training drills under realistic conditions, to the kinds of situations expected to arise in an actual emergency. Furthermore, such training must be under the watchful eye of knowledgeable trainers, who can observe performance and correct mistakes. LILCO, however, appears to offer little or none of this kind of training in its program.
Thus, the performance of LERO's personnel during the Exercise was what we would have expected, based upon our familiarity with LILCO's training program.
Second, there is a certain unreality to LILCO's training program. LILCO appears to seem to believe that media training is unimportant because all people will rely upon is the EBS messages. The County has demonstrated in the Contention Ex 38 Testimony that those messages are flawed and also that, even
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assuming those EBS messages are good, LILCO cannot ignore the media in dealing with an emergency. Those points will not be repeated here.67 Q. Are there any other concerns which you have regarding LILCO's training for media contacts as reflected by the Exercise results?
A. Yes. The Exercise results demonstrate that LILCO's plan for media contacts is fundamentally unworkable. The LILCO Plan appears to emphasize that media contacts by LERO/LILCO 67 (Evans, Rowan) It is essential to emphasize that LILCO personnel have relied on the EBS message system as the primary source of getting information to the public, even though the news media is the more likely conduit to the general public. Egg Deposition of Dennis Mileti, (January 8, 1987) at 48. This apparent ignorance of the prime role of the news media, especially of the reporters on scene who are not working on stories that would be published 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> later, but might be broadcast within seconds, indicates a significant lack of training in crisis communications. Based on our experience in covering emergencies, we are confident that the general public relies upon the news media, particularly the broadcast media, during the first stages of an acute emergency and upon newspapers if a crisis situation persists over several days (as did Three Mile Island).
Because LILCO personnel are not equipped through training or actual experience to understand the importance of the news media in the crucial first hours of an emergency, news coverage in a real' emergency of the sort simulated in the LILCO Exercise would quickly turn to non-LILCO sources. Reporters would summarize, condense, analyze and extrapolate on the information LILCO had provided. Moreover, they would seek alternative sources more willing to speak out. Thus, in a real emergency, the attention of the news reporters would quickly move beyond the untrained LILCO spokespersons and would focus on other sources.
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e 1
~ personnel will take place under controlled conditions, primarily through press releases and the like. There appears to be no emphasis on making data promptly available to.the media. ,
As we have already indicated, the media is highly unlikely in any emergency situation to wait for the responding organization to provide information at its own pace. -Rather, the media will be insistent upon receiving information virtually continuously. A training program must be geared to this reality.
Otherwise, if the responding organization does not satisfy the media's need for information, the media will immediately seek out information from other sources; the potential for rumors and -
conflicting information will grow accordingly.
The LERO training program for media contacts emphasizes the mechanistic approach. That approach was demonstrated during the Exercise to be unworkable. Thus, it is our conclusion that LILCO's training of LERO personnel for contacts with the media is fundamentally flawed, f
To be sure, an effective media relations training program must include mechanical aspects (press releases, news e
conferences, facilities, phones, etc.). However, it should not emphasize a mechanistic approach. Good communications training must stress the dynamic of interrelating with reporters, producers, editors and photographers. A mechanistic approach i
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which focuses on communications as what a sookesoerson savs will fail to provide adequate information in the right context. A
~ dynamic approach views communications as what the audience hears, remembers and acts upon. This aspect of training was evidently missing from LILCO's efforts. Personnel in the Exercise clearly show little appreciation for the impact of their words, actions and announcements on their audience.68 (Evans) This mechanical approach, and its limitations, is amply demonstrated by the EBS messages. Apparently, based on their behavior during the Exercise, LERO personnel are trained to use the pre-fabricated " sample" EBS messages. Drafted in advance of the Exercise (or a real emergency), they leave few options to
) LERO personnel coping with the emergency to exercise independent judgment, and the personnel demonstrated during the Exercise their apparent inability to exercise such judgment even when 68 (Evans, Rowan) We note also that from our review of the Exercise that it is clear that LILCO's training program did not
- take into account the lessons learned from Three Mile Island, and the subsequent recommendations of the Kemeny Commission based thereon. Two fundamental findings of the Kemeny Commission, with respect to the accident at Three Mile Island, were that the media was confused when sources used technological jargon to describe the accident and that the media had difficulty understanding
- information relative to release of radiation into the atmosphere l unless such information was given in terms of the precise nature and amount of radiation released and its impact on the health and safety of the public. One would assume that any training I
programs developed in the aftermath of Three Mile would take into account these findings. LILCO apparently did not, as evidenced by the numerous incidents in EBS messages, press releases and statements by LILCO spokespersons where jargon is used to '
describe the accident and radiological information is given in imprecise terms with little, or no, information as to its impact.
Egg Contention Ex 38/39 Testimony at 57. :
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1 obviously necessary. Other than filling in a few names here and there and striking from the drafts inappropriate language, the personnel who have responsibility for seeing that the messages are broadcast are apparently not required or trained to determine whether the broadcasts contain information the public ought to have in light of the unfolding emergency. For instance, in response to questions and as an apparent consequence of the media monitoring procedures, LILCO officials emphasized at press conferences that an explosion at Shoreham was not a possibility.
Yet that information, which might have been comforting to the public, was never included in the EBS messages because it was not in the drafted " sample" format. Thus, while LILCO officials maintain that the EBS broadcasts are its fundamental means of communicating with the public, the mechanistic approach to preparation of those messages prevented LILCO from communicating directly to the public information which may have been critical.
The fact that this was not recognized and corrected by LILCO officials during the course of the Exercise demonstrates not only a failure of the mechanistic approach but also a lack of adequate training to exercise independent judgment.
(Rowan) It further must be emphasized that the inadequate performance of LILCO personnel in dealing with the news media is evidence of inadequacies in training about the communications component of crisis management. There are several basic t
components of communications that were evidently overlooked in
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preparing LILCO personnel for the Exercise. These components include (1) the information, (2) the delivery system and (3) the sourcing. First, as to the information itself: is it true and useful? More specifically, is it clear, accurate, consistent with other official messages, appropriate for the audience and complete? My judgment from reviewing how LILCO interacted or failed to interact with the media during the Exercise is that personnel were not properly trained to collect, analyze, interpret and process information. Otherwise the results of the Exercise would not have included instances when LILCO information was not clear, sometimes was not accurate, was internally inconsistent at times, and lacked completeness. Egg Contention Ex 38/39 Testimony.
Second, as to the delivery system: was it effective and timely? More specifically, was it well organized, did it make optimum use of human resources, were facilities adequate, was there coordination with other key organizations, did it deliver information in a speedy fashion, was there responsiveness to the needs of various groups, and was it flexible in changing circumstances? Good training programs alert personnel to these needs and their importance. The Exercise reveals that LILCO personnel were unprepared to provide an effective delivery system. It was flawed organizationally, personnel did not perform optimally, facilities were inadequate, coordination with
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the pseudo-governmental entity, LERO, was rocky, information was late in flowing, and it was unresponsive to the needs of the news media. Egg Contention Ex 38/39 Testimony.
Third, as to the sources of information: were they credible? Specifically, did the LILCO sources provide access to information, were they open with the news media, did they offer data that were consistent with other external sources, did they exhibit objectivity, competence and honesty or were there conflicting loyalties? Based on our review of LILCO's conduct during the Exercise, it is obvious that LILCO personnel were unprepared to demonstrate credibility as news sources. They showed an absence of openness and a lack of cooperation with the media, and an apparent lack of understanding or appreciation of the necessity of demonstrating these characteristics. Good training programs stress ways that news sources can demonstrate shared values and create bonds of trust with news reporters; LILCO was unable to do this.
(Colwell) I have personally held numerous local, state-wide and national news conferences. I have also appeared on national news networks where I was interviewed " live" concerning events such as aircraft hijackings, kidnappings, shooting incidents, fugitive apprehensions, bombings and major legal cases such as ADSCAM.
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'For an organizational spokesperson (or a central news
' disseminating organization) to be effective, the spokesperson must instill a sense of confidence that full disclosure is being made at the designated media room location. Once the media believes that the most current and accurate information is not available at the news center, they will leave to pursue other lines of inquiry and other sources.
The key figure in keeping the media at the central location
-- and thus averting the dissemination of inaccurate information, speculative information, or information which may be distorted by being taken out of context -- is the spokesperson. The spokesperson must speak with authority, and have immediate access
-- access which the media can see -- to all levels of the organization. The spokesperson must be able to report on events contemporaneously. For a spokesperson to prove himself out of touch with what is happening in the field, or where the decisions are being made, is fatal to his effectiveness. And the spokesperson must have full knowledge -- down to the smallest operational detail -- of the organization he is representing.
Finally, the spokesperson must have the ability to perform under pressure. The media in this country is known for, and prides itself on, asking the hard questions, probing for ever more information, and refusing to be put off by vague or ill-informed answers.
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The ability to deal effectively with the media can only be gained through experience, or through extremely realistic role-playing exercises. It is essential to place the role-player under pressure in these simulated situations, because he will be under intense pressure when he is before the media in a real emergency. In fact, if the event in question were a nuclear emergency, I imagine the pressure from the media would be particularly intense, given that at the time representatives of the utility went before the press, they would already be perceived as having in some sense " dropped the ball" and thus endangered the health and safety of thousands of people.
I am not aware of the specific training the LERO spokes-person had received for her job. I can, however, say that, based on her performance during the Exercise, that training was ineffective. First, as has been discussed in prior testimony, the spokesperson (Ms. Robinson) failed in her first duty, i.e.,
informing the media as to what was going on. The ENC continually lagged behind the EBS station in the information it was giving out. Even when the spokesperson had information to give, she would wait for the next scheduled press briefing to give it. The spokesperson frequently appeared flustered by the questions she was asked. (Even the LILCO Lead Controller at the ENC noted that she lacked polish in answering a question about the evacuation.
Based on my own viewing of the ENC videotapes made during the Exercise, I consider this an understatement).
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The LILCO spokespersons' answers were, on occasion, flippant. (For example, when a reporter asked how the 95,000 people who had been sent to the Coliseum for monitoring would fit there, the spokesperson responded: "The answer is, not all at once." At another point, immediately after stating that the residents of six zones in the EPZ were being sent to be monitored-for possible contamination, the spokesperson delayed answering a question about whether people on the road were being exposed to radiation in order to adjust the table where she was sitting and to observe that "(w]e're having problem with the table at the moment."). At other times, the tone was offensive. For instance, when asked if any effort was being made to determine or ensure that people were in fact evacuating, the spokesperson opined that people are " expected to behave in a sensible and adult manner . . . .
Finally, the witnesses on Contention Ex 38/39 have already discussed the substantive inadequacies and inaccuracies in the answers to questions from the press and their likely result. I will not repeat their testimony here except to point out that the spokesperson should have known such things as the number of people who had been told to report for monitoring, the details of any traffic impediments, and that the population of the area was lower in the winter than in the summer. In sum, the spokes-person's performance during the Exercise made it clear that, l
although she was the "LERO" spokesperson, she exhibited little
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understanding of the operational details of "LERO," little access I to the higher levels in the organization and the information flowing from them, and little experience in establishing rapport with the media and in effectively fielding their questions. I can only conclude that she was given inadequate training to prepare her for her role as LERO spokesperson.
- 3. The Post-Exercise Drills Do Not Solve LILCO's Trainino Problems Q. Has your review of the post-Exercise LILCO training drills changed your opinion in any way with respect to whether LILCO's training program has successfully trained LERO personnel to deal with the media or otherwise provide timely, accurate, consistent, and nonconflicting information to the public, through the media, during an emergency?
A. No. First, there has been no basic change in LILCO's training approach. It was flawed before and continues to be flawed. Further, the post-Exercise drills in terms of media relations were quite limited, with no actual media involved. Egg also Contention Ex 38/39 Testimony at 135-38. Thus, these drills provide no basis to alter our conclusion that the Exercise results demonstrated fundamental flaws in LILCO's training program.
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G. Contentions Ex 50.G and H: Training for Persons and Organizations Relied Upon By LILCO and Training in Exposure Control Q. What do subparts G and H of Contention Ex 50 allege?
4 A. Contention Ex 50.G alleges that the Exercise demonstrated that LILCO has failed to provide training to persons and organizations relied upon for implementation of its Plan, other than those employed by LILCO. Contention Ex 50.H, as well as Contentions Ex 27 and 28, allege that the Exercise demonstrated that LERO training has been deficient in the areas of dosimetry, exposure control, KI, understanding of radiation terminology, and related areas.
Q. Please state subparts G and H of Contention Ex 50.
A. Subpart G states:
The exercise demonstrated that LILCO has failed to provide training to persons and organizations relied upon for the implementation of its Plan other than those employed by LILCO. Exercise actions and events which support this allegation are described in Contentions Ex 27, Ex 28 and in the following FEMA conclusions: EOC-ARCAs 11, 12, 13, 14, 15.
Subpart H states:
i The exercise demonstrated that LERO training is deficient in the area of dosimett:r, exposure control, KI, understanding of rad;.ation terminology, and related areas. Such tra. ting l deficiencies are very serious because members of L the public and non-LILCO personnel relied upon to
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respond to a Shoreham accident (for example, school officials, special facility personnel, and other individuals who are expected by LILCO to respond on an ad hoc basis) would seek information on such subjects from LERO personnel during a real emergency. Since LERO personnel do not understand and know how to use dosimetry equipment and the related procedures, they would be incapable of responding accurately or effectively concerning those subjects to members of the public, or other workers expected to respond. The following exercise actions and events are examples of dosimetry-related training deficiencies: Contentions Ex 42, Ex 45, FEMA Conclusions EOC-ARCAs 11, 12, 13, 14, 15; PJSA' ARCA 1; PSA-ARCAs 12, 13, 14, 15, 16; RSA-ARCA 4, 5, 6.
Contentions 27 and 28 are set forth in Attachment 6.
Q. Do you agree with subparts G and H and Contentions 27 and 28?
A. Yes, we do.69 Our opinion in this r9 gard is based upon what occurred during the Exercise, as well as our review of LILCO's training program, including training drills conducted since the Exercise.
- 1. Suboart G Q. Are there difficulties in compiling data on the subpart G allegations?
69 We deal with these Contention Ex 50 subparts together since many of the training deficiencies involving outside organizations concern dosimetry and related problems. Accordingly, to avoid repetition, we have combined them.
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A. Yes, because we are not dealing with a complete universe. As set forth in Contentions Ex 15 and 16, many persons and organizations outside of LILCO which are relied upon to perform necessary actions during a Shoreham emergency did not participate in the Exercise. Accordingly, the Exercise results provide no means to identify whether the training of those individuals and organizations is or has been adequate. This matter will be dealt with in greater detail in the context of Contentions Ex 15 and 16. We add only that it is our understanding that many such individuals -- such as personnel from the many schools within the EPZ that must take protective actions in the event of an emergency -- have received no training whatsoever.
Q. Focusing on subpart G of Contention Ex 50, on what do you base your opinion that LILT.O has failed to provide adequate training to persons in organizations relied upon for implemen-tation of its Plan?
A. The Exercise revealed a number of LILCO failures to provide training to the non-LILCO personnel and organizations relied upon by LILCO for the implementation of its Plan. For example, as recognized by FEMA (FEMA Report at 45-46), even those school bus drivers who participated in the Exercise -- t' rom Shoreham-Wading River School District -- had had no training in dosimetry, the use of potassium iodide, or excess exposure
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authorization procedures. Such training for emergency personnel is required, but the Exercise demonstrated that it either has not been provided at all or has been inadequate.
In addition, although the LILCO Plan relies upon ambulette drivers for implementation of the protective action of evacuation for special facility residents and the homebound (ggt OPIP 3.6.5), not all ambulette drivers had been trained in excessive exposure authorization and procedures. FEMA Report at 46.
Another example is provided by the actions of the LERO
" scientist" from Brookhaven National Lab who appeared at the ENC press briefings. Egg Contention 38/39 Testimony at 91-94. -
Although this scientist, Dr. Brill, had been involved in the LERO training program, he nonetheless gave out incorrect technical information and actually contradicted the LERO protective action recommendation of evacuation when asked by the press what he
- would do given that recommendation. Thus, Dr. Brill was asked what would happen if a " diehard" decided not to evacuate in the ;
face of an evacuation recommendation (a question which certainly l should have been anticipated by LERO trainers). In response, Dr.
Brill annoLnced that although he lived within two miles of the plant, he would probably himself be one of those " diehards" who would not leave. As noted in Contention 38/39 Testimony (at 93-94), such a response could have disastrous results during a real
- emergency. And, if anything should have been covered in the i - 189 -
e p . ww .
7
{!;
Q LIdCO training on public information matters, it should have been the necessity for consistent advice and recommendations. There is no excuse for Dr. Brill's statements, since he had been
. \ sitting in the press conferences and was well aware of the LERO recommendations; similarly, there is no excuse for the other LERO members who heard Dr. Brill's announcement failing to correct it immediately so that the harmful results were reduced. This demonstrates a clear failure of the training program.
The above examples demonstrate that LILCO's training program has failed to provide necessary training to those personnel from outside organizations that are relicJ upon by LILCO for the implementation of its Plan. In addition, it should be reiterated that many other non-LILCO personnel and organizations failed to participate in the Exercise in any way. S11, g2gi, LILCO
. Admission Nos. 21-24, 26-28, 30, 34-35, 48-49, and 199.
Therefore, the Exercise results provide no basis for concluding that LILCO has provided adequate training to any of them.
Given the small number of outside organizations which participated actively in the emergency response, we find it significant that there were widespread dosimetry problems with respect to two of those organizations. Beyond that, the lack of participation by so many other organizations makes it clear that there is no basis upon which one could conclude that LILCO has in i
fact implemented an adequate training program for personnel of
- outside organizations.
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- 2. Suboart H Q. Gentlemen, some of the foregoing examples relate to deficiencies in dosimetry and radiation protection training.
, Accordingly, they relate not only to subpart G of Contention Ex 50 but also to subpart H of Contention Ex 50. Are there other examples not involving outside organizations which support your views concerning subpart H of Contention Ex 50?
y A. Yes. The Exercise demonstrated that LILCO's training has been deficient in the areas of dosimetry, exposure control, KI, and related areas for its own personnel as well as for outside organizations. For example, during the Exercise, the following was noted by FEMA:
a One bus' driver dispatched from the Port Jefferson Staging Area failed to read his DRDs at any time during the 75 minutes that he was in the EPZ (agg FEMA Report at xiv, 59);
One of the general population evacuation route bus drivers dispatched from the Patchogue Staging Area'only read his DRDs twice, and then only at the instruction of the Transfer Point Coordinator, and another read his DRDs'only when it was convenient (agg FEMA Report at 68, 69);
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One of the drivers for the general population evacuation bus routes dispatched from the Riverhead Staging Area did not read his DRDs every 15 minutes, as required by OPIP 3.9.1 (ggg FEMA Report at xvii, 76, 77);
One bus driver dispatched from the Riverhead Staging Area simulated the ingestion of his KI tablet prematurely, prior to being assigned an evacuation route (agg FEMA Report at 76, 77);
On the basis of these problems, FEMA found that LILCO's bus drivers should be given additional training in these matters.
FEMA Report at 69-70, 77.
Q. Are.there other examples from the Exercise that demonstrate the ineffectiveness of LILCO's training in the areas covered by subpart H?
A. Yes. For example:
One of LILCO's Route Alerting Drivers believed he would receive KI authorization in an EBS message.70 (Egg FEMA Report at xvi, 69, 70).
70 FEMA found that LILCO's Route Alert Drivers should be trained to Know that KI authorization is to be issued to them by their supervisor as specified in the LILCO Plan (OPIP 3.3.4, Att. 1). FEMA Report at 70.
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l Traffic Guides at two Traffic Control Points did not know dose. authorization limits.71 Traffic Guides at two Traffic Control Points did not fully understand that the chain of command for excess exposure authorization gives the Lead Traffic Guide authority to authorize excess expos:re by radio. Further, some Traffic Guides indicated to FEMA that they might question the authority of the Lead Traffic Guide to issue the authorization for excess exposure (despite the fact that it is specifically established under LILCO's Plan that the Lead Traffic Guide can authorize exposure in excess of the general population PAGs, and that this can be done by radio). Egg FEMA Report at 70.
Two of the eight Traffic Guides observed by FEMA did not fully understand the difference between low- and mid-range DRDs (see FEMA Report at 76).
The Patchogue Staging Area Bus Dispatcher misinformed LILCO bus drivers when instructing them in how to read their DRDs (agg FEMA Report at 68, 69).
These, examples are significant, particularly since FEMA evaluated a very small number of LERO workers. Egg Contention Ex 21. The existence of so many training deficiencies in a small 71 FEMA found that LILCO needed to train Traffic Guides so that they learned dose authorization limits. FEMA Report at 70.
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number of workers evaluated by FEMA, strongly suggests that the problems are widespread. Yet, despite the obvious importance of such training, LILCO failed to provide any training at all to non-LILCO personnel, and failed to provide adequate training to its own personnel.
O. Has your review of the post-Exercise drill reports led to any changes in your opinions concerning LILCO's ineffectiveness in training personnel in the areas of dosimetry, exposure control, KI, and related areas?
A. No. In fact, a review of the post-Exercise drill reports has solidified our conclusion that LILCO's training program has been deficient in these areas.
For example, during the June 6 drill, several Traffic Guides were not clear on the procedure regarding exposure authorization
' levels. Attachment 7 at 6. The same general types of training deficiencies showed up again during the September 10 drill.
Thus, as had been the case during the June 6 drill, Traffic Guides were not aware of critical radiation control information.
In fact, most of those questioned were not aware of the maximum allowable dose or the proper procedures governing the use of KI.
Attachment 8 at 4-5. Further, two Road Crews were not aware of
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the proper procedures regarding the use of dosimetry and maximum exposure allowances. They also were not properly informed about when to take their KI tablets. Id. at 6.72 .
I Q. Has your review of the December drill report changed I
your view regarding Contention Ex 50 in any way?
A. No it has not. Problems occurred in the December 10 drill. Thus, the Director authorized exposure up to 10 rem for a field worker without consulting the Radiation Health Coordinator.
Attachment 9 at 12. And, a road crew worker failed to read his dosimeter every 15 minutes during the December 10 drill.
Attachment 9 at 41.
In conclusion, therefore, we see no basis in the post-Exercise training drills of LILCO to find any reason to alter our prior conclusion. LILCO has failed to adequately train its personnel, as well as those in support organizations, to understand and follow directions related to dosimetry, exposure control, K-1, and related areas.
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72 A review of the September 17 drill further supports our concerns about the inadequacy of LILCO's training program with respect to the training of personnel in the areas of dosimetry, exposure control, KI, and related areas. The distribution of dosimetry was not well controlled, and many personnel missed their dosimetry briefings. Attachment 8 at 8.
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l H. Contention Ex 50.I: LILCO's Modifications to ;
Its Trainino Procram are Ineffective l l
Q. Please state subpart I of Contention Ex 50.
A. Subpart I-states:
The exercise demonstrated that LILCO's proposals to modify training materials or procedures to
" emphasize" such things as " accurate use of field data," the need "to relay instructions," "the need to be more precise with information," or other matters already in the procedures and training materials (agg letter dated June 20, 1986, from John Leonard to Harold Denton (SNRC-1269), Encl. 1) -- training materials and procedures which have been so unsuccessful for three years -- would not correct the flaws revealed by the exercise.
Q. Do you agree with Subpart I?
A. Yes, we do. In our opinion, the Exercise clearly demonstrated that LILCO's proposed modifications will have little, if any, effect on how well personnel are trained.
- 1. LILCO's Proposed Training Changes Represents No Real Chance Q. Are you familiar with LILCO's proposed changes to its training program?
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A. Yes, we are. They are discussed in a document titled "SNRC-1269." Virtually every modification made by LILCO was made in direct response to a " Deficiency" or "ARCA" found by FEMA.
Each FEMA comment and LILCO response relating to training is set forth in SNRC-1269, which is Attachment 10 to this testimony.
Q. Are you aware of any additional training changes that LILCO has either implemented or proposed in addition to those listed in SNRC-1269?
A. Yes. LILCO has implemented a few minor changes to its training program in addition to those listed in SNRC-1269. These include: the addition of mini-tabletops for field personnel; and the creation of so-called " action diagrams" to be used during mini-tabletops.73 In addition, LILCO's personnel now receive all their classroom training on the same day and LILCO has shortened at least one videotape (the basic radiation module videotape).
See Deposition of Dennis N. Behr (January 13, 1987), at 61-62, 88.
l 73 LILCO has also created identification badges which have job functions and dosimetry information printed on the back. Egg Deposition of Dennis N. Behr (January 13, 1987), at 66. Contrary to LILCO's apparent position, however, we do not consider these badges to be a training modification.
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Q. Do you'believe that the changes reflected in SNRC-1269 ,
i
.and as otherwise' described above will solve the problems with LILCO's training program that were demonstrated both during the Exercise and in post-Exercise drills?
A. No, we do not. In fact, in our opinion, the changes in LILCO's training program that have been proposed and implemented since the February 13 Exercise do virtually nothing to solve the j
many problems with LILCO's program. We have already discussed many of these matters in connection with other subparts. That discussion will not be repeated.
i i-We emphasize, however, that LILCO's training program, as modified since the Exercise, is conceptually no different than it was when it was first implemented three years ago. Egg Deposition of Dennis N. Behr (January 13, 1987), at p. 81.
! ~ Making minor modifications, emphasizing specific tasks (when such j~ " emphasis" is accomplished primarily by highlighting tasks using colored pencils, as LILCO has done in its " action diagrams"), and 4
providing essentially more of the same kinds of training which
. have been ineffective in the past, cannot improve a training pro-1 gram as seriously flawed as is LILCO's program. There is simply no reason to believe that a training program that has been as l
unsuccessful as LILCO's, as demonstrated by the Exercise, despite having had three years in which to train personnel and three
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dress rehearsals and other drills just prior to the Exercise, will become successful by making the kinds of minor modifications proposed and implemented by LILCO.
Q. Please explain.
A. For example, LILCO now proposes to.tell trainees during classroom lectures and tabletops to be " aware" of their particu-lar jobs and the functions that need to be performed. In our opinion, this is not a " change" or " improvement" even worth discussing. If LILCO's original training program did not impart this most basic information, then it was totally inadequate to begin with. Merely repeating what one has already been told --
without effect -- for three years of prior training, will have no noticeable impact.
LILCO has also created what it calls " action diagrams."
These action diagrams are nothing more than charts that depict t the job tasks of LERO personnel, highlighted in different colors.
Clearly, LILCO's original training materials already had information -- albeit ineffective in many instances -- which depict job tasks.
Such " changes" in a training program as just described cannot be realistically expected to improve performance to any significant degree, if at all. They do nothing more than tell
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LILCO's personnel what to do, which is, presumably, what LILCO has been doing for three years of prior training. They do nothing additional to teach personnel how to do them. It is training in how to accomplish a job, in learning by doing, not merely telling trainees the job to be done, that is needed.-
Simply put, the training methodology utilized by LILCO is no different than it has been for the past three years, and there is therefore no basis for us to conclude that LILCO's training l program will be any more successful in the future than it has l been in the past, or was during the Exercise.
- 2. LILCO's Organizational Structure Will Make It Difficult for LILCO to Successfully Train its Personnel Q. Are there any additional reasons why LILCO's fixes will not be successful?
A. Yes. The LILCO fixes likely will not succeed for the additional reason that there are inherent deficiencies in LILCO's structure which would make it extremely difficult for LILCO's training program, even as modified, to succeed. LILCO's program would have to be implemented with great skill but, as demon-strated by the Exercise results, there is no basis to believe that LILCO's training program has been well implemented, much less successful.
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Q. Please explain what you mean.
A. LERO personnel supposedly are given basic training and training in interactions that would be consistent with the organizational structure of LERO. As demonstrated in the Exer-cise, LERO's structure is designed for routine tasks, in that it is quite centralized, and yet it has some wide spans of control.
It is not a structure that could readily respond to emergencies, or unexpected events, even though it purports to be an emergency organization. Thus, despite LILCO efforts to devise a training program to teach personnel to implement its organizational structure, such efforts will likely fail.74 Q. Please explain how LILCO's structure relates to the effectiveness of its training program.
A. The LERO organizational structure bears directly on the effectiveness of the training program. To the extent that people are trained to fit into LERO's structure, their training may be inappropriate for the kinds of tasks that the organization will confront. By that we mean not the literal tasks of following a map or contacting the Coast Guard, but the generic nature of the 74 An organization which has a highly centralized structure and wide span of control is not agr gg incapable of responding well to non-routine emergency situations. To the contrary, many law enforcement agencies, including the FBI, have such structures.
However, they are much different than LERO in having the ability to also emphasize flexibility and decentralization in crisis management and have repeated real life practice to make their structures work.
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N-
l tasks, which'are certain to be more non-routine than routine.
People are going to have.to " scramble," innovate,. jury-rig things, find substitute personnel or equipment, convince i distraught citizens that they should stay put, convince their-fellow workers not to flee, and so on.
However, given the structure of the LERO organization,-that is, the roles that people are trained for as laid out in the Plan documents, and the authority relations, and number of people and functions that top management has to control, we find little evidence that the LERO organization can perform effective.
training for non-routine events. Were it to do that kind of training, it probably would have to modify its structure.
I j The organizational structure devised for LERO is a i
i conventional, highly centralized structure with large spans of control. It would be an appropriate structure for routine operations if the spans of control were reduced in several cases.
But even if this were achieved, it remains an inappropriate structure for emergency operations, in that emergency operations, almost by definition, involve non-routine events and LERO does i
not have an opportunity for learning by doing training to gain
- the necessary experience to operate effectively with its organizational framework. Alternative structures involving some matrix forms that permit decentralization of responses would be 202 -
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possible only if personnel learned to work together over a long period of continuous operation under a large variety of conditions.
l LERO has designed its training program to fit its structure.
Thus, LERO is training for specific, set tasks, clearly demarcated into videotape modules or manuals, and emphasizing
( lines of authority and reporting. Its proposed " fixes" in response to the Exercise findings are simply more of LERO's training for routine events. But LERO's training will not succeed, because the training for a fixed, static, centralized organizational structure is incompatible with the kinds of uncertainties that will be encountered and the kind of adaptive, flexible, decentralized behavior that will be required.
Q. Could you explain what you mean when you say the structure of LERO is more suitable for routine operations but that the tasks that LERO has to perform will be anything but routine?
A. LERO has a straightforward structure, much as a power plant or an industrial plant would have. It is very centralized.
For example, under current LERO procedure when a road impediment is identified, it can be dealt with only upon orders of the Evacuation Coordinator at the EOC, whose orders then must be passed down a vertical chain until, finally, the LERO line
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personnel who must deal with the impediment finally are brought into action. Similarly, the lines of authority are such that except for the EOC, only the three staging areas have any separate status or autonomy, and within them it appears that anything of consequence has to go to the top (i.e., the EOC) for a decision. There is little decentralization of groups that can handle " local" problems, even though such problems likely will arise during an actual emergency. Thus, LERO is an organization where people call information up the line, and receive orders down the line. People are not expected to communicate and share information laterally in the organization, and people in the field have no authority to make their own decisions without seeking permission or guidance because of the urgency of the problem, the lack of information about the problem at higher levels, or the difficulty of reaching the higher levels.
A centralized structure can handle routine events because these events are predictable, and thus the level at which the decision can be made is known in advance, and there is little need for lateral communication across suborganizations because no problems should emerge that require this. Almost all organizations have to violate the centralization requirements built into the authority structure and rules as unexpected events appear. Generally, they set aside the heirarchy temporarily, and
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create temporary groups made up of people from different units, and allow communications to jump authority levels or cross over the divisions in the organization.75 We could find no evidence of temporary groups or cross-unit communications in LERO drills and exercises. There appear to be no provisions for coping with the need to jump lines of authority, or have lateral or diagonal communications across units. Apparently, LERO has trained its people to follow the book in virtually all cases.76 But obviously, there will be unexpected problems in an emergency, so the lines of authority and procedures must be held in suspension temporarily. More important, methods for dealing with unexpected problems can be built into a structure, even if it is quite centralized. Task groups can be set up to deal with cross-unit problems that have to be solved at levels below that at which the heads of two units would normally interact. They must have some autonomy, of course, violating the principle of a single chain of command. Furthermore, drills can simulate situations where it is necessary for a person low on the chain of command to jump one or more levels of authority to immediately l
75 This is what the FBI does quite effectively in crisis situa-tions. Egg the discussion of this in Charles Perrow, Complex Oraanizations: A Critical Essav, 3rd edition, Random House, 1986, pp. 36-42.
76 As previously discussed (ggg Contention Ex 50.B Testimony),
LILCO has been unsuccessful even at this task.
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i reach someone higher. Such behavior can be both unusual for centralized organizations, and threatening for the subordinate person. Therefore, it has to be part of training, so that subordinates can include it in their repertoire, and superiors can get used to talking directly, if need be, to a traffic guide.
Both need this experience, since the need for such changes in authority relationships occurs relatively infrequently and violates the principles of a centralized organization.
We suspect that in LILCO, in its normal daily operations, such cross cutting does occur in minor matters and is not all that foreign. It is hard to envision an organization functioning well otherwise. But LERO is not an organization that functions as an organization often enough or long enough to have this experience, and the people in it have quite different roles than they have when they are with LILCO and interact with people they are not familiar with.
In an organization which purportedly is to be capable of responding to an emergency, we would expect to see an organization chart with extensive provisions for mobilizing temporary groups that cut across functional boundaries such as exist between public information handling and traffic management; provisions for alternative reporting channels in case the normal one is clogged or destroyed; provisions for drawing from other units in the event that leaders are unavailable (because of n
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traffic jams, excessive exposure, or whatever); designated lateral ~ linkages between groups at low and intermediate levels, rather than requiring everything to go up one side to the top and then flow down the other side to the person who needs the information; and specification of coordinating groups that cut across specialties.
We see none of the foregoing characteristics, however, in LERO. Further, the LERO organization is so poorly designed, from the point of span of control and task requirements, it would probably fail. The task would just be too great for many persons who are relied upon.
Q. You used the term " span of control." What do you mean by span of control?
A. (Perrow) Span of control refers to the number of subordinates a superior is directly responsible for, that report to him or her, and also to the variety of functions that these subordinates are responsible for. A part of the organization car.
function well if the manager or superior has a large span of control (i.e., many subordinates, say 10 or even 30), if the jobs of the subordinates are routine, easily monitored, of a similar function, and not interdependent. When the tasks of subordinates are non-routine, and checking on their performance is difficult, and their tasks or functions vary, and especially if these tasks l
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are interdependent so that the subordinates must work together, then a small span of control, as low as 2 or 5, is required, unless there is extensive experience with dealing with large spans of control during crisis situations.
Q. Could you give some examples of spans of control in LERO?
l l A. (Perrow) The Director of Local Response, the head of
( LERO, has a small span of control since there are only two people reporting to him, his deputy, the Manager of Local Response, and the Coordinator of Public Information. On the other hand, some spans of control are quite large. For example:
- 1. There are eight Transfer Point Coordinators for 182 bus drivers at the Patchogue Staging Area. Thus, there is only one supervisor for every 22 Bus Drivers. OPIP 2.1.1, at 78.
- 2. There are only three Lead Traffic Guides for 109 field personnel dispatched from the Port Jefferson Staging Area. These personnel include Route Alert Drivers, Traffic Guides, Evacuation Route Spotters, and Road Crew members. OPIP 2.1.1, at 78. This is one supervisor for 36 field personnel.
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- 3. The Staging Area Coordinators for Port Jefferson, Riverhead and Patchogue each supervise either 15 or 16 people, OPIP 2.1.1, at 78, including the Lead Traffic Guides, Staging Area Support Staff, Dosimetry Record Keepers, and Bus Dispatchers. OPIP 2.1.1, at 78.
Q. Are there means by which LERO could overcome problems l
l with the span of control?
A. (Perrow) Probably not. It would be possible to add another hierarchical level in many of the sub-organizations, relieving some of the burden on managers. However, this adds to the complexity of the organization, creating new opportunities 4 for errors.
As mentioned earlier, a possibility perhaps considered by LERO is a matrix organization. However, a matrix organization probably is not possible for LERO because it requires continuous, intensive operation, and LERO does not have the option.77 77 In a matrix organization, to use the Riverhead Staging Area as an example, instead of the Staging Area Coordinator receiving directions from one person, the Evacuation Coordinator, on the basis of the latter's contact with Traffic, Transportation, and Special Facilities heads with responsibility for Port Jefferson, Riverhead, and Patchogue Staging areas (these heads in turn receive information from their own staffs) -- a traditional hierarchical and function related structure -- we would have a structure roughly as follows: Each Staging Area would have personnel who dealt with all tasks: traffic control, route coordinators, road logistic coordinators, etc., and also the traffic guides, dosimetry record keepers, bus dispatcher, drivers etc. These would be formed into a large matrix wherein each (footnote continued)
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i Q. Are there any other reasons why LILCO's " fixes" for its 1
training problems are, in your opinion, unlikely to succeed?
A. (Perrow) Yes. There are additional reasons, related l to, yet somewhat distinct from, the organizational and span of l
control problems discussed above. These additional reasons relate to the concepts of interactive epmolexity and tiaht couolina, l
Q. What do you mean by these terms and how do they relate to emergency response training by LERO?
2 A. (Perrow) The task of LERO is to determine and communicate appropriate protective action recommendations to the public, to implement them, to provide relocation services, to assist a large number of people, and to direct and control an (footnote continued from previous page) person reports not only to his or her functional head (the Route Alert Drivers, for example, reporting to the Lead Traffic Guide),
but also to a Staging Area coordinator, of which there would be several, each responsible for a particular area, a particular phase of evacuation, or a particular set of anticipated problems, or some mix of these.
In this matrix form, centralized control is minimized, and lateral coordination around particular tasks is emphasized. Here individuals form teams with roughly equivalent status and overlapping assignments, consisting of six to ten or so individuals with shared responsibility, and one team leader who forms the communicating and resource securing role. Matrix organizations require intensive socialization, long periods of working together, particularly under a variety of relevant conditions (e.g. for LERO, emergencies under different conditions such as summers when transients are about, winters when storms are in progress, high road travel days, etc.) Clearly this is impossible for LERO.
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entire community-wide response to a nuclear accident. These tasks involve two distinctive and incompatible conditions:
interactive complexity and tight coupling.78 LILCO's training program is deficient because it ignores this basic fact about the type of task LERO personnel and the organization as a whole are expected to perform.
Interactive complexity is a condition where unanticipated interactions between different parts of the system can take place because of failures in the parts or because intended behavior in one part affects another part in an unforeseen manner. For example, an EOC mistake in handling a message regarding an impediment can immobilize the traffic guides and road crews in the field trying to deal with the problem. The interaction of these several failures could then produce even more traffic as people who did not know of the impediment are caught in traffic.
Tuning into the EBS station for information might produce only the comparatively mild statement that there was a problem at the plant but no word about impediments because the ENC would also be uninformed.
i Compounding the problem is the matter of ticht couclina.
This refers to a variety of interrelated processes: highly time dependent processes (things must happen fast; there is little 78 Egg Charles Perrow, Normal Accidents: Livina With Hiah Risk Technoloales, New York, Basic Book, 1984, for definitions and illustrations of these concepts.
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time to wait for clarification because the accident might get worse and the roads more crowded); inability to stop the " system" (the plant accident, the unplanned evacuation, the traffic jams, etc.) until the failures can be corrected, or to delay parts of it, or reverse it or otherwise change its direction; inability to provide adequate substitutes (helicopters, protective clothing, alternative personnel to remove impediments or direct traffic);
i and an inability to provide buffers that are not designed into the system but which, in a loosely coupled system, are fortuitously available.
Tight coupling means not only that the time available for evacuation and other protective measures may be more limited than anticipated, but that the direction of evacuation cannot easily be changed or reversed, that a tie up on one road means over-loading another road, that the capacity of roads is fixed and cannot be substantially increased, and even that some autos will be low on gas and soon run out while idling in traffic, thus possibly becoming impediments.
An organization that is confronted with interactive com-plexity can only cope with it by radically decentralizing its operations. Decentralization allows those in direct contact with the " failures" such as the traffic impediments, the traffic congestion, the seemingly irrelevant or inaccurate EBS messages, the phone tie ups, etc., to make decisions on the basis of these
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a observed failures and take actions that cannot be foreseen in the emergency plan. Those who experience the unanticipated inter-action of failures first hand are those who are best able to take
- 7 corrective action.
1 As already' discussed, however, there appears to be little provision in the LERO Plan for such decentralization. The flow of information is upwards, and the flow of orders or directives is downwards. A decentralized system would rely upon lateral information flows, lateral directives, directives going up the I hierarchy as well as down, and consultation and problem solving at the point where the disturbances or failures occur regardless of levels of authority. Organizations that are responsive to 1 unexpected events temporarily suspend the lines of authority that [
are in place for handling routine events. The LERO Plan does not i
allow this.79 On the other hand, an emergency situation also requires l centralized command and control structures. Paradoxically, f
i because of the tight coupling of the system (time requirements; p ' no possibility to stop, delay or change directions; and large 79 Traffic Guides are not authorized to direct other personnel at or above their levels, even though interactive complexity would require this behavior wherein those with the most direct ,
experience of the failures can take charge of coping with them by $
giving directives to others that might be above them in the chain of command. However, LERO is modeled after a conventional organ-1:ation which means little interactive complexity and routine tasks and plenty of time to make corrections and plenty of
! opportunities to make substitutions. None of these obtain for LERO.
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I
limits on available substitutions of resources), it should be highly centralized so that those with a " big picture" can give incontrovertible orders to those that only have a small part of the picture. But interactive complexity means that those with a small part of the picture, those on the " firing line" so to speak, have to exercise extraordinary initiative and occasionally' ignore or violate the chain of command.
l l
l We have, then, two potentially incompatible system require-ments: decentralization and centralization. Were LERO the best organization possible, it would have grave difficulty in doing both at the same time.80 The implications for training are that even if LERO instituted training that emphasized individual or group responsibility, adaptiveness, lateral communications, bottom-up authority and so on -- all of which it should emphasize
-- it would run afoul of the need for very rapid response controlled by the very top. But our judgment is that since you can't have both a decentralized and centralized organization (except perhaps under some very special circumstances, such as Naval ships at sea that can drill continuously without inconveniencing anyone and the FBI and other law enforcement agencies), it is better to err on the decentralized side. This 80 Only endless drills and exercises under the most realistic conditions could produce an organization that could cope with these contradictory requirements. Personnel might have to be doubled, equipment trebled (because of the inevitable failure of some equipment; there were several instances in the exercise),
and the added complexity of these increases coped with, and the training, drills and exercises run daily or weekly.
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LILCO has not done. Rather, it has provided for training which is designed to support a highly centralized system but this is incompatible with the realities of what LERO's personnel must do.
Q. Are there examples from the Feb. 13 Exercise that illustrate the foregoing concepts and their implications for LdRO's training program?
A. (Perrow) Yes. The ENC problems provide one example.
The ENC reflects a part of LERO in a tightly coupled posture --
EBS messages, press releases, plant conditions changing, all of which contribute to a fast moving situation that cannot readily be stopped. There is a need to get information out fast because information rapidly becomes obsolete and because the media insists on receiving information. At the same time, there is interactive complexity -- the ENC cannot act unless the EOC has acted. When the copier broke down in the Exercise, this exacerbated the already difficult problem with the result that information did not flow well and the organization was unable to adjust to the changing situation.
Another example involves the Road Crews' responses to the road impediments. The failures there clearly suggest supervisory problems that could have been related to overload. The Crews were on notice that they would be called to duty (an advantage that would not obtain in a real emergency). They are not
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_ . . - - _ .- - - ~ . _ _ .
required to begin reporting to the. staging areas until after a Site Area Emergency had been declared. But, by the time a General Emergency was declared, approximately one hour and twenty minutes after Road crews should have begun reporting to their Staging Areas, less than 25 percent of those required to implement the LILCO Plan were mobilized. LILCO Admission Nos. 146, 147 and 148. As late as 10:20, 16 percent were still not mobilized. LILCO Admission Nos. 149 and 150; LILCO's Response to Suffolk County, State of New York and Town of Southampton's Second Set of Interrogatories to LILCO (dated January 5, 1987), Interrogatory Response No. 8. Obviously, in an actual emergency, they would not be waiting to be called; the personnel doing the calling would not have arrived at their stations as quickly; they would most likely br far busier than they were in the Exercise; heavy early evacuation traffic could be expected,' delaying the arrival of crews at the staging areas; with more staggered arrivals, crews would be harder to assemble; and with heavy traffic it is possible that more road impediments would take place.
The Road Crew delays are not surprising in view of LERO's structure. The Evacuation Coordinator must direct the efforts of seven subordinate areas. Three of these are the Staging Area Coordinators for Port Jefferson, Riverhead and Patchogue. He informs the Staging Area Coordinators; the Coordinators inform the Lead Traffic Guides (each Coordinator deals directly with 15
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or 16 individuals); and the three Lead Traffic Guides mobilize and direct the efforts of from 79 personnel at Patchogue to 84 at Riverhead to 109 at Port Jefferson, an average of over 30 each.
These include Route Alert Drivers, Traffic Guides, Evacuation Route Spotters, and Road Crew personnel. Were this a routine, daily function, it is possible that learning by doing would have taken place and everyone would know what to expect: where the delays might arise; how to contact people quickly; and so on --
the hallmarks of a routine organization. But it would still be a difficult task even on a daily basis with only minor variations in the environment. To have a full exercise with everyone from the Evacuation Coordinator down to the Road Crews involved only once or twice a year will not provide much doing and thus much learning. Thus, a timely execution of the task would be hard because of the many links in the chain of command and the size of the supervisory problem at each level. To do so with very little experience makes it unreasonably hard to perform well; to do so if the public were involved in a simulated emergency would make it even harder; and to do so in a real emergency appears to be even harder. We should not be surprised at the long delays.
1
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T l
IV. CONCLUSION Q .' Please summarize your conclusions.
A. In our opinion, the LILCO training program is seriously inadequate in a number of crucial respects, all of which were demonstrated during the February 13 Exercise. We have no reason to believe that LILCO has or likely could take steps to cure these flaws.
The foregoing flaws in LILCO's training program as detailed in this testimony lead us to conclude that there is no assurance that the protective measures contemplated under the LILCO Plan could or would be implemented in the event of an emergency at
' Shoreham.
j :
Q. Does that conclude your testimony?
A. Yes.
'l
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000 METED USNHC UNITEdISTATES OF AMERICA t. )
NUCLEAR REGULATORY COMMISSION [ " '.j7 fl4R 23 P5 :24 Before the-Atomic Safety and Licensina Board CFFICE 3F 3hgggy DOCKEriNG A SERVICT' -
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LONG ISLAND LIGHTING COMPANY- ) Docket No. 50-322-OL-5
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(Shoreham Nuclear Power Station, )
Unit 1). )
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ATTACHMENTS ,'
TO DIRECT TESTIMONY OF WILLIAM LEE.COLWELL, DEPUTY INSPECTOR PETER:F. COSGROVE, PHILIP EVANS, CHARLES B. PERROW, FORD ROWAN,-
LIEUTENANT JOHN W. STREETER, JR., AND HAROLD RICHARD ZOOK ON BEHALF OF SUFFOLK COUNTY REGARDING CONTENTION EX 50 -- TRAINING OF OFFSITE EMERGENCY RESPONSE PERSONNEL March 20, 1987
UNITED STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY. ) Docket No. 50-322-OL-5
) (EP Exercise)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
ATTACHMENTS TO DIRECT TESTIMONY OF WILLIAM LEE COLWELL, DEPUTY INSPECTOR PETER F. COSGROVE, PHILIP EVANS, CHARLES B. PERROW, FORD ROWAN, LIEUTENANT JOHN W. STREETER, JR., AND HAROLD RICHARD ZOOK ON BEHALF OF SUFFOLK COUNTY REGARDING CONTENTION EX 50 -- TRAINING OF OFFSITE EMERGENCY RESPONSE PERSONNEL March 20, 1987 1
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ATTACHMENTS Attachment 1 Professional Qualifications of William Lee Colwell Attachment 2 Professional Qualifications of Deputy Inspector Peter F. Cosgrove Attachment 3 Professional Qualifications of Charles B. Perrow Attachment 4 Professional Qualifications of Lieutenant John W. Streeter Attachment 5 Professional Qualifications of Harold Richard Zook Attachment 6 Contention EX 50 Attachment 7 Drill Report for June 6, 1986 Attachment 8 Drill Report for September 10, September 17, and October 1, 1986 Attachment 9 Drill Report for December 2 and December 10, 1986 Attachment 10 SNRC-1269 - Letter dated June 20, 1 1986, from John Leonard to Harold Denton
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' WILLIAM LEE COLWELL ACADEMIC DEGREES Bachelor.of Science in Business Administration, Little Rock University, 1961 .
Master of Public' Administration, University of Southern 1
California, 1982 Doctor of Public Administration, University of Southern California, 1985 AWARDS Attorney General's Exceptional Service Award, January, 1983, in recognition of service to the FBI, the U. S. Department of Justice, and the American Public.
National Association of Schools of Public Administration and Affairs, Nominated as a Finalist for Annual Outstanding Award.
TEACHING EXPERIENCE FBI Academy Training-Division, 1970-1973 -- Instruction on weekly basis addressing substantive and policy issues relative to criminal investigations.
Class Counselor, Instructor, Student Advisor and Evaluator to.new Agents' classes, 1972-1973.
Lectured in areas related to inspection, professional responsibility, and implementation of policy, 1975-1977.
Participated in planning, development, and presentation of all executive type development courses sponsored by the Training Division, 1977-1985.
University cf Vircinia (1973 - Present) :
Adjunct Professor.
University of Southern California Washincton Public Affairs Center (1980 - 1985)
Adjunct Professor, appeared regularly as Guest Lecturer and consultant on a variety of Public Administration topics.
I
~ _ _ __. . _ . _ . _ . . _ _ _ _ ._. _ _ _ _ . . . _ _ . . _ _ . . . _ _ - - __
Institute for Law and Social Research (INSLAW)
Consultant and resource person.
, University of Arkansar, - Little Rock (1985 - Present)
Associate. Professor - Criminal Justice Department. Member of International Studies Faculty.
Evaluator and consultant through University of Arkansas at Little Rock to representatives of city, county and State governments on the effectiveness of police services, includ-ing training, in the State of Arkansas.
BIBLIOGRAPHY PUBLISHED Article Title Journal and Date
" Progressive Law Enforcement Arkansas Municipal Police in Arkansas" Journal, 1980 "The Effects of Budgetary Arkansas Municipal Police Constraints on Law Enforcement Journal, 1981-1982 Resource Management and Allocation"
'" Good Manager Can Recognize Arkansas Municipal Police-and Relieve Staff Stress" Journal, 1982-1983
" Fighting the Budget Crunch -- Arkansas Municipal Police Is Japanese Management an Answer?" Journal, 1983-1984
" Performance Measurement for Journal of Police Science Criminal Justice -- The FBI & Administration, Vol.
Experience" 12, No. 2, Spring, 1984 Reprint Public Productivity Review, Fall, 1984
" Formulating a Corporate Response Arkansas Municipal Police
- to Terrorism" Journal, 1984-1985 1
" Reacting to Terrorism: Security Management, Don't Fue1 the Fire" February, 1985
" Designing a Corporate Response The Police Chief, to Terrorism" February, 1985 i
"Long Range Planning in the FBI" FBI Management Quarterly, September, 1985 Official FBI Research Documents Sample of Documents prepared by Dr. Colwell or under his immediate direction or general supervision.
Document Title Date Bank Robbery Suspects Program 1977 and Effectiveness of Bank Robbery Investigations Field Police Training 1977 Psychological Services Within the FBI 1977 Training of FBI Managerial Personnel 1977 Principal Administrative Features 1980 of the FBI, U.S. Department of
, Justice Problem Analysis - One Approach to 1980 Improve a System Within an Organization Policy Issues Affecting an Evalua- 1981 tion of a More Active FBI Role in Drug Enforcement Drug Enforcement Efforts 1981 A Comparison of Selected Provisions 1981 of the U.S. Civil Service Reform Act of 1978 with Principal Practices in Personnel Administration Career Development Program 1981 An Analysis of Resource Allocation 1981 in a Law Enforcement Agency FBI Role in Police Training 1982 .
Establishing Recruiting Priorities 1982 and Capabilities
LOfficial FBI Research Documents (Continued)
Document Title Date Change and Its Importance to 1982 Public Administration Organizational Change Within- 1982 the FBI
-FBI / DEA' Budget. Coordination 1984 Consolidation of1 FBI / DEA 1984 Procurement Functions-Impact of Automation Efforts 1984 The FBI's Role in Investigating 1984 Labor Racketeering Coordination and Collocation 1985 lof. FBI and DEA Training at the FBI Academy The Further Integration of 1985 Administrative Aspects of FBI and DEA Expanded Integration of Inspection / 1985' Evaluation Aspects of FBI and DEA Integration / Allocation of FBI / DEA 1985 Personnel Resources UNPUBLISHED "How to Prevent Interpersonal Change" 1982
" Qualitative Evaluation in the FBI" 1985 "An Examination of the 1982 Decision to Reorganize the FBI and DEA" (Doctoral Dissertation)
PAPERS PRESENTED AT CONFERENCES
" Role of FBI in Policing," International Association of Chiefs of Police, Annual Conference; Dallas, Texas; 1977.
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PAPERS PRESENTED AT CONFERENCES (Continued)
" Trends and Crime Prevention: a Perspective," Sixth United Nations Congress, Prevention of Crime and Treatment of Offender; Caracas, Venezuela; 1980 (participant and delegate).
" Allocation of Resources," American Psychological Association; Atlanta, Georgia; February, 1981.
" Role of FBI's Personal Crimes Program in Combating Violent Crime"; " FBI's Role in Combating Drug Trafficking," Interpol; Torremolinos, Spain; October, 1982.
" Performance Measurement Systems," American Society of Public Administration (ASPA) National Conference; New York; April, 1983.
WORK EXPERIENCE Dr. Colwell previously was the Associate Director and Chief Executive Officer of the Federal Bureau of Investigation, a position that is regarded as the senior career law enforcement position in the entire United States. He frequently served as Acting Director of the FBI.
As Chief Executive Officer of the FBI, Dr. Colwell was directly responsible for a budget in excess of one billion dollars,-the direction of policy review and analysis, budget formulation and implementation, and allocation of FBI resources and oversight of all administrative investigative operations involving 20,000 employees in the FBI's 59 field offices and 14 foreign posts. He was also responsible for program evaluation, long-range planning, and review of personnel actions. He was instrumental in the development of an innovative management information system for the FBI. He also oversaw FBI public affairs.and congressional liaison functions and frequently testified before Congress.-
A career employee, Dr. Colwell held every investigative and management position ~in the FBI. He served as Executive Assistant Director for both Investigations and Administration. He served on special assignment as Coordinator of the Surveys and Investigations Staff of the House Appropriations Committee to review appropriations requests for entire management systems of the Executive Branch of the Federal Government. .
Dr. Colwell helped develop the FBI's National Emergency Operations Center located in FBI Headquarters, with links to the White House, Department of Justice, Department of Energy, Department of Defense, all FBI field divisions, and other local,
-state and federal agencies during a crisis. In the absence of l
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the FBI Director, Dr. Colwell was in command of any crisis l situation that involved local, national, or international dimensions.
FBI Procrams Graduate of, FBI Senior Executive Program and National Executive Institute.
One of five original evaluators for the FBI's Personnel Assessment Center. Reviewed leadership dimensions of candidates for supervisory positions.
Panels - Committees Law enforcement applicant interview panel, Pulaski County, Arkansas, Civil Service Commission Vice President's Task Force on Terrorism Center for Strategic and' International Studies, Georgetown University on Terrorism (chaired by Dr. Zbigniew Brzezinski)
Program Director for an international seminars security crisis management planning for seven Eastern Carribean nations in November 1985, and representatives from Turkey, March 1986 Sino-American Criminal Justice Institute, August 1986, Taipei, Taiwan, Republic of China. One of nine U.S.
representatives invited to participate in first such meeting. Included lectures at Taiwan Central Police College and Tunghai University.
i CONGRESSIONAL TESTIMONY
[ During the period 1976-1985, Associate Director Colwell testified frequently before U.S. Senate and U.S. House of Representatives committees on topics such as terrorism, organized crime, and the administration of the FBI,
, including budget matters. He testified regularly before the U.S. Department of Justice budget committees and the Office of Management and Budget.
I I PROFESSIONAL ASSOCIATIONS American Management Association American Society of Industrial Security American Society of Public Administration Arkansas Law Enforcement Officers Association International Association of Chiefs of Police-Maryland Law Enforcement Officers Association Police Management Association Society for Long Range Planning Tarrytown 100 (charter member along with Peter Drucker and others)
Texas Police Association Texas Sheriffs Association 4
World Future Society I
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Personal Resume Deputy Inspector Peter F. Cosgrove Suffolk County Police Department Police Emperience ,
F;bruary, 1985 - present Commanding Officer, Personnel Bureau J nu:ry, 1984- Promoted to Deputy Inspector, February, 1985 Executive Officer, 3rd Precinct Occcber, 1981 -
January, 1984 Commanding Officer, Police Academy .Section M:y, 1980 Promoted to Captain F;bruary, 1979 -
October, 1981 Commanding Officer, Personnel Section S:ptcmber, 1977 -
February, 1979 Commanding Officer, Employee Relations Unic J:nunry, 1977 - Assigned to Chief of Detectives Office
. September, 1977 to develop performance evaluation program S:pt:mber, 1975 Promoted to Lieutenant S:ptember, 1975 -
January, 1977 Assigned to Sixth Precinct, Patrol Supervisor D ccaber, 1972 - Assigned to Police Academy Section, September, 1975 Recruit Training Unit Octcher, 1971 Promoted to Sergeant October, 1971 -
December, 1972 Assigned to Fourth Precinct, Patrol Supervisor c
July, 1966 -
October, 1971 Assigned to Sixth Precinct, patrol duties May, 1966 Appointed to Suffolk County Police Department F7rmal Education:
1982 Completed course work for Master of Public Administration, C. W. Post College, L. I. University
- 1974 B.S. Behavioral Science, N.Y. Institute of Technology I
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F ~ rant Educat ion: -(cont . )
1970 A.A.S. Police Science, Suffolk County Community College Related Training & Education:
1983 FBI National Academy, 132nd Session (11 weeks) 1974 Ethical Awareness Instructors Workshop N.Y.S. Bureau for Municipal Police (I week) 1974 Police Performance Appraisal Workshop Northwest Traffic Institute (I week) 1973 . Basic Instructors School, Internal Revenue Service (2 weeks)
Related Experience:_
1972 - Present Lecturer, Suffolk County Police Academy 1972 - Present Adjunct Asst. Prof. , Suffolk County' Community College 1973 - 1976 Training Instructor, N.Y.S. Bureau for Municipal Police 1975 - Present Training Instructor, Suffolk County Department of Health 1979 - Present Lecturer, Suffolk County Sheriff's Department Certificates & Memberships:
Cartified New York State Police Instructor N:w York State Association of Chiefs of Police N:ticnal Academy Associates American Society of Personnel Administrators
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6/86 Curriculum Vitae Charles B. Perrow Education University of California, Berkeley B.A. 1953, M.A. 1955, Ph.D. 1960, all in Sociology
-Present Position Professor, Department of Sociology Yale University, Box 1965 Yale Station New Haven, Connecticut 06520 Personal Born 1925, Tacoma, Washington Married, two children Social Security No. 532-18-4107 Imaching Ensitions 1959-1963 Instructor to Assistant Professor, Department of Sociology, University of Michigan, Ann Arbor.
1963-1966 Assistant to Associate Professor, Department of Sociology, and the School of Public and International Affairs, and the Administrative Science Center, University of Pittsburgh.
1966-1970 Associate Professor to Professor, Department of Sociology, University of Wisconsin; Head, Social Organization Center, 1966-1970.
1968-1969 Visiting Professor, Institute of Industrial Relations and School of Business Administration, University of California, Berkeley.
1970-1981 Professor, Department of Sociology, State University of New York at Stony Brook.
1972-1973 Visiting Professor, London Graduate School of Business, London. ,.
1981-1982 Fellow, Center for Advanced Study in the Behavioral Sciences, Palo Alto, California.
1981-Pres. Professor, Department of Sociology, Yale University.
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2 Major Research Grants 1957-1958 NIMH Predoctoral Fellowship. Goals and authority in general hospital.
1958-1962 NIMH Grant. Associate Study Director, comparative study of seven juvenile correctional institutions.
1963 NIMH Grant. Panel study of a correctional institution.
1965-1967 NSF Grant. Comparative study of eight industrial corporations.
1967-1968 NSF Grant and Vocational Rehabilitation Grant, Comparative study of fourteen industrial corporations.
1971-1972 NIMH Grant. Insurgency and social change in U.S.,
1948-1970.
1973-1976 NIMH Grant. Insurgency and social change in U.S.,
1948-1972.
1978 NSF Grant. Origins of industrial bureaucracy in the U.S.
1980-1982 NSF Grant. Accidents in High Risk S'ystems.
1982 Office of Naval Research Grant. Organizational Context of Human Factors.
Consultancies and Minor Grants 1956-1958 Evaluation study for OVR of Home Care Program, Mount Zion Hospital; Evaluation study of alcoholic rehabilitation program, California State Alcoholism Commission.
1963-1964 Evaluation study of half-way home program for Federal Bureau of Prisons. (with other co-investigators); Consultant and research role for City Youth Commission.
1974-1975 Consultant to Philips Industries, E'indhoven, Holland, on work structuring program.
1972-1973 Consultant on various projects in public sector
! for Imperial College of Science and Technology, l London.
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Consultancies and Minor Grants (continued) 1972-1975 Workshop leader, for Dale-Loveluck Associates, running two-day workshops for executives in London.
1973-1974 Evaluation study of administrative practices in student services at Stony Brook.
1975 Consultant on evaluation strategies for AID rural health programs; Consultant, Office of Tele-communications Policy, electronic funds transfer.
1979 Background paper for President's Commission on the Three Mile Island Accident, "T H I-- A Normal Accident."
1979 Consultant to Institute of Public Service, New York City, interview ard surveys of New York City Welfare Department employees.
1979-1980 Nuclear Regulatory Commission, panel member of Safety Goals for Nuclear Power Plants conferences.
1980-1981 Battelle Institute, panel member of group studying the optimum organizational structure for nuclear power plants, sponsored by the Nuclear Regulatory Commission.
1981-1982 Dioxin in the Office Building: the Generation of Risk Assessment in Terms of Personal Tragedy and Organizational Dilemmas. Russell Sage Foundation, small grant.
1982 Consultant to Institute of Public Service, New York City, on survey of employee attitudes for Citibank.
1982 Testimony for Friends of the Earth at the Indian Point Restart Hearings before a three person special Federal Judge panel.
1985- Consultant to law firms regarding chemical plant accidents.
1985- Pro bono work for the Oil, Chemical and Atomic Workers Union, regarding chemeial plant safety.
Teaching Interests Complex Organizations, Industrial Society, Technology and Social Change, Social Movements, Research Design, Sociological Theory.
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i Honors and Membershios Phi Beta Kappa; Newhouse Fellowship (University of California)
Public Health Pre-Doctoral Fellowship Public Health Service, Special Fellowship Vice-President:. Eastern Sociological Society National Association for Advancement of Scier~e, Fellow National Research Council, Committee on Human r wtor Research, 1981-83 Editorial Board Membership: American Sociological Review, Administrative Science Quarterly, American Journal of Health and Social Behavior, Administration and Society Council Member, Section on Professions and Organizations:
American Sociological Association Sociology Panel: National Science Foundation Senior Research Fellow: Center for Policy Research Mestar AAAS, Nominating-Committee, Section K.
Industrial Relations Association J Eastern Sociological Society
- International Sociological Association 4
- Normal Accidents recipient of the 1985 George R. Terry Book Award, Academy of Management.
Books and Published Monograohs
- 1. Studx an Zhn Ran=Sngrngatts Hu291Lalizakkan af A1CQhn11n fa11Anta in a Gantral HAAD11al, (Ameriean Hospital Association, Hospital Monograph Series 7, 1959) with Mark Berke, Jack D. Gordon, M.D., and Robert I. Levy, M.D., 120 pages.
- 2. Organization Inr Irmatman11 A Enmaaratiya Study sf Juvenile Correctional Institutions, New York: The Free Press, 1966) with David Street and Robert D. Vinter.
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- 3. Organiza11snal Analyalai A Sosiningisal Ying, Belmont, Ca.: Wadsworth Publishing Co. 1970, (Chapters have been reprinted).
- 4. .Enanlax Drgan;t.ilsnsi A fritisal Essay, Glenview, Ill.: Scott, Foresman, 1972. (Chapters h, ave been reprinted.) Revised edition, 1979 Third edition:
1986.
- 5. Ihn Radica1'AL%ack on Bunkanss. Harcourt Brace Jovanovich, 1972.
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- 6. Entmal Accidents: Living with High Risk Technolonies, Basic Books, 1984.
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5 Research Articles nr Chanters
- 1. "Are Retirement Adjustment Programs Necessary?,"
Harvard Business Review, 35:4 (July-August, 1957), 109-15.' ,
- 2. "Gemeinschaft and Gesellschaft: A Critical Analysis of the Use of a Polar Tysiology," Berkelev Publications in inallintinna and Snniaty, 2:1 (Spring, 1956), 20-43 Also reprinted in Autonomous Group Bulletin, XIII:1, 2 (Autumn-Winter, 1957), 10-16.
- 3. "Research in a Home Care Program," American Journal nf Public Health, 49: 1 (January, 1959), 34-44.
- 4. " Nonsegregated Hospitalization of Alcoholic Patients in a General Hospital," Haagitala, Journal of the American Hospital Association, Vol. 33, (Nov. 16, 1959), 45-48, with Mark Berke, Jack D. Gordon, M.D.,
and Robert I. Levy, M.D.
- 5. " Organizational Prestige: Some Functions ' and Dysfunctions," Amarinan inMrnal af Saniningy, 66:4
. (January, 1961), 335-41. Reprinted in 3 books.
- 6. " Reality Shock: A New Organization Confronts the Custody-Treatment Dilemma," Sonial Ernhiana, 10:4 (Spring, 1963), 374-82.
- 7. " Goals and Authority Structures,-A Historical Case Study," Chapter 4 in Ihm Hnamital in Endarn annimix, Eliot Freidson, (ed.), (The Free Press, 1963), 112-46.
- 8. " Sociological Perspective and Political Pluralism,"
Social Rastarsh, 31:4 (Winter, 1964-65), 411-22.
Reprinted.
- 9. "The Reluctant Organization and the Aggressive Environ-men t ," (with John Maniha), Administratiya Solanna cuarteriv, 10:2 (September, 1965), 238-57. Reprinted.
- 10. " Hospitals: Technology, Goals and Structure," Chapter 22 in Handhnnk of Drganizatinna, James March (ed.),
Rand McNally, 1965),. 910-71.
- 11. " Reality Adjustment: A Young Institution Se'ttles for Humane Care," Social Problema,14:1 (Summer, 1966), 69-79
- 12. " Technology and Organizational Structure," Proceedings of the 19th Annual Meeting of the Industrial Relations Research Association, December 1966, 156-63.
. 6 Research Articles gr Chanter (continued)
- 13. "A Framework for the ' Comparative Analysis of Organizations," American annininginal RAX1AM, (April, 1967), 194-208. Reprinted several~ times and in Bobbs-Merrill Series.
- 14. " Organizational Goals," IntArnational Enevelooedia of thA Sanial Sn1AnnAA , r e v i s e d e d i t i o n , ( M a c M i ll a n C o . ,
1968), Vol.11, 3 05-11.
- 15. "The Professional Army in the War on Poverty," " Focus Article" in EnXAr%X And Engan EtanutnAA AkALranLA, (January-February, 1968).
- 16. " Technology and Structural Changes in Business Firms,"
Industrial RA1A11sna.1 EnniAmanrary IAAuAA, B.C.
Roberts, (ed.), (MacMillan Co., 1968), 205-19.
17 "Some Reflections on Technology and Organizations," in A. R. Negandhi, et al. (eds.), SnaAAIA11XA AdakakAgrakkan and BanagAaAnk, Comparative Administration Research Series, No. 1 (Kent State University Press, Kent, Ohio, 1969).
- 18. " Members as a Resource in Voluntary Organization," in QrKAn1XA119A And D11An11, W . R o s e n g r e n a n d M . L e f t o n ,
(eds.), Charles E. Merrill, 1970,93-116.
- 19. " Departmental Power and Perspective in Industrial Firms," in EnMar in ornanizations, edited by Mayer Zald (Vanderbilt University Press, 1970), 59-89.
- 20. "The Short and Glorious History of Organizational Theory," ornanizational DXnAmiga, (Summer 1973), 2-16.
(Reprinted)
- 21. " Zoo Story, or Life in the Organizational Sandpit,"
Chapter in course text, Peoole and Ornanizations, Open University (England), 1974. Revision for 1980 edition.
- 22. "Is Business Really Changing?" ornanizational DXnAmisa (Summer, 1974). (Reprinted) 23 "The Bureaucratic Paradox: The Efficient Organization Centralizes in Order to Decentralize." ornanizational DXnAmins, Spring, 1977, 2-14. (Reprinted) .:
- 24. "Three Types of Organizational Effectiveness," in Paul S. Goodman and Johannes M. Pennings, ed. RAM EarARAnkkXAA nn Dr$AnLZALLanAL Effectiveness, Jossey.
Bass, 1977,96-105. .
. 7 Research Articles er Chanters (continued) 25.- " Insurgency of the Powerless: Farm Worker Movements, 1946-1972" (with Craig Jenkins), American Sociolonical
~
laxism, 42, (April, 1977), 249-68.
- 26. "Demystifying Organizations" in Rosemary C. Sarri and Yeheskel Hasenfeld eds. Iha Managamani nf Human Services, (New York: Columbia University Press, 1978).
105-122.
- 27. "The Sixties Observed," in Mayer M. Zald and John D.
McCarthy, eds., Iha DXnamina af Sanial MAXamania, Cambridge, Mass., Winthrop Publishers, 1979, 192-211.
- 28. "The President's Commission and the Normal Accident,"
in David Sills,~et al. (eds.) Iha Annidant at Ihram Mila Island: Iha Human Dimensiona, Boulder,-Colorado:
The Westview Press, 1981.
2 9. - " Disintegrating Social Sciences," Rax Inzk university Education Quarter 1v, vol. 12, no. 2 (Winter, 1981), 2-9.
- 30. " Markets, Hierarchies and Hegemony: A Critique of Chandler and Williamson," in Andrew Van de Ven and William Joyce, eds. EaragankkXma nn DrgankaakknD Daalan and BahaXint, New York: Wiley Interscience,
.1981, 371-386, 403-404.
- 31. "This Week's Citation Classic," Durrant Dentanta,14 (April 6, 1981), p. 14 (A reflection on item 1_5-
"Framew o rk. . .")
- 32. " Normal Accident at Three Mile Island," San 1111, vol.
18, no. 5 (July / August,1981), 17-26.
- 33. "Three Mile Island: a Normal Accident," David Dunkerley and Graeme Salaman, eds., Iha Internallanal Imachenk af Drganization Studina, 1981, London:
Routledge & Kegan Paul, 1982, 1-25.
- 34. "The Organizational Context of Human Factors,"
Technical Report, U.S. Navy, Of fice of Naval Research, Washington, D.C., November, 1982, 1-50. DTIC
- ADA123435.
- 35. "The Organizational Context of Human . Factors Engineering," Administrative Science cuarteriv, vol.
28, Cornell University, 1983, 521-541.
- 36. "Journaling Careers," i n L.L. Cummings and Peter J.
Frost, eds. Publishing in thg Organizational Sciences, Homewood, Ill.: Richard D. Irwin, Inc., 1985, 220-230.
. 8 Research Articles Dr Chanters (continued)
- 37. " Comment on Langton's ' Ecological Theory of Bureaucracy,'" Administrative Science Quarteriv, vol.
30, 1985, 278-283.
- 38. "Journaling careers," sociolonical Forum' 1:1' Winter 1986, 169-177 39 " Risky Systems: The Habit of Courting Disaster," Itut Nation, October 11,'1986.
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RESUME John W. S tree ter Jr.
Lieutenant Command S124 Suffolk County Police Department EXPERIENCE 1986 -
Present: Suffolk County Police Department 1986 - Present Executive Officer of Police Academy (Lieutenant)
Direct the research, development, production, administration and evaluation of instructional television programs for county, federal, s ta te and local law enforcement agencies within the county. Oversee and Cirect entry level ( re-cruit) training for county, s tate and local en-forcement agencies within the county. Primary ins tructor for police response to critical in-cidents for recruit, in-service and supervisors; training needs assessment, and evaluation of training for new instructors: Instructor-evalu-ator and critical incidents response instructor for Bureau for Municipal Police.
. Meritorious Award for development of critical incidents response instruction methodology.
1984 -
1986: Commanding Officer In-Service Training (Lieutenant)
Direct the research, development, administration, and evaluation of in-service training for county, federal, s ta te and local law enforcement ' agencies.
Primary instructor for critical incidents response, training needs assessment, evaluation of training, training coordina tor for hos tage negotia tions and emergency service units. Instructor - evaluator for Bureau for Municipal Polico.
. Curriculum development, administrator and evaluation of Career Development Course for in-service patrol personnel.
. Curriculum development, administration and evaluation of Career Development Course for in-service investigative personnel.. ,
. Outstanding Achievement Award for 1985 by the Federal Bureau of Investigation National Academy Association of Nassau and Suffolk Counties.
. Bureau for Municipal Police ( N. Y.S. ) commit-tee member - developed new curriculum and l standards for state mandated Police Super-i vision Course.
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. Bureau for Municipal Police (N. Y.S. ) com-mittee member - for development of mandated in-service training standards.
1978 - 1984: Commanding Officer Decentralized Individualized In-Service Training (Sergeant)
Developed, administered and evaluated training needs analysis and evaluation instruments.
Administered and evaluated instructional television programs for county, federal, s ta te and local law enforcement agencies within the county.
. Indepth evaluation and analysis of the use of instru:tional television on attitude, know-ledge and retention.
1977 -
1978 Patrol Supervision (Sergeant)
Generalist police service first ilne supervisor for police of ficers a t precinct level.
1968 - 1977: Police Officer Police service generalist with specialization in Vehicle and Traffic Law enforcement and rescue work.
. Professionalization Award
. Multiple Department commendations 1965 - 1968: Police OfficerInc. Village of Huntington Bay Police service generalist 1963 - 1965: Security Officer Security Officer generalist for Hofstra University 1961 -
1963: Electronic Productive Technician Potentionmeter calibration technician for Computer Instrument Corp.
1960 - 1961: United States Marine Corps Infantryman l
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-3 PROFESSIONAL ACTIVITIES
. F.B.I. National Academy Associates, Member.
International Associa tion of Chiefs of Police, Associate Member.
. Law Enforcement Training Director Association of New York State, Member.
. Suffolk County Police Conference, Member.
. Suffolk County Police Association, Member.
. Suffolk County Police Superiot Officers Association, Member.
. Suffolk County Police Pattoimen's Benevolent Association, Member.
. Suffolk County Police Steuben Association, Financial Secretary.
. Suffolk County Police Columbian Association, Member.
EDUCATION F.B.I. National Academy, (University of Virginia),
Diploma, 1985 ,
Sta te University of New York a t Stony Brook, M.A., Political Science, 1981 New York Institute of Technology, B.S. Behav-local Science, 1976 Suffolk County Community College, A.A.S.,
Criminal Justice, 1975 e
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I RESUME Harold Richard Zook 10015 Chicot Road Little Rock, Arkansas 72209 Residence and Business (501) 562-0610 Obiective:
General Information-
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1943 - 1947 Agency - United States Navy - Active Duty Position - E-5 Reason for Leaving - Honorable Discharge 1949 - 1971 Agency - Little Rock, Arkansas Police Department Position - Captain Reason for Leaving - Retired /22 years service
-1971 - 1978 Agency - United States Government Veterans Administration Department of Medicine & Surgery, Washington, D.C.
Position-Regional Security Officer / Chief, Police Training Center 1980 - 1981 Agency - State of Arkansas Commission on Law Enforcement Standards Position-Executive Director Reason for Leaving - The Commission on Law En-forcement Standards and the Arkansas Law Enforcement Training Academy were con-solidated. Director's position was offered on the condition of permanent change of residence to East Camden, Arkansas. Position was declined. Appointed Deputy Director for the Standards Division. .,
1981 - 1986 - Agency - State of Arkansas Commission on Law Enforcement Standards and Training Position-Deputy Director, Standards Division Reason for Leaving - Retired L
1986 - Retired.' Continuing to serve as a consultant in Present Law Enforcement Administration and Management, remaining active as local, national and inter-national Criminal Justice Training Coordinator.
Professional Orcanizations:
Member: Arkansas Municipal Police Association Member: Arkansas Law Enforcement Officers' Association Member: International Association of Chiefs of Police Member: National Association of State Directors of Law ,
Enforcemeric Training; Past President l Member: Advisory Board - College of Liberal Arts University of Arkansas at Little Rock Member: International Association of Bomb Technicians and Investigators Former Member: International Association of Hospital Security Regional Vice President Former Member: Association of Federal Investigators Educational - Professional Acencies and Institutions Attended:
United States Department of State United States Department of Justice United States Department of Transportation Federal Bureau of Investigation United States Bureau of Prisons United States Army United States Alcohol, Tobacco and Firearms Agency United States Civil Service Commission University of Arkansas University of Arkansas Medical Sciences Campus Texas A & M University University of Georgia University of Michigan University of Indiana University of Cincinnati e College of the Ozarks, Arkansas Industrial College of the Armed Forces, Washington, D.C.
Institute of Municipal Police Administration International Association of Chiefs of Police i Little Rock Police Academy Missouri National Aquadic School l
Education - Formal Central High School Little Rock, Arkansas 1940 - 1942 Little Rock Junior College (Now the University of Arkansas at Little Rock) 1947 - 1948 College of the Ozarks Clarksville, Arkansas 1980 - 1981 Phillips County Community College Helena, Arkansas 1982 - Spring Semester Arkansas State University Jonesboro, Arkansas 1982 - Fall Semester University of Arkansas Little Rock, Arkansas 1984 - Present Criminal Justice Major ,
Other Sionificant Facts and Exoerience
- 1. Assisted in development and implementation of the Little Rock, Arkansas Police Training Division. Served 12 years with the Little Rock Police Department in training capacity, retiring as Captain and Commander of the Little Rock Police Department's Training Division.
- 2. For eight years served at Little Rock Police Department as a bomb technician and officer in charge of identifying, trans-porting and disposing of improvised explosive devices, com-mercial chemical and military explosives.
- 3. As Chief of The Veterans Administration Police Training Center, supervised approximately 500 Veterans Administration police officers in 17 states and Puerto Rico. Developed, implemented and relocated the Veterans Administration National Police Training Center from Washington, D.C. to North Little Rock, Arkansas. The Center provides law enforcement training to Veterans Administration police i officers and investigators from all facilities in the United States and the Commonwealth of Puerto Rico.
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- 4. Served as Project Director for the United States Dopartment of Justice and National Association of State Directors of I Law Enforcement Training in the delivery of National Train-ing Programs in witness assistance training, executive development, child abuse and neglect and general victimology to police officers in all 50 states.
- 5. Currently serving the United States Department of State, Office of Counter Terrorism, as Coordinator and Instructor in VIP security, K-9 operations, SWAT operations and rendering safe improvised explosive devices. The training is provided to foreign law enforcement executives and operational personnel.
- 6. Have been appointed by the United States Department of d
Transportation Safety Institute as an Associate Staff Member in providing counter terrorism training to foreign national law enforcement officers. Provide instruction la hostage situations, personal protection of heads of State and other 4
dignitaries, improvised explosive devices in the areas of airports and ports and harbor security. Developed counter i ambush, counter assassination procedures for Presidential I and Prime Ministers protective units of foreign nations.
. 7. Assisting in coordination and development of exclusionary rule training program sponsored by the Attorney General of the United States. Training will be provided to law enforcement officers of all 50 states.
- 8. Previously employed as Executive Director of the Arkansas Commission on Law Enforcement Standards and Training. In i 1982 was elected to the Executive Board; in 1985 was elected President of the National Association of State Directors of Law Enforcement Standards and Training (NASDLET). NASDLET membership consists of the Executive Director or his
- i. designee from each of the 50 states. The 50 members of l NASDLET have the statutory authority to regulate and control all employment, training and certification or licensing of every sworn State, county and municipal law enforcement officer in the United States.
- 9. Was a member of the United States Police Training delegation that traveled to The Peoples Republic of China in November 1986 for the purpose of participating in a technical exchange with Chinese police officers from the Ministry of Public Security. Was invited to return to China and present courses of instruction at three Ministry of Public Security Universities in Peking, Wuhan and Canton.
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Attachment 6 I
CONTENTION EX 50: FUNDAMENTAL FLAWS IN LILCO'S TRAINING PROGRAM
, Contention EX 50. {The alleaed mistakes related to trainina
!L raised in EX 42 will be dealt with under EX 50; and bases for EX 45 are consolidated with EX 50]. The exercise demonstrated t that LILCO's Plan is fundamentally flawed in that members of t LERO, as well as the personnel of various organizations upon which LILCO relies for implementation of the Plan, are unable to carry out effectively or' accurately the LILCO Plan because of inadequate training.
Under the LILCO Plan, LILCO is responsible for the training cnd retraining of both LILCO and non-LILCO personnel in LERO.
Training began in 1983 and, since that time, has consisted of classroom instruction, tabletop sessions, and drills / exercises.
Plan at 5.1-1 thru 5.2-7 and Figs. 5.1.1, 5.2.1; OPIP 5.1.1.
LILCO requires all.LILCO members of LERO to participate in its 1
training program on an annual basis. Plan at 5.1-1, 5.1-7 and 5.1-8; OPIP 5.1.1. At a minimum, this requires each LILCO worker in LERO, each year, to attend classroom instruction sessions on seven emergency response training modules and to participate in at least one tabletop session / drill / exercise; on average, how-Sver, LILCO personnel are required, each year, to attend class-room instruction sessions on nine modules and to participate in three tabletop sessions / drills / exercises. Plan, Figs. 5.1.1 and 5.2.1; OPIP 5.1.1. Thus, as of the time of the February 13 exer-cise, the bulk of LILCO's LERO personnel had already undergone almost three years of training by LILCO involving, on average, classroom instruction on a total of 27 training modules and participation in nine tabletop sessions / drills / exercises.
The large number of training deficiencies revealed during the exercise collectively demonstrate LILCO's lack of compliance with 10 CFR S 50.47(b)(14) and (15) and NUREG 0654, S II.N and O,
, and violations of LILCO's Plan and procedures (chiefly OPIP 5.1.1), as well as LILCO's overall inability to implement the LILCO Plan and procedures as required by 10 CPR S 50.47(a)(1).
In its April 17, 1985 Partial Initial Decision, the ASLB found
- .that the "LILCO Plan training program meets the regulatory standards," but that conclusion was expressly:
made subject to confirmation by a finding, to be made by FEMA after a graded exercise, that the Plan can be satisfactorily implemented j with the training program submitted and that l
LILCO possesses an adequate number of trained LERO workers.
21 NRC 644, 756. No such findings have been made by FEMA; in fact, as noted below, in its Report FEMA identified a significant number of training deficiencies. The exercise results thus dis-close fundamental flaws in LILCO's training program which pre-clude a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham emer-gency. ,
Every instance of a LILCO training deficiency revealed during the exercise is not described at length in thi.s contention because they are so numerous; virtually every error made by a LILCO player during the exercise involved to some degree a fail-ure of the LILCO training program to prepare personnel adequately to perform necessary actions. Thus, each " deficiency" and each "ARCA" identified by FEMA, plus each additional error committed during the exercise and identified in other contentions, provides a basis for the Governments' allegation that the exercise results demonstrate a fundamental flaw in LILCO's training program.
Because such errors are all identified elsewhere, in the interest of brevity and to avoid needless repetition, in subparts A-I below, the Governments use cross-references to identify specific examples of the training deficiencies which support this contention.1 EX 50.A. The exercise demonstrated that the LILCO program has not successfully or effectively trained or prepared LERO personnel to respond properly, appropriately, or effectively to unanticipated and unrehearsed situations likely to arise in an cmergency. Exercise actions and events which support this alle-gation are described in Contentions EX 38, EX 39, EX 41, and EX 42, and in the following FEMA Comments: EOC-D-1; ENC-D-1; PSA-D-1; PSA-D-6; R-D-2; EOC-ARCAs-2, 3, 9; ENC-ARCA-2; PSA-ARCAs-5, 7, 8, 9, 10, 11.
EX 50.B. The exercise demonstrated that LILCO's training program has been ineffective in instructing LERO personnel to follow and implement the LILCO Plan and LILCO procedures, and in imparting basic knowledge and information essential to the ability to implement such procedures. Exercise actions and .
events which support this allegation are described in Contentions EX 36-39, EX 41, EX 42, EX 45, EX 49, and in the following FEMA conclusions: EOC-D-1; ENC-D-1; R-D-2; PSA-D-6; EOC-ARCAs 2, 5, 6, 7, 9; PJSA-ARCA-1; PSA-ARCAs 3, 4, 7, 8, 9, 12, 13, 14, 15, 16; R-ARCAs 4, 5, 6; RC ARCA 1.
1 References in the subparts to FEMA deficiencies ("D") and ARCAs are to Table 3.1 in the FEMA Report, where the deficiencies and ARCAs are numbered and identified by LILCO facility. Herein the Port Jefferson Staging Area is referred to as "PJSA"; the Riverhead and Patchogue Staging Areas as "RSA" and "PSA"; and the Reception Center as "RC."
EX 50.C. [The alleaed missten described in EX 23 will be considered under this suboart]. The exercise demonstrated that the LILCO training program has not successfully or effectively trained LERO personnel to communicate necessary and sufficient data and information, to inquire'and obtain such information, or ,
to recognize the need to do so. Exercise actions and events which support this allegation are described in Contentions EX 34, '
36, 38, 39, EX 41, EX 42, EX 45, and in the following FEMA con-clusions: EOC-D-1; ENC-D-1; EOC-ARCAs 4, 5, 6, 7, 9; ENC-ARCA 2; 1 PSA-ARCA 8, 9, 11, 12; R-ARCA 1.
EX 23. [Not separatelv admitted but will be considered under suboart C of EX 50]. EOC ARCA 5 refers to a 2.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> delay by LILCO personnel in correcting the error of reporting extrapolated dose data a's actual measurements at other distances.
FEMA Report at 41. This violates OPIP 3.5.2 and, depending upon the particular numbers involved in the error, could result in 1 substantially erroneous dose projections and wholly inappropriate l protective action recommendations. Thus, this deficiency ,
precludes a finding that actual and potential offsite i consequences of an accident are accurately assessed, and that appropriate protective actions can and will be chosen during an accident, as required by 10 CFR SS 50.47(b)(9) and (b)(10). It, therefore, precludes a finding of reasonable assurance that j adequate protective measures can and will be taken in a Shoreham cccident.
EX 50.D. The exercise demonstrated that LILCO's training program has not successfully or effectively trained LERO ,
personnel to follow directions given by superiors during an Emergency. Exercise actions and events which support this allegation are described in Contentions EX 41, EX 42, EX 45 and in the following FEMA conclusions: EOC-D-1; PSA-D-6; PJSA-ARCA 1; PSA-ARCAs 9, 13, 16; R-ARCAs 4, 6; RC-ARCA 1.
EX 50.E. The exercise demonstrated that LILCO's training program has not successfully or effectively trained LERO per-
- sonnel to exercise independent judgment or good judgment, or to use common sense in dealing with situations presented during an smergency or in implementing the LILCO Plan and procedures.
Exercise actions and events which support this allegation are described in Contentions EX 34, 36, 38-43, EX 45 and in the following FEMA conclusions: EOC-D-1; PSA-D-1; RD-2; EOC-ARCAs 2, 3, 9; ENC-ARCA 2; PSA-ARCAs 5, 7, 8, 10, 12; R-ARCA 1.
EX 50.F. The exercise demonstrated that LILCO's training j program has not successfully or effectively trained LERO per- J connel to deal with the media or otherwise provide timely, ac- 1 curate, consistent and nonconflicting information to the public, i
- through the media, during an emergency. Exercise actions and events which support this allegation are described in Contentions EX 37, EX 38, EX 40.C, and EX 43.A and in the following FEMA conclusions: ENC-D-1; ENC-ARCAs 2, 3.
1
.- -- - -_. =_ . _. - . . - .
l
, EX 50.G. The exercise demonstrated that LILCO has failed to provide training to persons and organizations relied upon for the I implementation of its Plan other than those employed by LILCO. l Exercise actions and events which support this allegation are described in Contentions EX 27, EX 28 and in the following FEMA )
conclusions: EOC-ARCAs 11, 12, 13, 14, 15. j EX 50.H. [The alleaed errors described in EX 27 and 28 will be dealt with under this suboart]. The exercise demonstrated that LERO training is deficient in the area of dosimetry, exposure control, KI, understanding of radiation terminology, and related areas. Such training deficiencies are very serious because members of the public and non-LILCO personnel relied upon l to respond to a Shoreham accident (for example, school officials, cpecial facility personnel, and other individuals who are sxpected by LILCO to respond on an ad hgg basis) would seek information on such subjects from LERO personnel during a real smergency. Since LERO personnel do not understand and know how to use dosimetry equipment and the related procedures, they would be incapable of responding accurately or effectively concerning those subjects to members of the public, or other workers ex-pected to respond. The following exercise actions and events are 4 examples of dosimetry-related training deficiencies: Contentions i EX 42, EX 45, FEMA Conclusions EOC-ARCAs 11, 12, 13, 14, 15; PJSA-ARCA 1; PSA-ARCAs 12, 13, 14, 15, 16; RSA-ARCAs 4, 5, 6.
EX 27. [Not seoarately admitted but will be dealt with under suboart H of EX 50]. EOC FIELD ARCAS 1, 3 and 5 refer to the fact that school bus drivers have had no training in dosime-try, use of potassium iodide or excess exposure authorization procedures and that LILCO has not provided dosimetry or supplies of KI for them. FEMA Report at 45-46. According to the LILCO Plan, school bus drivers are relied upon for implementation of 4 the protective actions of early dismissal and evacuation of school children in the EPZ. OPIP 3.6.5. Thus, these deficien-cies preclude a finding that protective actions for school chil-dren can and will be implemented as required by 10 CFR S 50.47(b)(10), that means are in place for controlling radio-logical exposure of emergency workers as required by 10 CFR
, 5 50.47(b)(11), or that radiological emergency response training has been provided to those called upon to assist in an emergency, as required by 10 CFR $ 50.47(b)(15). They also preclude a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham accident.
EX 28. [Not seoaratelv admitted but will be dealt with under suboart H of EX 50]. EOC FIELD ARCA 4 refe,rs to the fact that ambulette drivers are not all trained in excessive exposure cuthorization and procedures. FEMA Report at 46. According to the LILCO Plan, ambulette drivers are relied upon for implementa-tion of the protective action of evacuation for special facility residents and the homebound. OPIP 3.6.5. Thus, this deficiency precludes a finding that protective actions for special facility residents and the homebound can and will be implemented as re-quired by 10 CFR S 50.47(b)(10), that means are in place for con-
. trolling radiological exposure of emergency workers as required by 10 CFR S 50.47(b)(ll), or that radiological emergency response training has been provided to those called upon to assist in an cmergency, as required by 10 CFR S 50.47(b)(15). The deficiency also precludes a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham accident.
EX 50.I. The exercise demonstrated that LILCO's proposals to modify training materials or procedures to " emphasize" such things as " accurate use of field data," the need "to relay instructions," "the need to be more precise with information," or other matters already in'the procedures and training materials
- (agg letter dated June 20, 1986, from John Leonard to Harold Denton (SNRC-1269), Encl. 1) -- training materials and procedures which have been so unsuccessful for three years -- would not correct-the flaws revealed by the exercise.
EX 45.A. LILCO's response to the two free play impediment messages involved numerous serious communications failures which played a major role in LILCO's inability to remove the simulated impediments as provided in the Plan, and as would be necessary to implement an evacuation. In addition, the types of actions which, as described below, LERO personnel failed to take in response to the impediment messages are similar to those that would be required under the LILCO Plan in response to many other situations which would occur in substantial numbers during a real
, cmergency. Therefore, these failures are significant and d
preclude the reasonable assurance finding required by 10 CFR
- 5 50.47(a)(1). Specifically
(i) The Evacuation Coordinator, who is responsible for coordinating all evacuation traffic control, evacuation transportation, and evacuation implementation (OPIP 2.1.1) was never informed by LERO personnel of either of the free play impediment messages, contrary to OPIP 3.6.3 which requires such communication. The Evacuation Route Coordinator was given the fuel truck impediment message at 11:00 and the gravel truck impediment message at 10:40. The Evacuation Coordinator was not informed of either one, however, until after 12:13, when he was informed by the FEMA controller. Egg FEMA Report at 36. The late notification of the Evacuation Coordinator, as well as the lack of status updates and other necessary communications between and among the Evacuation Route Coordinator, the Traffic Control Coordinator, the Road Logistics Coordinator, the Transportation Support Coordinator, Lead Traffic Guides, Road Crews, Evacuation I
Route Spotters, and Evacuation Support Communicators, as required by OPIP 3.6.3, led to the substantial delays and ultimate inability to respond adequately to the impediments. In fact, the delays caused by such failures would have been even greater in an Ectual emergency, since in the exercise LERO never even discovered its errors; rather, it was the FEMA controller who alerted LERO to the problem LERO itself had created.
(ii) LERO personnel at the EOC failed to include casential information communicated to them via the free play impediment messages on LERO message forms, nor did they otherwise communicate such critical data to the other LERO personnel expected to respond to the impediments, as required by OPIP 3.6.3 and OPIP 4.1.2. Sag FEMA Report at 30. For example, important information was not included on the 10:45 LERO message from the Evacuation Route Coordinator to the Evacuation Support Communicator for Route Spotters / Road Crews regarding the gravel truck impediment,. including the fact that three passenger cars were involved in the accident. Similarly, essential information was not included on the 11:06 LERO message from the Evacuation Route Coordinator to the Route Spotter / Road Crew Communicator regarding the fuel truck impediment, including that fuel was leaking, that there_was the possibility of fire, and that both shoulders of the road were blocked. Egg FEMA Report at 30.
Because of these failures, the equipment eventually sent to respond to the gravel truck impediment was inappropriate and inadequate to remove the simulated obstruction, and the equipment sventually sent to respond to the fuel truck impediment was so
- substantially delayed that LILCO's response was not observed by FEMA. FEMA Report at 37, 39, 57-58.
(iii) The Evacuation Coordinator and other LERO personnel were not properly informed concerning a " visual check" of the fuel truck impediment received by the Transportation Support Coordinator from the Bus Dispatcher at the Patchogue Staging Area, and appropriate actions therefore were not taken in response, contrary to OPIP 3.6.3 and OPIP 4.1.2, until more than three hours after the free play message had been injected. Egg FEMA Report at 30, 57.
(iv) LERO personnel were unable to locate, communicate with, or timely dispatch a Route Spotter to investigate and verify the fuel truck impediment. They were also unable to determine whether one had actually been dispatched. Thus, at about 11:15, the Route Spotter / Road Crew Communicator requested the Port Jefferson Evacuation Support Communicator to determine whether a Route Spotter had been dispatched as required under the Plan, and as apparently assumed by the LERO players. The spotter was not in fact dispatched until about 12:02. Sag FEMA Report at 37.
(v) Although the FEMA controller had informed LERO personnel of their initial errors in dealing with the gravel and fuel truck impediments at about 12:13, and despite the fact that the Evacuation Coordinator had discussed the situation with some of his staff at about 12:16, as of 12:40, the Transportation Support Coordinator still had not been informed that bus
svacuation route M-1 was potentially blocked by the gravel truck, contrary to OPIP 3.6.3. And, as late as 1:48, the Road Logistics Coordinator had not been informed that there might be a need to cend equipment to the site of the fuel truck impediment. Sag FEMA Report at 36. Thus, the initial errors, omissions, and failures to follow procedures and accurately transmit information were compounded by additional errors even after the first errors had been identified for LERO by FEMA. These later errors further illustrate the significance of LERO's inability to obtain and transmit essential information, since they had demonstrable impact on other aspects of the overall emergency response.
I (vi) As a result of the numerous failures and delays in internal LERO communications, information concerning the road impediments and the need~to avoid the blocked evacuation routes was not communicated to the public until 1:46 when EBS message 4
number 8 was simulated. This further demonstrates the impact of LERO's communications failures upon its ability to implement its Plan.
EX 45.B. The response of LERO personnel to the Ridge Elementary School free play message also demonstrates LILCO's
! inability to communicate essential information to appropriate response personnel in a timely manner, as required by OPIP 3.6.5.
The free play message requesting LERO to provide a bus and driver to assist in transporting 40 children from Ridge Elementary School was given to the Evacuation Coordinator at the LERO EOC at approximately 10:30. The request was communicated to the Special Population Bus Dispatcher at the Patchogue Staging Area within about 10 minutes, but in violation of OPIP 3.6.5, the staging area personnel did not respond appropriately or quickly in processing the communication. As a result, the bus driver was not even dispatched to a bus yard to pick up a bus for 40 minutes. Egg FEMA R7 port at 38, 66. Furthermore, there were no apparent efforts by LSRO personnel to follow up on their dispatch orders during the approximately three hour period prior to the report that the driver had arrived at the school. Finally, LERO's inability to contact, communicate with, or even locate the l LERO bus driver, when as of 4:23 he had still not arrived at the Reception Center, further demonstrates LILCO's inability to j obtain or follow up on the absence of information critical to the
- implementation of a required protective action.
EX 45.C. LERO was unable to notify or communicate emergency information to the FAA or the LIRR, despite the provisions in OPIP 3.6.3 requiring notification of the FAA in order to have air traffic diverted from the EPZ, and the obvious need to have the LIRR divert its. trains from the EPZ. The failure of LERO l
personnel to perform these tasks evidences their inability to appropriately process, act upon, and communicate emergency information. Egg FEMA Report at 29.
l
EX 45.D. Communications relating to release data and dose projections were not handled properly or accurately as required by OPIP 3.6.1. For' example, LERO personnel failed to designate clearly on the EOC dose assessment status boards the distinctions between DOE RAP monitoring data and LILCO field monitoring data.
Egg FEMA Report at 29-30. This failure demonstrates not only an inability to effectively ccmmunicate important dose information and potentially significant distinctions between the information from the two sources, but also an inability to recognize the '
i significance of that distinction, contrary to the requirements of OPIP 3.6.1. Similarly, downwind distances of sample readings by field monitors were, incorrectly reported as 7000 meters instead of 700 meters for a thyroid dose. This error resulted in an initial calculation of thyroid dose as 900 mrem /hr at 4.3 miles downwind, instead of 9000 mrem /hr at about 0.5 miles downwind.
Egg FEMA Report at 33. And, at the EOC, several extrapolated doses at various distances were reported as actual measurements rather than as projected data on the dose assessment status board. It took two and one half hours to identify and correct this error. Egg FEMA Report at 33. These failures indicate a significant inattention to detail and accuracy in recording, processing, and communication of data critical to the accident assessment and protective action recommendation processes which are at the core of an emergency response. Such failures could lead to dangerous errors in a real emergency.
EX 45.E. During the exercise, the LERO Director apparently left the " command room" on several occasions, and therefore was not available to take calls over the RECS telephone or the dedicated telephone. Since, pursuant to OPIP 3.1.1 and OPIP 3.3.1, data and information critical to command decisions are communicated by these means, his absence and resulting inability to obtain and act upon such data quickly was significant.
Moreover, the secretary who took the calls in the Director's absence merely told the callers that the Director would call back, and failed to take a message in writing and carry it to the Director immediately upon completion of the transmission. Final-ly, LERO failed to have key events or evacuation status boards in the EOC command room. Thus, updated information on the status of
' the emergency situation was not visible to LERO workers in those
, areas at all times. Egg FEMA Report at 30. These failures to obtain or communicate vital data, and to have updated information available and visible in the command room substantially impair
! the ability of command personnel to perform their duties under the Plan.
EX 45.F. There were numerous failures to obtain, process, communicate and appropriately act upon important emergency information and data demonstrated by the performance of LERO ENC, Public Information and Rumor Control personnel, in violation of OPIP 3.8.1. These are detailed in Contentions EX 38 and EX 39.
The fact that such personnel exhibited such communication
4 inaoilities is particularly significant since such individuals were purportedly selected for their LERO positions because of their communications expertise.
EX 45.G. LERO personnel at the staging areas evidenced an inability to accurately, appropriately or in a timely manner obtain, record, transmit, or act upon emergency data, in viola-
< tion of OPIPs 4.1.2, 3.6.3, 3.6.4, 3.6.5, and OPIP 3.9.1. For example:
(i) Personnel at the Riverhead Staging Area did not j properly record or appropriately identify event status informa-l tion on Emergency Event Status Forms or on status boards. Egg FEMA Report at 72.
(ii) Communication between the Port Jefferson Staging Area and Traffic Guides was difficult due to poor radio recep-tion, and disrupted other essential communications from that Staging Area. Sag FEMA Report at 56. Such difficulties would be much more serious in an actual emergency when many more traffic guides would be attempting to make radio communications with the staging areas involved.
(iii) The Bus Dispatcher at the Patchogue Staging Area repeatedly made inaccurate and misleading announcements to bus drivers concerning the dose levels at which they were to call in.
These incorrect instructions concerning such important informa-tion in fact led to confusion on the part of the bus drivers, and could be very dangerous in a real emergency. Egg FEMA Report at 68.
(iv) The Transfer Point Coordinator at the Brookhaven National Laboratory Transfer Point was unable to follow instruc-tions and transmit information and directions from the staging area to bus drivers during the exercise. For example, he di-rected a bus driver to the EWDF despite the fact that a message from the Bus Dispatcher to all Transfer Point Coordinators had directed that all drivers arriving at transfer points before 4:00 should be directed to the Nassau Coliseum Reception Center. Egg FEMA Report at 65.
EX 45.H. LERO personnel at the EOC and staging areas were unable to transmit consistent or accurate information concerning casistance from the Suffolk County Police Department ("SCPD")
during the exercise. For example, at 9:19, the LERO Manager was told by simulators purportedly representing Suffolk County i officials that no County resources would be available to assist LILCO during the exercise. This fact was confirmed by the County simulators at 10:15, 10:26 and 10:36, according to the logs kept by the LERO Manager and Director. However, at 9:20 the Evacua-a tion Coordinator recorded in his log that the SCPD had offered to j provide LILCO whatever assistance was required, and the Traffic Control Coordinator was advised of this purported information at
9:35. At 10:02, the Evacuation Coordinator notified the staging creas that the SCPD had offered assistance on traffic control, route alerting, and route spotting, and that police officers would be dispatched to the staging areas for briefings. And, between 10:02 and 10:15, the Traffic Control Coordinator informed (i) the Riverhead Staging Area to expect 39 SCPD officers to report for assignment to traffic control and route spotting functions; (ii) the Port Jefferson Staging Area to expect 74 SCPD officers and; (iii) the Patchogue Staging Area to expect 37 SCPD officers. These messages, all of which conflicted with the facts known and recorded by the LERO Manager and Director, were in turn transmitted to Lead Traffic Guides, Dosimetry Recordkeepers, and other staging area personnel. The erroneous information which had been communicated to the staging areas was not corrected until approximately 10:50. In a real emergency, such a total failure of communication could lead to serious problems.
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M Renert M { g b 118G M L33Q Faelities - E yd{g ggg Riverheac. Stacinc h ("Jartial) anckaround A drill was held on June 6, 1986 to exercise portions of LERO. Those portions that were exercised on this date were the EOC, the EUC and the Riverhead Staging Area !!anagement staff, cdministrative support staff, dosimetry staff and the traffic guides. All other groups within the LERO were simulated. Shift 2 wcs the team that participated.
Emergency Preparedness Drill Scenario 8A Rev. 0 (attachment
- 1) was used. This scenario was essentially the same as was used i during the FEMA graded exercise on February 13, 1995 uith the following major exceptions:
o The length of the drill was shortened from 12 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />; o The start time was changed from 5:30 A'1 to 8:00 AH; o The length of time between the events for the Unusual Event and the Alert was shortened; o The LERO staff was prestaged at their respective facilities rather than being called out.
o Proposed Revision 7 to the LERO plan and procedures were testad; in particular the assignment of traffic guides for the 2 - mile evacuation, and the neu position of Traffic Engineer.
As a result of the FEMA evaluation of the February 13 cxercise the following specific additional objectives and tests wore added to the scenario:
I o Two impediments to evacuation were simulated to test the communications within L3RO and LERO's response to the impediment; namely rerouting of traffic and public notification of the impediment; o The pat formance of traffic guides dispatched out of the Riverhead Staging Area was specifically loo l:ad at; namely all traffic guides stationed for a 2 - mile evacuation and the majority of the remainder, were verified to be on station; o Use of the Traffic Engineer as a new position within the LEno was exercised:
225 BROAD Hou.OW ROAD + MELVILLL NEW YORK 11747*(516)420 320o L765720 l
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o Demonstrate adequate reproduction cababilities (E"c) throughout the duration of the exercise.
scenario Obiectivest Attachad M Observer / Controller Comments t Emercancy Onerations Center (EOC)
- 1. set-up of the facility was adequate. The EOC was declared activated 49 minutes after the participants were told to report.
- 2. The notification for early dismissal of the schools It took 40 within the EP2 was not done efficiently.following minutes to issue an E3S message the declaration of the Alert. Eventhough' the EOC was not declared activated, the Director and the Public Information Coordinator could have expedited this process.
- 3. A simulator was used to simulate the presence of Suffolk County. He was not to assume command and control of'the EOC, be but rather to offer any assistance to L2RO which might asked for, and which might be available from the County. The simulator provad to be a slight distraction .to the Director of Local Response. EOC management personnel must be cognizant of outside parties in the EOC but should not lose sight of their prime responsibility unless that function is assumed by that outside party. ,
- 4. The preparation of ESS messages took too long. The Public Information Coordinator was getting persons involved in minute details of the message i.e., which were consulted by the Diractor. This caused- several of the messages to miss the 15 minute deadline.
- 5. The E3S message for the General Emergency took 25 minutes to issue following the decision to initiate protective actions. This was due to the reasons stated above.
Personnel, particularly the Director and the Public Information Coordinator, must be aware of the 15 minute time limit with regards to the issuance of EDS massage's.
- 6. It took between 10 to 15 minutes to get the word out to the Staging Areas about the evacuation. Personnel in the EOC responsible for passing this word out are relying too much on the use of written message forms and the EOC Communicator. The use of the commercial phones on the IMPR @
[765721
individunio dccho should bo cmphasized as a mecns of ccumunicating to the staging Arons and than folloucd up with tho written message.
scraps of
- 7. Written messages were frequently written on
- 93per and then transcribed onto the standard message form.
supply of Often, no transcription took place. Uhen the i
message forms was depleted in the EOC, messages were not written down at all.
very
- 8. Updating of the status boards in the EOC was not the a timely. At times entries were 30 to 45 minutes behind cctual events.
Public Information staff did inform the EUC of the
- 9. The prcsonce of the suffolk County Simulator. However they did as not inform them that had relieved Director. ,
- 10. There was a communications problem between the dose accessment staffs in the EOC and EOF. The problem was one of a lack of cooperation between the two organizations. This is an area to be emphasized during future training sessions.
- 11. The EOC staff must talk to the TSC when the EOF is not staffed. Delays were encountered in the EOC because the EOF ready to assume command and control while the was ECC was not staff was. (This was due to the way that the EOC easier, prestaged) . In order to make contact with the TSCshould be tolephone numbers of key individuals in the TSC placed in the LERO phone directory. Telephone numbers of the Control Room would also be helpful. The LO20 staff must bo reminded that contact should only be with the facility which has command and control.
to assist the dose assessment staff in dose
- 12. In order Weather Service projections, the telephone number for Corporation should be included in the LERO phone book.
the
- 13. No comparison between the DOE field team data and SUPS field team data was observed to be made by the R3C.
- 14. There is .a difference between the RECS forms used by the en site organization and the one in the OPIP's. This caused a lot of confusion especially in transmittal of the Partthe III data.- This will be corrected in a future revision to r
plan and procedures.
- 15. The nuclear Engineer did a good job of assessing plant ccnditions and conveying to the Director the various ,
passibilities of core failure and release paths.
Ih1PE14@
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( :
- 15. The special Facilities Evacuatio that the one-hour delay in the startn Coordinator of the thought process from the time the word is conveyed to evacuation the public cyplies to all LERO assisted evacuation processes. He wanted !
to wait the order one hour to evacuate. to evacuate the mobility impaired following , '
All persons should be reminded throughleaving buses trainingthe that the one-hour delay only applies to the '
i transfer points for general public evacuation. ,
t
- 17. The Special Facilities Evacuation Coordinator delayed in i proceeding with the deaf notification process until he had a
! copy of the EBS message for the evacuation. The only reason he needed the EBS message was for the zones to be evacuated.
This namely information the status was readily available from other sources, board'which w desk. This delay was unnessary,as directly in front of his i
i 18. The ambulance group did a fine job in dispatching of the 1 simulated ambulances and in briefing the simulated ambulance drivers. -
- 19. The bus coordinator did a very was her first time in this position. good job considering it
- 20. The Traffic Control Coordinator delayed in traffic guides out after the word to evacuate was given.getting It tcok staging approximately 40 minutes to transmit the message to the
. Area from the time the General Emergency conditio'n w s known in the EOC.
EZih This is a special objective item.
- 21. The truck) gravel handling of the first impediment to evacuation ( the cxpeditious was generally done in a well organized and i manner. The second road impediment (the truck) was confused and the response was delayed. Specific fuel ctaments on these two impediments are listed below:
N0?ft These are special objective items.
o The Transportation Support Coordinator should have done a better job of keeping control and managing his group during was the road impediment scenarios. No one individual assigned to be in charge of handling impediments. these Because practically all groups in the ECC need that one individu to be made aware of such a problem it is important al be responsibis for this effort. coordinating o The RBC was not made aware evacuation of the impodiment to until 2:15 PM; I hour and 30 minutes after L.755723
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C
- I
. . 1
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tha event had occurred.
Ess messago telling of the road impediment .vas o The event issued at 1:29 P:Ir almost 45 minutes after the had occurred. In addition this important piece of nassage ,
information uas incluSad with tha catira T33public. A and might hava basa missal by the general special EBS message should have been issued. l
)
The message for the second road impediment was called l o i into the Eoc and was properly logged on a message form, however when the information was relayed to the field, the wrong road was mentioned; Route 25-A vs. Route 25. simulating a l
The word came back from the controller, route spotter, that there was no impediment at the location indicated. At'that time it was assumed that had been the impediment was either a false alarm or It was not cleared, and no follow up action was taken.
until the controller in the EOC prompted the players to review the original message that any
- three times action was takan.
for
- 22. The position of the Traffic Engineer was utilized the first time. Their exact responsibilities was not very too involved in clear in their own minds. They became traffic engineering details, i.e. extent ofrather the crown on the than quickly road and its effect on traffic flow, cdvising the Evacuation group of alternate evacuation routes and their effect on evacuation time estimatas.
EG
- 1. The dedicated telaphone line between the Eoc andtelephone 2nc was not available for the drill. Backup commercial Repairs to the dodicated lines were used satisfactorily.
line have subsequently baan made.
- 2. Of the two copier machines in the EUC, one failed during the drill. The repair technician was called twice and shoved up two hours later. As a result of this problem, press releases were not distributed in a timely manner. The total 1429 and 501 copies made by the two machines were the respectively. The Emergency Progratedness Group is in process of obtaining new reproduction equipment.
- MOTT This is a special objective item.
stacina & ggg i
- 1. The lead traffic guide in Riverhead gave 4 c1sar and thorough briefing to the traffic guides. .
I <
lh1PE@
-, . - - , - _ - . - - - - - - . , - - - - - , _ _ - . - . ~ . , _ , , . _ , , , .-...-.. - , ,-,.,_ _ _ ._ _,_ , _ .,.,_c - --,- ,-. - - .. _ _ _ _ _ --
4
- ,. ) .
- 2. Tho Trcffic Guidos woro dispatch 0d opproximately 13 minutes after the message to do so was transmitted from the Eoc. This is an adequate time frame.
- 3. The Patchogue communicator in the EOC did not transmit the message to dispatch buses until prompted by the controller in Patchoguer 1-1/2 hours after the massage was given to him by the bus coordinator.
- 4. When issuing revised or amended evacuation instructions to the Staging Areas, entirely new forms should be filled out and transmitted. The Patchogue Staging Area received a modified form for bus dispatching and this created a lot of confusion in the staging area.
- 5. of those Traffic Guides questioned, all were very familiar with their traffic guide duties. Several however were still not clear on the procedure regarding reaching certain exposures, i.e. 3.5 Rem and 5 Rom. This will continue to be stressed in future training sessions.
Summa m This is the first LERO drill held since the February 13 exercise and the first drill with shift 2 since the Fall nany of the participants. were new to LERO and unfamiliar with their procedures and job functions. Several new concepts were also oxercised for the first time. Overall response by the participants can be classified as poor, however due to the natura of the drill and the participants, this was not totally unexpected.
During the post drill critique, emphasis was placed upon rapid and accurate communications flow within the EOC and to cutside facilities, i.e. Staging Areas, Etic and the general public. This is especially true during an evacuation when the ovacuation process is impeded and a radioactive release is imminent or in progress.
This is the first time since the exercise that a traffic impediment was simulated during a drill. The response to the two impediments was generally good for the first ona and somewhat poorer for the second one. The response by the public information group in getting the information out to the general public was not as rapid as it should have been. Information flow to other groups within the ECC, i.e. the Radiological group was almost non-existent. .
LERIO will continue to emphasize the response 'to traffic impediments in all future drills and training sessions.
O 765725
4 ATTACHMENT 8
+ .
O L LP E L LM October 31, 1986 0630-031-NY-017 TO:
FROM:
SUBJECT:
Drill geoort f,gg, Seotember lQ,,, Seotember 17. And October 1, 1215 fgI,LEEQ Backaround; ,
As part of the quarterly Emergency Preparedness drill pregram, drills were held on September 10, September 17 and October 1, 1986 to test the response of the Local Emergency Racponse Organization's (LERO) to a simulated emergency at the Shereham Nuclear Power Station (SNPS) . The purpose of the drills wac to exercise LERO's ability to implement the Offsite Radiological Emergency Response Plan Implementing Procedures (OPIP's) and to train new personnel to improve their ability to rocpond to an emergency, make appropriate recommendations to the public and implement those recommendations. All sections of LERO participated in the drills with the exception of the Emergency N;ws Center on September 17, LERO Relocation Center and Family Trccking on September 10. The facilities which did participate included the Local Emergency Operations Center (EOC), the Emsegency Worker Decontamination Facility (EWDF), Patchogue Sttging Area (PSA), Port Jefferson Staging Area (PJSA) and Riverhead Staging Area (RSA) . Due to the revisions being made in tha plan, the Relocation Center was not tested at all. Only 1/3 ef the field personnel were exercised during each of the three drills. All field workers performed their normal emergency duties with the exception of the bus drivers who were involved in a
, cpecial training session to familiarize them with all bus yards I
cnd transfer points.
Emergency Preparedness Drill Scenario 7A Revision 0 (objectives attached) was used for all three drills. Shift 3 participated on September 10 and 17, and Shift 2 participated on October 1. Shift 3 had not drilled as a team since late in 1985, and Shift 2 was last drilled in June 1986. The purpose of
( drilling Shift 3 on two consecutive weeks was to allow the participants to use the first week as a learning process, and to cllow the new members of the organization to become familiar with i
their new positions; and the second week would be conducted as a l core normal " hands off" drill.
All LERO members were pre-staged, i.e. told to report to th31r work locations at preassigned time, rather than exercise tha normal notification and call out procedures. To vary the cccnario seen by Shift 3 personnel the EOC staff was told to scport at 9:30 AM on September 17, rather than 8:00 AM. In 225 BROAD HOU.OW ROAD = MEl.VILLE NEW YORK 11747 -(516) 420 32M 765726
2 ; )
were cddition the type and location of the traffic impediments
~
changed for the September 17 drill. Response Revision 7 to the Offsite Radiological Emergency and Plcn and Procedures was in effect at the Specific time of the drills objectives to cll persons were tested to that revision.
d :nstrate the response to this revision were as follows:
O Demonstrate the ability to assess the effect of roadand develop impediments upon evacuation traffic These and actions may implement timely response actions. associated include rerouting and the broadcast of an EBS message, as necessary.
o Demonstrate the ability to pre-assign Traffic Guides an to to Traffic Control Posts within the two mile EPZ dispatch'the Traffic Guides in an expeditious manner at the appropriate t'ime.
o Continue the bus driver training to ensure bus drivers are familiar with all bus yards and transfer points.
o Reinforce the concepts of dosimetry and KI.
Scenario obiectives:
Attached .
a summary of the major comments generated by the Bolow is Obccrver/Conrollers during the series of drills.
september las 11&E Eneraency onerations Center of
- 1. The EOC was staffed and activated within This 45 minutes is a very the time the players were told to report. set good response. All personnel were actively helping to up the facility.
- 2. The Coordinator of Public Information was participating in his first drill, as were many of the people on his staff.
As such the controller assigned to that area was forced to players through their procedures. The walk the EBS messages for the traffic impediments were slow in being generated. The wording was ambiguous and not concise.
One EBS message out of approximately 7 was broadcast 3.
without the sounding of the sirens. Better coordination is needed between the Director of Local Response and the Coordinator of Public Information.
- 4. Several communications problems occurred during the day but were attended to and were repairud; the TSO in the public information area, the dedicated line between the EOC and PJSA and the radios ot PSA and PJSA. The staff was able ,
k 5:
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to make use of the backup systems available.
- 5. The Radiation Health Coordinator (RHC) ordered the ingestion of KI prior to performing the calculations '
necessary for the technical justification. This omission was pointed out at the post drill critique.
- 6. Security was not observed to perform accountability checks of the EOC and a sweep of the facility to check for improper or non-existant identifications. What security did do was have each person sign out as they left the facility and sign back in as they returned, however this procedure was not strictly adhered to.
- 7. The dose assessment staff in the EOC had difficulties in obtaining data from the dos'e assessment staff in the EOF.
Only one (1) Part II RECS message was recieved during the drill. In addition, the lines of communication for technical data was almost non-existant. This matter was brought to the attention of the Emergency Preparedness group and will be an item for furthur discussion and training.
- 8. Response to the traffic impediments was generally good.
The Traffic Engineer was instrumental in developing rerouting schemes and there was good lines of communication among all groups in the EOC relative to the problems.
- 9. There was approximately a 1/2 hour delay at the Road Crew Comunicator's desk in getting the message transmitted to respond to one of the road impediments. It was stressed
. during the critique the importance of transmitting messages in a timely manner.
- 10. The use of message forms needs to be improved. It was observed that many people are using scraps of paper to transmit messages and therefore the appropriate copies are not being distributed, or that messages are being written on scraps of paper and then being incorrectly transcribed on the message forms.
Emergency Worker Decontamination Facility
- 1. The normal Brentwood Security was not prepared for the arrival of the emergency workers from the field and the workers were given different directions upon the'ir arrival at Brentwood. In addition, the direction given the workers at the staging areas, was not correct and the workers did not report to the correct gate. The Emergency Preparedness group is aware of the problems and has ensured that Brentwood will be aware of the arrival of the emergency workers in future drills, and has revised the maps from the kb
. 765728
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' 'i i staging areas to the to the EWDF.
- 2. The personnel. reporting to establish the EUDF were not familiar with their jobs, and took no action until prompted by the controller.
- 3. The personnel.were unfamiliar with the location of the storage rooms for EWDF equipment. The equipment checklist was not used per the procedure. The correct setup of the g facility was demonstrated by the controller. ,
- 4. No check sources were available testing the survey instruments; several of the instruments had more than one calibration sticker with conflicting 'information; one instrument's cable and detec. tor failed due to a shorts two instruments went into continuous alarm; one instrument was completely dead. All equipment problems and shortages were brought to the attention of the Emergency Preparedness group and have been corrected.
Patchoaue S.t,gging &ggg
- 1. Due to the lack of experience of the participants, the set up of the facility was slow and undirected. No priority was given to the activation activities. The establishment of security and issuing of badges was also slow. These issues were discussed during the post drill critique.
- 2. Briefings conducted by staging area management'were not very frequent. This led to a lack of information regarding
.the emergency withing the staging area. The need to periodically conduct staff meeting and the need to keep the emergency workers informed of the status of the emergency was emphasized at the critique.
- 3. Due to the problem mentioned earlier concerning communications, personnel dispatched into the field were provided telephone numbers during the briefings. This showed good foresight on the part of the Lead Traffic Guide.
- 4. The dispatch of the Traffic Guides from the Staging Area was done in an efficient and timely manner. The Traffic Guides necessary for the two mile evacuation were preassigned and were issued their equipment. Upo.n the order to evacuate, they were dispatched and the average time to arrive at their posts was approximately 30 minutes.
- 5. In all cases the Traffic Guides who were questioned were knowledgeable in their individual tasks relative to traffic guidance, however of the 9 Traffic Guides questioned most of
. them were not aware of the maximum allowable dose, and the IMEll318 765T29
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.1
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proper procedures governing the use of KI. This will continue to be stressed in all future training.
- 6. The performance of the emergency field workers relative They to the traffic impedia'nt e was satisfactory.
communicated the situation properly to the Staging Area and responded well to the direction of the Staging Area.
Egzi Jefferson Stacing &gga Jefferson,
- 1. Due to a turbine maintenance outage at. Port drill. As a the turbine floor was not available for the accomodate result temporary arrangements had to be made to the large number of participants. A tent was erected compounded outside the the Staging Area. This additional problem the lack of experience of the drill team and as a result Controllers provided direction to the participants.
This October 1 situation e'xisted during the September 17 and a
drills.
were
- 2. The Traffic Guides for the two-mile evacuation preassigned and were standing by prior to the evacuation the order. Once the message to evacuate was recieved from
~
EOC, they were dispatched within minutes.
- 3. The response to the traffic impediment at Traffic Control from j Post #45 was very slow. There were repeated requests road crew. The the Traffic Guide as to the status of the Road Crew never did arrive.
l Riverhead Stacina &ggg
- 1. Similar to the other Stgaing Areas, the personnel at l
slow to activate the faci!aQ. The Riverhead were l
! controllers had to prompt and train the personnel varing the -
drill as to their duties.
announcements were made during the day, l 2. Several 'P.A.
however no staff briefings were conducted by the Staging Area Coordinator. It was pointed out during the critique that it is important to keep key coordinators apprised of emergency conditions on a regular basis.
- 3. The packets for the deaf notifications were missing from Riverhead and as a result this portion of the drill was not able to be demonstrated. This wa: pointed out to the Emergency Preparedness group and has been corrected.
- 4. The dispatch of the Route Spotters was delayed because the message from the EOC took 20 minutes to go from The the ,
Administrative Support Staff to the Lead Traffic Guide.
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' 765730
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importance of prompt handling of messages was stressed at the post drill critique.
- 5. Thel Road Crews which were dispatched from Riverhead arrived at their locations in a timely manner. They had a good general knowledge of road-clearing procedures, and maintained good communications with the EOC and other road crews.
- 6. Two Road Crews questioned were not aware of the proper procedures regarding the use of dosimetry and maximum exposure allowances. They were also not properly informed to l
take their KI tablets.
september lla 1111 .
Emergency Deerations Center
- 1. The participants were prestaged so that notifiation was not demonstrated. The setup and activation of the facility from the time the participants were told to arrive was approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The activation of the facility was orderly and well coordinated.
- 2. The Command and Control of the EOC was handled well by the Director and the Manager.
- 3. The Coordinator of Public Information did a very good job in working with the Director in issuing EBS messages. The CPI anticipated well and there was no deJay in issuing the messages.
- 4. The EBS message which was issued for the traffic impediment gave too specific information relative to the new . traffic directions and rerouting. The messages should have been more general and should only have instructed the t evacuees to follow the directions of the Traffic Guides.
This was pointed out at the post drill critique.
- 5. The Radiation Health Coordinator did an excellent job in performing dose projections and assisting the Director in making the proper protective action recommendations. The l
I posting of the DOE / RAP team field data was a little slow and this was pointed out to the RHC. .
- 6. The overall response to the traffic impediment was good.
Improvement could be made in generating the rerouting information and arriving at new evacuation time estimates.
- 7. Information flow from the Staging Area to the EOC needs improvement. At times messages were left on the WlP,E_LL@
l communicatoro desk for 10 to 15 minutes before it was transmitted to the proper individual in the EOC. In addition the flow from the EOC to the Staging Area could also be improved. The message indicating that an Alert had been declated was sent at 1038. The announcement was made at 1014.
- 8. At times when the key coordinators were at staff meetings, their phones would go unanswered. It was pointed out at the critique that all phones should be monitored and answered if the person is not at his desk.
- 9. The Special Facilities group performed well in carrying out their duties. All procedures were followed.
Emercency Worker Decontamination Pacility
- 1. The set up of the EWDF was done in an efficient manner and quickly. The Decon. Leaders took charge of the personnel arriving and began assigning tasks. The status of the emergency was known to the staff by periodic briefings.
- 2. Several pieces of equipment had conflicting calibration stickers on them. This was pointed out to the Emergency Preparedness group for resolution.
- 3. There were several pieces of faulty equipment which were not recognized by the participants and were used to monitor the emergency workers. The equipment problem was pointed out the Emergency Preparedness group and the error in not checking the equipment properly was pointed out to the participants at the post dri14 critique.
Patchocue Stacina Ar,gg
- 1. In general, command and control of the facility was very good. The Staging Area Coordinator made good use of the personnel available to him.
- 2. The documentation of messages in the Staging Area was not .
done on the standard message form. Many messages were being writter on blank pieces of paper and then later transcribed on the message form. This caused delays in delivering the message to the appropriate party and caused transcription errors and erroneous information being transmitted. The proper use of the approved message forms was reiterated at the post drill critique.
- 3. The preassigning of Traffic Guides for the two mile evacuation was done in a timely manner.
IN1PJQ:()
765732
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- 4. The Traffic Guides which were observed demonstrated adequate knowledge in their duties and responsibilities and also were knowledgeable in proper radiation and exposure control.
Engi Jefferson Staaina Ar_ea
- 1. The set-up and activation of the facility went very smoothly and was better organized that the drill on September 10 with the same crew.
- 2. The command and control of the facility by the Staging Area Coordinator was very good. He utilized the P.A. system effectively for general announcements and conducted briefings with his key coordinators as the need arose.
- 3. The preassignment of the Traffic Guides for a two mile evacuation was done promptly. The Lead Traffic Guides performed properly and knew their procedures well.
- 4. Response to the traffic impediments by the field workers was very goo.d. The information flow to the staging area was timely and accurate. The Road Crew arrived within 17 minutes of the request for help from the scene of the accident at Oakland Ave. and Rte. 25A.
Riverhead Stacina Area
- 1. The setup and activation of the facility proceeded smoothly and was accomplished in a timely manner.
- 2. The conduct of operations within the Staging Area were much improved over the previous week. Briefings were better conducted and were more complete. Communications between staging area personnel were improved.
/
- 3. The distribution of dosimetry was observed to be not well controlled. Emergency workers were arriving at the briefings near the completion of the session and were not afforded the benefit of a complete briefing. A better coordinated dosimetry briefing and issuing session was pointed out at the post drill critique. ,
s
- 4. The response by the Road Crew to the traffic impediment. ,'
was timely. He arrived within 10 minutes of being requested.
There was a problem however in the area of communications;
! several of the vehicles which are used for the road crew simulation do not have cigarette lighter receptacles for the radio power supply. This however is only of a concern during a drill when actual road crew vehicles are not used.
t 765733 i
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- 5. Tho Traffic Guides which ware cbcorysd parformed satisfactorily. Each arrived at his location in a timely 1 manner and were knowledgable in their procedures. They i periodically updated the EOC of traffic conditions. The l redirection of traffic following the traffic impediment was !
handled well. The Traffic Guides were observed to l periodically check their dosimetry per the procedure. l
- 6. The performance of the Route Spotter was very good. He was familiar with his procedures and was in contact with the EOC. His response to the simulated accident was prompt. He was observed to check his dosimetry periodically and was knowledgeable as to as to maximum exposure allowances.
October L,1185. -
Emeroency Doerations Center
- 1. The participants,were prestaged. The facility was fully staffed and set-up within 45 minutes of the time the participants were told to report.
- 2. Only 2 general staff meetings were held by the Manager of Local Response.'Several more general announcements were made to the EOC floor. It was pointed out at the critique that the information flow to the staff either through staff meetings or general status meetings could be improved.
- 3. The distribution of RECS messages to the EOC staff was very slow. This was due to the number of copies being distributed. It was pointed out at the critique that the distribution should be reduced to expedite that process.
- 4. The broadcast of the EBS messages was well coordinated with the sounding of the sirens and all messages were aired within 15 minutes of the decision to do so.
- 5. The handling of the traffic impediments in the EOC was done very well. All persons concerned exhibited a high level of concern and urgency. There was good coordination among all groups. The Traffic Engineer however, had to be prompted to develop revised evacuation time estimates based upon the i rerouted traffic. The information flow into the public information office could have been improved so that they would have information immediately available to them to
. generate the EBS messages. These shortcomings were pointed out during the post drill critique.
- 6. The information flow between the EOF and the EOC in the dose assessment area was very good. Both organizations were comparing data and field team deployment was well IMP,EA:@
765734 1 ... - - - - _ _ _ - -
! I coordinated.
- 7. The information flow from the EOC to the Staging Area was slow and as a result the field personnel were working with information and data that was up to 30 minutes old. The rapid and accurate transmission of information to the field
- was emphasized during the critique.
- 8. The generation of EBS Messages, Press Releases and
' Summary Sheets by the Public Information Staff in the EOC was very good. However the information flow from the EOC to the ENC was poor. Due to a malfunction of the TSO, and no alternate means of transmitting information to the ENC explored, the LERO Spokesperson in the ENC was not in " sync" with the SNPS Spokesperson during press briefings and press conferences. It was pointed out during the critique that it it is i' m perative that both organizations represented-at the News Center have the same information in the same time frame. .
Emeroency Worker Decontamination Facility
- 1. There were several pieces of equipment which were used during the drill which were not functioning properly or were used improperly; bad or dead batteries, broken connectors, wrong probe, open vs. closed window etc. The proper use and .
checking of the equipment was stressed, at the critique.
Equipment deficiencies were reported to the Emergency
. Preparedness group for resolution.
'2 . The status of the emergency was not regularly announced to the EWDF staff. The importance of timely information flow was pointed out during the critique.
I l
- 3. The controller conducted several contamination scenarios I which were presented to the participants for their resolution. In one instance the contamination was not found due to poor monitoring techniques, in another the monitoring'
~
personnel cross-contaminated the area by improper controls. j These discrepancies were pointed out to the personnel during the critique.
Patchocue Stacina h
- 1. Bri'efings given by the coordinators to the Staging Area personnel were few in number and not specific enough.
Dosimetry information was not repeated during the briefings to the field workers. During the critique it was pointed out that the staff must be kept up to date with respect to the j status of the emergency and this is done by frequent and timely briefings. It was also pointed out that dosimetry l
l 765735
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and exposure control procedures and criteria should be repeated as often as possible. ,
- 2. The Lead Traffic Guides needed guidance to perform their function and implement their procedures. This was due to the fact that they were relatively new to the position.
- 3. The message concerning the failed sirens was transmitted to the Staging Area by the EOC at 9:48 A.M. It was not until 10:25 A.M. that the Route Alert Drivers were dispatched. At the post drill critique it was stressed that message handling must be expedited especially when the Hispatch of field personnel.is involved.
- 4. The issuing of dosimetry and the dosimetry briefings got off to a slow start. _However as the drill progressed, the dosimetry briefings improved as the personnel gained experience.
l 5. Information for transmittal was frequently given to the communicator verbally instead of written. The use of written messages and the procedure governing the handling of messages was discussed at the post drill critique.
- 6. Of the 5 Traffic Guides questioned, all were unclear as to the maximum allowable doses.
- 7. The Route Spotter questioned in the field was knowledgeable in his job function and was knowledgeable in dosimetry and exposure control.
- 8. The Route Alert Drivers questioned were knowledgeable in their job function and were knowledgeable in dosimetry and exposure control. ,
P.g.3 Jefferson Stacina Arga
- 1. Many personnel at the facility were new to LERO and were participating in their first drill. As such the more ,
experienced personnel had to perform many of the tasks which otherwise could have been delegated. This detracted from the success of the drill. ,
- 2. IEhe message'to dispatch the preassigned traffic guides arrived in the Staging Area at 1245. This was approximately 13 minutes after the information relative to the evacuation :
protective action recommendation was known to the evacuation group in the EOC. This time could be reduced. The traffic guides were dispatched from the Staging Area slower than previously due to confusion arrising when three seperate dispatch messages arrived in the Staging Area within a few l
1 765736
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minutes of each other. There was also confusion reintive to flow.
the , procedure for one-way traffic l 3. The briefing of the players and the issuing of dosimetry by the Dosimetry Record Keepers was good. The briefings were clear and concise.
The DRK's displayed a good knowledge of their procedures.
prompts were issued by the Communications Several issue updates 4.
l
' Controller to the Staging Area Coordinator to to the EOC relative to facility status and to request status reports from the BOC. During the post drill critique it was stressed that the information flow is a "two-way street" and that the lines of communication must continually be open. '
Riverhead Staaina Arga Similar to the situation at Port Jefferson many ofwalked the
- 1. be players were new to their position and had to by through their jobs either by more experienced people or the controllers.
The message 'to dispatch the bus drivers following the
- 2. to recommedation by the EOC to do so was veryP.M. late getting this the Staging Area. It was not until 1:30 that information was available in.the Staging Area and only after Bus ' Dispatcher requested it from the EOC. Another the P.M. indicated message recieved in the Staging Area at 1:40 that a release had occured at 12:35 P.M. The bus drivers At
- were dispatched into the plume without prior knowledge. in the critique it was pointed out that this type of delay message transmission an0 working with information which is can have negative results as was demonstrated in very old -
this case.
- 3. The dispatch of the Traffic Guides for the 2 mile to evacuation was done promptly following the instructions do so by the EOC.
Summary The concept of conducting drills on consecutive weeks with staging tha same team proved to be beneficial especially cope. in the with the l Arons.- Shift 3 personnel were better able to cmargency on September 17 than they were on September 10. Shift primarily due to 2 on October 1, did not perform as well overall tho fact that they had not drilled since June. special objectives The assessment of the response to the report is as itomized in the " Background" section of this follows:
IN1P M )
765737
,, y o The ability of the EOC staff . to recognize and to i develop a plan to counteract impediments to traffic were generally good. Communications within the EOC relative to the impediment and the cooperation of the various groups involved were good'. The use of the Traffic Engineer proved to be very valuable in developing recommendations for citernate evacuation routes, however more emphasisestimates, should be placed on rapidly generating new evacuation time ~
even if they are first order approximations, so thatemphasis a more informed decision can be made. In addition more
- needs be placed on the roll of the Public Information group.
EBS messages need to be streamlined concerning the l
i impediment information and what the general public need know. The flow of information into the Public Information can be Office needs to be improved so that the. messages' generated in more expeditious manner.
The response of the Staging Area to traffic impediments was also generally good. The flow of information withinfield the staging Area and between the Staging Area and the i needs to be improved. There is considerable delay caused by the handling of messages. The response of the field forces to the impediment was good. Generally, most'of the would field '
personnel were knowledgeable in their procedures and
! have been able to handle the situation in the field without too much difficulty.
o The procedure to pre-assign Traffic Guides for the two mile evacuation was demonstrated very well. The staff at the Areas knew the procedures and were able to carry
> Staging them out. The dispatch of the Traffic Guides to the field was once the order to do so was recieved from the EOC the generally good. Some improvement could be attained in the l
area of establishing one-way traffic flow per procedures. Once dispatched, the Traffic Guides were able in toa locate their positions and establish the post
- reasonable amount of time.
continuation of the bus driver training did o The occur during this drill series. The results of that training is included in a seperate report.
o The concepts of dosimetry and KI were reinforced by the controllers and the players during the briefings held by the Dosimetry Record Keepers. Bowever, when questioned in the controllers, responses still showed a lack of
- field by J
understanding by some of the players. Continued education in this area is needed.
l One of the major areas of concern during this drill andseries the continues to be the communications between the EOC
~
Sttging Areas. Long delays in getting information to the Staging IN\Pfflk&
765738
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Arocs were experienced throughout the drills. Much more emphasis nocds be placed on communications, both in accuracy and l
titoliness. Delays in the response by the Staging Areas can be traced back to delays in transmitting information or instructions by the EOC. The information flow from the EOC to the ENC also proved to be major deficiency noted in one particular drill. It cpp3ars that the common denominator in communications delays is tho EOC, and emphasis must be placed in training that facility.
The information available to the staff at a particular fccility, i.e. the EOC of the Staging Area is a function of how wall, how often and how accurate the staff briefings are. One of tho major reasons for a lack of available accurate information wac the lack of proper staff briefings. During future training cosolons this area o'f communication will be stressed.
Another area of communications that has been a problem in the past, and is still a problem with certain shifts, is the communications link between the EOC and the EOF in the area of deco assessment. The exchange of information from the EOF to the EOC needs to.be improved. This will continue to be examined in future drills where the EOF and the EOC are both participating.
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765739
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- ATTACHMENT 9 4
( ..
March 4, 1987 -
D.M. Crocker Drill Report for December 2 and December 10, 1985 for LERO
Background
As part of the quarterly Emergency Preparedness drill program, drills were conducted on December 2 and December 10, 1986 to practice the response of the Local Emergency Response Organization (LERO) to a simulated emergency at the Shoreham Nuclear Power Station (SNPS). The purpose of the drills was to exercise LERO's ability to implement the Offsite Radiological Emergency Response. Plan Implementing Procedures (OPIP's) to. improve their ability to respond to an emergency, make appropriate recommendations to the public and implement those recommendations. All sections of LERO participated in the drills with the exception of the LERO Relocation Center and the Evacuee Reception Centers. The facilities which did participate 1.icluded the Local Emergency Operations Center (EOC), the Emergency Worker Decontamination Facility (ENDF), Patchogue Staging Area (PSA), Port Jefferson Staging
. area (PJSA), Riverhead Staging Area (RSA), Family Tracking and the Emergency News Center (ENC). Only 1/2 of the field personnel were exercised during each of the two drills. All field workers performed their normal emergency duties with the exception of a few bus drivers who were involved in a make-up session to familiariza them with bus yards and transfer points.
Emergency Preparedness Drill Scenario 8A Revisior. I was used fcr the December 2 drill and Scenario 7A Revision 1 for '.he December 10 drill.
Shift I participated in both drills. They were last drilled in the February 13 1986 exercise. The purpose of drilling Shift 1 on two consecutive weeks was to allow the participants to use the first week as a learning process to become familiar with the latest procedures and the second week to reinforce their knowledge gained during the first drill.
All LERO at locations members weretime, preassigned pre-staged, rather than i.e. told to rep exerci (ort e the to their work normal notification and call-out procedures. This prov.ded the opportunity to brief LERO personnel on procedure changes and reinforce earlier training on OPIP revisions.
Revision 8 to the Offsite Radiological Emergency Response Plan and Procedures was in effect at the time of the drills. All persons were drilled to that revision.
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Scenario Obiectives The following is a summary of how well LERO performed the scenario objectives. The LERO objectives were the same for both scentrios and are -~
listed in Attachment 1.
EOC Obiettive 1 December 2 &
December 10: Initial and follow-up communications were accurately and timely received. RECS messages from the TSC and EOF were telecopied to the EOC to prevent any misinformation.
This objective was met for both drills.
E0C Oniective 2 December 2: LERO EOC members were told to report at 0800. The EOC was fully staffed and operational at 0845. However, the facility was not declared activated until 0910 because the TSC/ EOF staff were not pre-staged and were thus, not available. The Manager informed the Lead Controller of
, this and it was deemed acceptable to him.
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December 10: LERO EOC members were told to report at 0800 with the 1 EOC being declared activated at 0848. .
EOC activation for both drills was adequate. This objective was met.
During the February 13th exercise, LERO EOC members began. arriving at 0707 with the EOC being declared activated at 0810.
EOC Obiective 3 ,
December 2: Rosters could not be found by the Lead Communicator.
The Equipment Controller for the EOC claims the rosters
- were on the cart but must have been misplaced during l set-up. This objective was not met. The critique emphasized the importance of these rosters.
December 10: Rosters were available to the Lead Communicator and he verified the ability to maintain 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing. This fulfilled the objective.
j E0C Obiective 4 ,
December 2 &
December 10: No shortage of space, equipment or supplies was observed during these drills. This objective was met.
r EOC Obiective 5 December 2 &
December 10: As stated in the objective, the RECS ,
communicationsbetween the state and county were l simulated. In addition, communications with FEMA, EBS I station, local schools, hospitals and ambulance companies were simulated. For December 10, communications with the radiological monitoring teams ,
were also simulated (this was not practiced on December 2). All other communications were practiced and found satisfactory. On December 2, the EOC had minor difficulty receiving data from the EOF via the dedicated line due to background noise by personnel in the room.
However, this did not hinder any response to the scenario and did not recur during the December 10 drill. This objective was adequately met.
1 EOC Obiective 6 December 2: Security was unable to locate their box of procedures i
for 20 minutes during the drill due to it being
- misplaced during set-up. However, Security was familiar enough with the procedures to do.without them. They also obtained pertinent procedures from the Manager and Director. Therefore, their inability to locate their own procedures for 10 minutes did not hinder their performance.
Finally, Security did not maintain a log-in/ log-out -
- policy during the course of the drill. Tht s should be done per procedure to maintain accountabilnty in the EOC.
The need to maintain accountability with the log-in/ log-out procedure was stressed in the Critique and a form will be provided to Security in a later ~
4 revision of the OPIPs to assist them in this matter.
This objective was partially met.
December 10: No problems were observed during the drill. This objective was set.
EOC Obiective 7 i December 2: Six staff meetings were held during the course of the
' drill which is adequate. All messages were properly logged by the Lead Communicator; however, some persons (approximately 207, estimated by the EOC Lead Controller)
' wrote messages on a scrap sheet of paper rather than standard LERO message forms. Status boar &. were
' observed to be kept up-to-date and communications were observed to be transmitted accurately. Proper use of message forms was discussed in the critique.
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Status updates from the EOC ccntained canflicting .
Information. For example, at 1215 an EOC message was sent to the Riverhead Staging Area instructing field personnel to don their protective clothing and injest KI. At 1307, a status update was sent to Riverhead indicating no change in status with no recommendation to don protective clothing or injest KI. This problem was addressed and corrected for the December 10 drill.
This objective was partially met.
December 10: Five staff meetings:were held during the course of the i drill which is fewer than December 2 but is still adequate. Two general status updates were made by the ,
Lead Coordinators. All messages were properly logged by the Lead Communicator.
The information contained in the communications relative to the brush fire on the Long Island Expressway changed '
as the message was transmitted through the LERO Organization. The message stated that a brush fire was causing a complete blockage of the east and westbound lanes of the Long Island Expressway and also the north i and southbound lanes of Patchogue-Mt. Stani Road.
(Refer to LERO Message Nos. 14 and 14A). The Lead Controller at the EOC decided to initiate the message at the ENC rather than at the EOC as the message dictates.
. In the transmittal of the information from LERO ENC personnel to the EOC, the information on which roads '
were blocked was left out. This information was given
! to the Traffic Group at 0934. The Traffic Group
, attempted to determine which roads were blocked by-
! seeking information from the Patchogue Staging Area.
I The Public Information Group was prompted by the Public 4 ,
Information Controller to re-contact the ENC for the road blockages. This complete information was given to
, the Traffic Group at 0942. However, the Traffic Group
- continued its efforts to verify the road blockages.
! Ultimately, at 1025, through information provided by the
! Patchogue Staging Area (Patchogue Traffic Controller simulating a Route Spotter per the scenario) the information was that only the westbound lanes of the Long Island Expressway were blocked. However, the EOC
, began investigating re-routing, if necessary, and the
- fire's effects on the evacuation time estimates at 1008.
The importance of obtaining all information was
! discussed with the Public Information staff. In addition, the necessity of verifying reliable i information (i.e. radio broadcast) was discussed at the
- critique.
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-In an ann:uncement to the EOC, the phrase "10-mile l
- keyhole" was used to describe the area to pre-stage .
buses which led to some confusion by the Transportation l Group. However, this did not slow their response since these players are well versed in determining zones based I on wind direction. Still, the exact zone letters should I be used and was mentioned in the critique.
The Emergency Planning Group developed a new method to improve the speed and accuracy in which status updates are transmitted to the Staging Areas. This new method was tested by LERO members in this drill. Instead of i being given to the Evacuation Support Communicators for transmission to the Staging Areas, the Lead Communicator, with help from the Administrative Support Staff, telephoned status updates directly. In addition, the Manager reviewed and approved all messages prior to s their transmittal to ensure accuracy. This process
. worked well. This change will be reflected in a later revision to the procedures.
.].y This objective was partially met.
- EOC Ob hetive 8 December 2
- The Director of. Local Response was in control throughout
- the drill and decisions were handled in a proper and i
expeditious manner. This objective was met. -
December 10: The Director of Local Response was in control throughout
- the drill; however, the PAR decision took from 1220 to i , 1250. The Director was trying to obtain information from the EOF relative to the declaration of the Genefal Emergency and the rationale for their protective action
- recommendations. The EOF recommended evacuation of
- ' zones A-J at 1225. The RHC and the Nuclear Engineer tried to obtain data from the EOF to make their independent assessment of the potential for containment i failure. Since the persons in the EOF were in a meeting
! at the time, the RHC and the Nuclear Engineer were content to wait. At 1250, the Lead Controller prompted
- the Director to call for an evacuation of the affected zones so as not to impact the remainder of the i scenario. This objective was not adequately fulfilled. ,
l In the critique, the RHC and the Nuclear Engineer were j informed that they weren't forceful enough in trying to
!' obtain the data and they should have informed the Director so that he might try to obtain the information
, from another source.
EOC Obiective 9 f
December 2: The Alert was declared at 0842. The Director decided to recommend early school dismissal at 0908. Sirens were activated at 0913 and an EBS message with early dismissal of schools was sent at 0914. The Public and Private School Coordinators obtained a copy of the EBS e message and contacted simulated schools.
December 10: The Alert was declared at 0808. The Director decided on
- an early dismissal of schools and sent an EBS message at
! 0828. Sirens were activated at 0834 and EBS message
- with early dismissal of schools sent at 0833-0836. The Public and Private School Coordinators obtained a copy of the EBS Message and contacted simulated schools.
- Response at both drills' was adequate; this objective was met.
l EOC Obiective 10 December 2: EBS Message 1 - Alert declared at 0842.
Director decides on PARS at 0908.
i Sirens sounded at 0913 (simulated).
, EBS aired at 0914 (simulated).
EBS Message 2 - Site Area Emergency declared at 1010.
Director decides on PARS at 1027.
Sirens sounded at 1030 (simulated).
EBS aired at 1031 (simulated).
The section referring to placing animals on stored feed was deleted'and a follow-up message had to be issued.
This item was discussed at the December 9 critique with
- the Lead Controllers and the problem did not recur at the December 10 drill.
EBS Message 3 - General Emer g ency declared at 1132.
! Director decides on PARS at 1149.
Sirens sounded at 1154 (simulated).
j EBS aired at 1155 (simulated).
1 EBS Message 4 - This is a Traffic Impediment message and doesn't fall into the 15 minute criteria. Refer to EOC Objective 11 for further information.
- EBS Message 5 - This is a Traffic Impediment message and t doesn't fall into the 15 minute
! .. criteria. Refer to EOC Objective 11 for further information.
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December 10: EBS Message 1 - Alert declared a~t 0808.
Director decides on PARS at 0828.
Sirens sounded-at 0834 (simulated).
EBS aired at 0833-0836 (simulated).
EBS Message 2 - Site Area Emergency declared at 0953.
Director decides on PARS at approx. 0955.
Sirens Sounded at 1002 (simulated).
EBS aired at 1003-1006 (simulated).
EBS Message 3 - General Emergency declared at 1202.
Director decides on PARS at 1205.
Sirens sounded at 1219 (simulated).
EBS aired at 1218 (simulated).
EBS Message 4 - Director decides on PARS at 1248.
Siren sounded at 1255 (simulated).
EBS aired at 1257-1302 (simulated).
EBS Message 5 - This is a Traffic Impediment message and doesn't fall into the 15 minute criteria. Refer to EOC Objective 11 for further information.
EBS Message 6 - Director decides on PARS at 1355.
Sirens sounded at 1407 (simulated).
EBS aired at 1408-1415 (simulated).
- EBS Message 7 - This is a Traffic Impediment message and doesn't fall into the 15 minute criteria. Refer to EOC Objective 11 for further information.
All EBS Messages with protective actions met the objectives for both drills.
EOC Obiective 11 December 2: The Traffic Group expeditiously handled two evacuation free play impediment messages that were introduced per the scenario in the field. Specifically, the first impediment, a gravel truck and thrae passenger cars was introduced at 1315 from a Road Cr-4 on location. The message was recorded accurately and completely by the Evacuation Support Communicator and by 1320 the Evacuation Coordinator and the rest of the Traffic Group were informed of the impediment. Immediately the Traffic Engineer started evaluating the problem under direction of the Evacuation Coordinator and additional Road Crews were dispatched to the scene. By 1328 the Manager, Coordinator of Public Information and Transportation Support Coordinator were informed. At 1334 the Road Crew informed the EOC that removal of the impediment would take more than two hours. Previously at 1328, the Traffic Group followed procedures and had obtained approvals on the proposed re-routing and had contacted TCP 10 by radio (as per procedures). A total of 13 minutes elapsed from notification of the impediment and the implementation of re-routing. The Director decided to issue EBS Message No. 4 with traffic impediment information at 1330 and the EBS message was broadcast at 1341 (simulated). The sirens were sounded at 1340 (simulated). By 1337 the Manager briefed the EOC on the impediment and stated that an EBS message was being broadcast to alert motorists of the situation. By 1349 an approved bus re-routing scheme was developcd by the Traffic Engineer and the Transportation Support Coordinator. The Evacuation Support Communicator transmitted this information at 1402. Special Population Coordinators, whose functions may have been impeded by the accident, were informed at 1358. This exhibited very good control and coordination by the Evacuation Coordinator and all other functional groups.
At 1404 Route Spotter 1005 called in a fuel truck impediment. The Evacuation Support Communicator quickly and accurately transcribed the message and gave it to the Traffic Control Coordinator immediately. By 1410 the entire Traffic Group was informed. By 1412 the Traffic Engineer started working on re-routing because the Evacuation Coordinator realized it would be difficult to remove a leaking fuel truck. After following all procedures, at 1425 re-routing information was given to the Lead Traffic Guides at the Staging Areas. A total of 21 minutes elapsed from the impediment notification to transmission of re-routing instructions. The Traffic Control Point Coordinator was informed by the Traffic Controller that response may have been faster if the Traffic Control Points were radioed from the EOC with re-routing instructions as was done in the first impediment. . Also, at 1425 the Mt.
Stani Fire Department was called (simulated) and was asked to respond as was the owner of the fuel truck.
Bus re-routing was completed by'the Traffic Engineer by 1450 and was transmitted to the Bus Dispatcher by 1455.
EBS Hessage No. 5 describing re-routing was approved by the Director at 1418, broadcast (simulated) at 1437 and sirens were sounded (simulated) at 1436.
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Response to the road impediments was organized and efficient due to good communication between and within the Traffic Group and other groups and upper EOC management. This objective was met for both impediments. .
The EBS Messages for these Traffic Impediments contained - -
specific re-routing information. Contents of EBS Message issued for Traffic Impediments was discussed in the December 9 critique with the Lead Controllers. The ;
Emergency Preparedness Group is in the process of ;
developing general guidelines of what should be included J in these messages. There are no Federal requirements.
In the December 10 drill, the EBS Messages for Traffic Imp.diments were improved over those for previous drills.
December 10: Four impediments were introduced per the scenario. The first impediment, a brush fire, was designed to test only the EOC's response to an impediment that blocked a major artery (LIE) and might possibly affect the evacuation time estimates. No field workers were dispatched and the fire was extinguished before the evacuation per the scenario. The second impediment was removable and its intent was to pre-occupy the EOC while
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an evacuation was in progress and when the third and fourth immovable impediment were introduced. The third and fourth impediments were designed to test LERO's re-routing abliities.
Brush Fire'Imoediment - LIE & CR 83 The.EOC was informed of the fire by the ENC at 0930.
The Public Affairs group gave the message to the Traffic Group and the Evacuation Coordinator was informed as of 0942. By 0954 the Evacuation Coordinator instructed the Evacuation Route Coordinator to get a Route Spotter out to check out the fire. The Traffic Engineer started
- working on potential re-routing, should it be necessary. At 0955 the Site Area Emergency was declared. The Route Spotter responded as of 1025 (Controller via radio at Patchogue, no personnel actually were dispatched to the fire per the scenario).
The Traffic Engineer discussed the impact on the evacuation time estimates (roughly double) with the Radiation Health Coordinator and discussions took place on the possible effect on PARS. After questioned by the Traffic Controller, they indicated that this may sway a PAR toward sheltering if conditions degraded further. i The objective of this impediment was adequately fulfilled by EOC members. Further details on problems with communications on the brush fire are included in
- EOC Objective 7.
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l Duck Truck Innediment ~
-This was introduced at the ENC at 1200. An EOC Pteiic Information staff member gave the message to the Evacuation Coordinator at 1223. This delay was because the ENC Controller had transmitted the message incorrectly indicating the EOC was already aware of the incident. The Public Information Controller corrected the response. At 1226 a Route Spotter was dispatched to ,
report on the accident.. Note that this was prior to an evacuation order. Previously the Traffic Control Coordinator and the Evacuation Route Coordinator had decided to dispatch the Evacuation Route Spotters i because some were already at the Staging Areas. This was done without consulting with the Evacuation Coordinator. By 1249 the Route Spotter reported the extent of the accident (T = 23 min.). By 1252 the Evacuation Coordinator wanted a tow truck sent to the scene even though there was not an evacuation yet. By ,
1353 this Road Crew reported to the scene (T = 61 min.
i (Note that evacuation order came at 1254). By 1400 the
- duck truck had been' cleared. The reasons for the delay s
was discussed with the Traffic Group at the drill critique.
Cement Mixer Innediment l This was introduced at the desk of the Evacuation
, Support Communicator at 1303. By 1314 the Evacuation Coordinator ordered the Road Logistics Coordinator to send out two Road Crews while the Traffic Engineer
! developed alternatives. Re-routing was presented at
- 1317 and was approved. At 1327 the Traffic Control Coordinator relayed modifications to the Riverhead Lead Traffic Guides because the Traffic Control Points were not yet manned. The appropriate Traffic Control Points -
, were contacted by the Staging Area at 1331. Very good i response by the Traffic Engineer (T = 14 min.). Bus
- re-routing was developed in 13 minutes (1330). The i total time for the entire response was 28 minutes. This i time was very good. EBS Message No. 5 with this traffic j information was approved at 1330 and was broadcast between 1334-1339 (simulated). Strens were sounded at 1333 (simulated).
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Cessnoel Truck Immediment This was introduced at 1400 to an Evacuation Support Communicator. Information was correctly disseminated and by 1412 the Traffic Engineer developed a re-routing scheme-(T - 12 min., very good response). After approval was made, the Traffic Control Point Coordinator transmitted re-routing information directly to, Traffic Control Points 63 and 64 via radio at 1417. Total response time was T = 17 min. (good response. time). Bus operations were not affected by this impediment. EBS Message No. 7 with this traffic information was approved at 1432 and broadcast at 1437 (simulated). Sirens were sounded at 1436 (simulated).
This objective was partially met with the exception of the Duck Truck accident. As stated previously, the reasons for the delayed response was discussed at the i
drill critique.
EOC General Comments December 2: The procedure for the periodic estimation of total population exposure was not demonstrated. However, the procedure allows for this estimation to be completed after the initial crisis is over and, due to the compact
! nature of the scenario, time would not permit this to
- occur.
For the pre-staging of' buses, the Manager and Evacuation Coordinator wanted to wait until all of the required Bus Drivers were at the Staging Areas. In fact by procedure, the order to pre-str.ge should be issued regardless of the number of drivers available and the Staging Area should assume the responsibility for dispatching the Bus Drivers at the proper time. This was discussed at a critique held on December 9, 1986
- with the Lead Coordinators.
At the ENDF, two of the twelve RM-14s (#5253 and #5230) used during the drill were nearly discharged at the start of the drill. The Decontamination Leader directed
! the monitoring personnel to check battery levels every i 15 minutes and change any that were below the acceptable i level in anticipation of this problem. This was excellent guidance on the part of the Decontamination l Leader. This equipment maintenance problem was brought i to the attention of the Emergency Preparedness Group and i
has been resolved.
The Record Keepers at the ENDF were confused on the correct serial numbers to use for the TLD's. LERIO is in the process of highlighting the serial numbers to avoid this confusion in the future.
December 10: Again, estimation of total population exposure was not performed; however, it was considered. The procedure was not demonstrated because the drill was terminated prior to its. implementation. The practice of this procedure will be emphasized.in future drills.
At the ENOF, a field worker simulated to be contaminated walked approximately 20 feet in a clean area before being stopped by an ENDF person. This was discussed at the drill critique.
One problem was encountered with Family Tracking which concerned the EOC at Brentwood. The people receiving the calls in Brentwood were not returning the confirmations of delivery of the message to Family Tracking, they were returning them to the original J
caller instead. Procedures call for them to call back to Family Tracking when the message has been delivered to the LERO worker. Family Tracking would then call the 4 original caller to confirm that the LERO worker had been reached. This ites will be stressed at future training sessions and drills.
I The Special Facilities group and the Ambulance *
, Coordinator did a very good job in performing their i
duties. The Home Coordinator however did not get a Itsting of the Reception Hospitals prior to calling the "
homebound when the evacuation of additional zones P and
. S were called for. This was discussed at the critique and will be stressed in future training sessions and i ,
drills.
A message was received from the 'fleid that an individual had received 4 Rem and was requesting authorization for l additional exposure. The location of this individual
, was outside the radioactive plume and his reported i exposure was never questioned. In addition the Director i authorized exposure up to 10 Rem and the RHC was not
! consulted. This is a direct violation of the procedure and was discussed at the critique.
The RHC assumed that no release was in progress at 1245, yet the Assistant RHC had information which was obtained 10 minutes earlier that field readings indicated 25-30 ar/hr near the site boundary. This was due to contradictory data being given to the Assistant RHC by
! the Lead Controller. The data supplied by the Controller was lower then the data supplied by the EOF.
This was a problem with the scenario and not a problem with the players.
Staaina Areas Obiective 1 December 2 &
December 10: Port Jefferson. Patchoaue and Riverhead Emergency notifications were received in a timely manner. This objective was met.
Staaina Areas Obiective 2 December 2: Port Jefferson LERO Group 1 and 2 members were told to report at 0800.
The Port Jefferson Staging Area was declared activated at 0845. The Staging Area was ready at 0830, but they delayed stating that the Staging Area was activated until the EOC was ready to receive messages at 0845.
Patchoaue LERO Group 1 and 2 members were told to report at 0800.
The Patchogue Staging Area was declared activated at 0830.
Riverhead LERO Group 1 and 2 members were told to report at 0800.
The Riverhead Staging Area was declared activated at 0815.
These times were adequate; this objective was met for all Staging Areas.
December 10: . Port Jefferson LERO Group 1 and 2 members were told to report at 0800.
The Patchogue Staging Area was declared activated at.
0820.
Patchoaue LERO Group 1 and 2 members were told to report at 0800.
The Patchogue Staging Area was declared activated at 0822.
Riverhead LERO Group 1 and 2 members were told to report at 0800.
The Riverhead Staging Area was declared activated at 0825.
These times were adequate; this objective was met for all Staging Areas.
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, Stacina Areas Obiective 3 December 2&
December 10: Port Jefferson. Patchoaue and Riverhead Rosters were available to the Staging Area Coordinators to fulfill this objective.
Staaina Areas Obiective 4 December 2: Port Jefferson Sufficient space, parking, equipment and supplies were available to activate and support the Staging Area activities. One minor problem with equipment was that
- not enough magnetic-type antennas were available. Three
! Traffic Guides had to use the clip-type antennas and l attato these to their windows since their cars did not
, have raingutters. This did not prevent the Traffic
!. Guides from performing their duties, however, the i Emergency Preparedness Group is addressing the concern.
Patchoaue and Riverhead
.: Sufficient space, parking, equipment and supplies were available to activate and support the Staging Area activities.
I December 10: Port Jefferson. Patchoaue and Riverhead Sufficient space, parking, equipment and supplies were available to activate and support the staging area activities. The concern about antennus for Port Jefferson was not resolved for this drill and is being addressed by the Emergency Preparedness Group.
This objective was met for both drills, f Staaina Areas Obiective 5 December 2: Riverhead i
! The radio at Riverhead used to communicate to the field
! was inoperable at 1125. The Riverhead Staging Area called for a radio repair technician and the radio was back in service at 1215. Due to the problems with the Riverhead radio the Eastport Substation Transfer Point
- Coordinator phoned in to the Bus Dispatcher at Riverhead
! informed him that both he and the Brookhaven Substation
! and could not radio Riverhead. He stated he would call i in every 1/2 hour. As stated previously this problem
, was resolved at 1215. This did not affect field operations and demonstrated a resourceful approach to problems.
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Port Jefferson and Patchoaue All communication links with these Staging Areas and the LERO EOC and field personnel were established and operated adequately.
ihis objective was met.
December 10: Port Jefferson. Patchoaue and Riverhead All communication links with these staging areas and the LERO EOC and field personnel were established and operated adequately. This objective was met.
Staaina Areas Obiective 6 December 2 &
December 10: Port Jefferson. Patchoaue and Riverhead Security was adequately maintained at these Staging Areas. It should be noted that only 1/2 of the field personnel were instructed to report per drill. This caused some problems with staffing security however security was maintained with available personnel. This objective was met.
Staaina Areas Obiective 7 December 2: Eart Jefferson
.All messages were accurately transmitted and put on the proper message forms. Updating of the status boards were not consistently kept up-to-date. Three updates from the EOC were received but on one, only some of the changes were reflected on the status board. Upon prompting, the status boards were corrected. The updating of status boards was stressed in the drill critique.
The PA system was regularly used to brief staging area personnel.
Patchonue The entire communication staff was well trained in all aspects of their responsibilities, however, some messages were not forma 15y documented on a message form (i.e., Bus Dispatcher to radio operator to inform Transfer Points to begin evacuation at 1250 was done verba11y). Use of message forms was discussed at the drill critique.
t- Status boards were adequately kept up-to-date and L- briefings were held frequently. However, the Bus Driver briefings held by the Bus Dispatchers were not well -
organized. Bus Drivers came out of the briefings not knowing of their assignments or status of the emergency. This item was thoroughly discussed in the drill critique. There was no such problem in this group's subsequent drill of December 10.
The Staging Area Coordinator did not fill-out OPIP 4.1.4, Attachment 4 per his procedures and the Lead Coordinators did not document their critical actions / decisions. This was discussed in the drill critique and did not recur in the December 10 drill.
Riverhead Messages were transmitted and recorded in an accurate and timely manner and were properly logged. However, status boards were not consistently maintained (i.e., at 1055 and 1115 the Staging Area received a status update but did not update board). In addition, status update announcements were lacking information and infrequent.
This was discussed at the drill critique.
December 10: Port Jefferson. Patchoaue and Riverhead All three Staging Areas performed well in fulfilling this objective. However, stating and writing "THIS IS A' DRILL" was sometimes omitted from communications. The use of this phrase was emphasized in the drill critique.
Staaina Area Obiectiva 8 December 2&
December 10: Port Jefferson. Patchoaus and Riverhead The Staging Area Coordinators demonstrated that they were in charge and control of the overall response assigned to their Staging Areas. This objective was met for both drills.
Stanina Area Obiectives 9. 10 and 11 December 2: Port Jefferson Transportation - Bus Dispatcher received message from EOC to dispatch Bus Drivers at 1110 for Miller Place Shopping Center to -
pre-stage and 1210 for Norwood Avenue for evacuation of all zones. 'The Bus Drivers were dispatched by 1130 for Miller Place and at 1210 for Norwood Avenue. (Note: Norwood Avenue Bus Drivers were assigned and ready to be dispatched at 1200. So, as soon as the order came in, they were dispatched.)
All were at the Transfor Points in time to support the evacuation.
Pre-staged Transfer Points were contacted at 1211 by the Staging Area and directed to begin dispatching of buses on their routes at 1300. This fulfills the requirements of the procedures. -
Curbside Pick-up was simulated for this drill and the controllers provided -
names of individuals to the Transfer Point Coordinators at Miller Place and Norwood Avenue. They were instructed to radio in these names between 1330 and 1430 (Refer to LERO Messages Nos.
34-38). The radioing of the names was performed at 1411 for Norwood Avenue and.1416 for Miller Place.
Communication between the curbside Bus Drivers and Staging areas was established for curbside pickup and was adequate.
The Bus Dispatcher received message
, from EOC at 1509 to re-route buses due to fuel truck accident for Routes K5-6 and K4-5. At 1510, the Bus Dispatcher contacted the Norwood \ venue Transfer Point to inform him o.' the re-routing. ,
He was informed that these routes were complete. This shows good
, communications.
-____-_____J
. Transfer Point Coordinators were dispatched to their points earlier (at
. 1015) prior to the dispatching order to support the Bus Driver Road Rally.
(Refer to Staging Areas Objectives 13
, and 14).
Staging Area objectives 9 and 10 wers met for the Transportation Group. ,
. Route Alert Drivers - Lead Traffic Guides received message of
, siren failures (Sirens #50 and #33) at-1025. The route for siren 50 was divided among 2 drivers; those drivers were dispatched at 1045. The route for ;
siren 33 was divided among 3 drivers;
- those drivers were dispatched at 1046. i These routes were completed by 1330. A i slight delay in dispatching was a i
t result of it taking 8 minutes to make i copies of the' zone maps for dividing up the routes. Note that no time frame for completing a route is required.
! In addition, the Lead Traffic Guides received message to dispatch Route Alert Drivers for deaf notification at 1208. Dispatching began at 1215 and
, was completed by 1225. This time is adequate.
i All Route Alert-Drivers phoned in upon
! completion of their routes to receive direction from the Lead Traffic Guides. This fulfills the requirements of the procedures.
< Road Crews - Lead Traffic Guides received message to
, dispatch Road Crews at 1208. Road i Crews were dispatched at 1217. This time is adequate.
i Road Crew 2011 was informed of the fuel
- truck accident at 1430. He was not .
j asked to respond to accident; informed
- that fuel company would handle.
' These objectives were met for the Road Crews.
i
~
Evacuation Route Spotters - Lead Traffic Guides received message to
,, dispatch. Route Spotters at 1208. All Route Spotters were dispatched by 1275. This time is adequate.
- l. Route Spotter 1005 radioed in the fuel truck accident at 1405 (Refer to LERO Message No. 42). The EOC contacted Route Spotter 1005 at 1414 to obtain further information and received it at i
1415. The EOC contacted the Route Spotter at 1430 to provide dosimetry l -
protection to Fire Department and Oil Company personnel responding (simulated) to accident. The EOC again i+s contacted Route Spotter 1005 for update on accident at 1512.
As evidenced above, communications were r
established with Route Spotters and the EOC was able to prcvide directives.
- These objectives were met for the Route
- Spotters.
l.
Traffic Guides - The General Emergency declared at i' .
1132. PAR of Evacuation of Zones A-S
( decided at 1149. Traffic Guide posts
,, to be manned sent to Port Jefferson at 1206 and received at 1208. Preassigned Traffic Guides required for a 0-2 mile evacuation (6) was dispatched at 1222.
Remaining Traffic Guides were
<i dispatched by 1247. The six preassigned Traffic Gui~ des for a 0-2 mile evacuation arrived at their posts as follows: (Note that although 6 Traffic Guides are needed only 3 TCPS are required to be preassigned. 2 Traffic Guides report to TCP #5).
TCP #4 1244 1 Traffic Guide TCP #86 1243 1 Traffic Guide TCP #6 1258 1 Traffic Guide
. TCP #5 1257 2 Traffic Guides TCP #38 1246 1 Traffic Guide
This time frame is less than adequate because only 3 of the 5 Traffic Control Points were manned within 1-hour of the time the EBS Message uas aired (1155). .
The inadequacy was not serious however, because the two remaining Traffic Control Points were manned within 63 minutes. Objective 11 was partially -
met for Port Jefferson. ;
Only 3 TCPs out of the 38 activated for <
this drill were unable to communicate with the Staging Area. These were TCPs 74, 113 and 50. Two of these radios (2100 used by TCP 74 and 1056 used by TCP 113) were used on December 10 and were operating well. Radio 2111 (used by TCP 50) was brought to the attention of the Emergency Planning Group and the problem will be resolved by the next drills.
During re-routing for the fuel truck impediment (at 1502-1510) TCP 56 could '
not be reached via radio by either the EOC, Port Jefferson Staging Area, or by TCP 55. These Traffic Guides were needed to implement the re-routing plan. Initial communication between the Port Jefferson Staging Area and TCP 56 was established at 1255 and TCP 56 radioed in at 1313 upon arrival at TCP. After interviewing a Traffic Guide at TCP 56, he informed me that he tried to reach the Staging Area to verify his re-routing responsibilities but the frequency was being used by others. He eventually did get through to the Staging Area at approximately 1320. At this time, he was told to ~
report to the ENDF. During the time that TCP 56 was unreachable by his radio, the Lead Traffic Guide used good initiative by employing TCP 55 as an available means to contact TCP 56 l directly. TCP 56 was aware of his responsibilities and would have assisted in the re-routing scheme (if time permitted) to ensure adequate
h
, evacuation flow. TCP 55 was contacted and given the appropriate instructions for re-routing. The performance of these instructions by the Traffic Guides at TCP 55, however, were not observed as time did not allow for the performance.
Communications were established and maintained throughout the drill and the Staging Area and EOC were able to issue directives for re-routing. Objectives 9 and 10 were met by the Traffic Guides.
One of the 7 TCPs that the Port Jefferson Field Controller visited was not manned. This was TCP #40 and was visited by the Controller at 1335. TCP
- 40 did not arrive until 1351. This was because the Traffic Guide assigned to TCP #40 was last to receive dosimetry and briefing. The lateness of dispatch for this and four other TCPs were discussed during the critique to emphasize to the Lead Traffic Guide the importance of making sure these posts are manned in a timely manner.
These problems did not recur in the December 10 drill.
Patchocue Transportation - Staging Area received message from EOC to dispatch Bus Drivers at 1055 for pre-stage of zones A-J and at 1207 for evacuation of all zones. By 1145 the required General Population Bus Drivers were dispatched for pre-stage and by 1225 for the additional zones. Special Population Bus Drivers were dispatched by 1110 for pre-stage. No additional Special Population Bus Drivers were dispatched for additional zones since no Bus Drivers were available because only 1/2 of the required field members were participating per the scenario.
All General Population Bus Drivers were at the Transfer Points in time to .
support the evacuation and all Special Population Bus Drivers returned to the Staging Area in time to receive their assignments to support the evacuation.
Special Population Bus Drivers were dispatched on their assignments at 1245.
i Pre-staged Transfer Points were contacted at 1237 and directed to begin dispatching of buses on their routes at 1250. This fulfills the requirements of the procedures. -
Curbside Pick-up was simulated for this drill and the controllers provided names of individuals to the Transfer Point Coordinators at Brookhaven National Laboratory and Coram Plaza ,
Shopping Center (Refer to LERO Message Nos. 34-38). This was performed at 1320 for Brookhaven National Laboratory i and at 1355 for Coram Plaza. :
Communications were established for curbside purposes and were adequate.
In addition, Special Population Bus Drivers assigned to Health Facilities notified the Health Facilities Coordinator upon completing their assignment.
Transfer Point Coordinators were ,
dispatched to their points at 1120 and were at their Transfer Points by 1145.
~
These objectives 9 and 10 were met for the Transportation Group.
Route Alert Drivers - Lead Traffic Guides received message of siren failures (Sirens #19 and #45) at 1018. Both Route Alert Drivers were dispatched at 1025.
In addition, the Lead Traffic Guides received message to dispatch Route Alert Drivers for Deaf Notification at 1212. Dispatching was completed by 1219.
These time frames were adequate.
The Route Alert Drivers phoned in upon completion of their routes to receive directions from the Lead Traffic Guides. Deaf Notification was <
completed by 1414 and notification '
because of siren failure was completed by 1400. No time frame for completing l
! a route is required. Lead Traffic l Guides will be encouraged to dispatch multiple Route Alert Drivers, when they are available, to expedite the Route Alerting Process.
Road Crews - Lead Traffic Guides received message to dispatch Road Crews at 1155. Road Crews were dispatched at 1200'. This time is adequate.
Communications were established with the Road Crews by the EOC. Road Crews frem Patchogue were not needed for this drill's Traffic Impediments.
These objectives were met for the Road Crews.
Evacuation Route Spotters - Lead Traffic Guides received a message to dispatch Route Spotters at 1158.
Route Spotters were dispatched at 1205. This time is excellent.
Communications were established with the Evacuation Route Spotters by the EOC. Route Spotters from Patchogue were not needed for this drill's Traffic Impediments.
These objectives were met for the Evacuation Route Spotters.
Traffic Guides - The General Emergency was declared at 1132. PARS of evacuation of zones A-S decided at 1149. Traffic Guide posts to be manned sent to Patchogue at 1200. Preassigned Traffic Guides required for a 0-2 mile evacuation (18 of the 21 required) were dispatched by 1218. 18 Traffic Guides were used since only 1/2.of the field personnel were invited per the scenario. This did not adversely affect the drill.
Remaining Traffic Guides were dispatched by 1218 also.
The 18 preassigned Traffic Guides for 0-2 mile evacuation arrived at their posts (13 posts; some posts required more than one TG) between 1230 and 1258. (Note that the Traffic' Guide for TCP 75 - one of the TCPs required for a 0-2 mile evacuation - was sent home because of illness. He was not ,
replaced since no other Traffic Guides 1 were available at the Staging Area and- l it was not necessary to call someone I out). This time frame is less than adequate because some Traffic Control Posts were not manned within 1-hour of
{ the time the EBS Message was aired (1155). The inadequacy was not serious however, because the posts were manned '
within 63 minutes, objective 11 was partially met for Patchogue.
No controller was sent to observe the times of arrivals for the Traffic Guides since no Patchogue Traffic Guides were needed for this drill's ,
Traffic Impediments per the scenario.
4 Communications were established and maintained for the Traffic Guides. All Traffic Guides reported in by radio of their arrival at their TCPs by 1258.
These objectives were met by the Traffic Guides.
Riverhead
, Transportation - Staging Area received message from EOC to dispatch Bus Drivers at 1115 for pre-stage of zones A-J and at 1200 for evacuation of all zones. By 1119 all required Bus Drivers for pre-staging were dispatched and by 1235 for evacuation of remaining zones. All Bus Drivers were at the Transfer Points in time to support the evacuation. ,
The pre-staged Transfer Points were not
. contacted per procedures to begin dispatching of buses on their routes I hour after General Public notified. As a result of this, the Brookhaven
. Substation Transfer Point began dispatching Bus Drivers at 1200. The critique stressed the need to follow the procedure and wait I hour before dispatching buses. This waiting requirement stated in the procedures will be stressed in future training sessions and drills. Note that proper notification of Transfer Points occurred in the December 10 drill.
l Curbside pick-up was simulated for this i drill and the controllers provided names of individuals to the Transfer Point Coordinators at Shirley Mall (Refer to LERO Message Nos. 34-38).
The curbside pick-ups were radioed in to the Staging Area. This was successfully completed at 1350.
The Bus Dispatcher received message from EOC at 1400 to re-route Buses on routes H-1, I-1, and J-1. This information was not relayed to the Brookhaven Substation. The importance of transmitting this information will be stressed in future Training Sessions and drills. Re-routing information was properly transmitted at the December 10 drill. .
i Transfer Point Coordinators were dispatched to their points prior to the dispatching rder (at 1100) to support the Bus Driver Road Rally (Refer to Staging Area Objectives 13 and 14).
9
%. ,- ,- --y~,--,- - ,-.- -
Route Alert
. Drivers - Lead Traffic Guides received message of stron failure (Sirens #60 and #89) at 1024. Two Route Alert Drivers were
. dispatched at 1040.
In addition, the Lead Traffic Guides received message to dispatch Route Alert Drivers for Deaf Notification at 1204. Dispatching was completed by 1230.
These dispatching times were adequate.
The Route Alert Drivers phoned in upon completion of their routes to receive direction from the Lead Traffic Guides. Deaf Notification was completed by 1330 and siren failure notification was completed by 1130 for siren #89 and by 1210 for siren #60.
No time frame for completing a route is i
required. Lead Traffic Guides will be encouraged to dispatch. multiple Route Alert Drivers when they are available, to expedite the Route Alerting Process.
Road Crews - Lead Traffic Guides . received' messages to dispatch Road Crews at 1158. Road Crews were dispatched at 1205. This is a good time frame.
Road Crew #2004 vent to his location with a Traffic Guide Radio rather then sith a Road Crew radio. A Tratfic Guide was dispatched to location #2004 with the proper radio at 1230. This showed good response by the Staging Area.
Road Crew #2002 radioed in at 1315 to inform of Gravel Truck Accident. At 1320. EOC contacts Road Crews 2002,
.- 2003 and 2001 to respond to accident.
I Road Crew 2002 asks for heavy duty wrecker and indicates clearing of accident will take greater then 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. At 1342, EOC contacts Road Crew 2002 for status of impediment, Road Crew 2002 indicates no change and EOC l
contacts again at 1355. At 1356, Raad
~
Crew 2002 informs EOC that the 3 cars are cleared but road still blocked by gravel truck. At 1435, EOC contacts Road Crew 2002 to ask if heavy wrecker arrived. Road Crew 2002 indicated he will contact when it does. Road Crew 2002 contacts EOC at 1503 to inform accident has been cleared. j
' 1 Communications and response by the Road Crew were good. Objectives were met.
Evacuation Route Spotters - Lead Traffic Guides received message to dispatch Route Spotters at 1155. All Route Spotters were dispatched by 1205. This time is excellent:
Route Spotter 1007 contacts EOC to inform them of Traffic build-up on Route 25. EOC contacts Route Spotter 1007 at 1326 to proceed to the accident scene. Route Spatter arrives at <
accident at 1329. The EOC contacted Route Spotter '007 at 1400 to travel South on Grumman Boulevard to inform residents of new Bus Pick-up location.
The Route Spotter observed (1007) made frequent contact with the EOC (approximately every 15 minutes). This is good use of the Route Spotters and demonstrated good communications.
Objectives were met for the Route Spotters.
T.raffic Guides - The General Emergency was declared at -
1132. PARS of Evacuation of Zones A-S decided at 1149. Traffic Guide Posts to be manned sent to Riverhead at 1155. Pre-assigned Traffic Guides required for a 0-2 mile evacuation (32 of the 36 required) were dispatched by 1222. Note that TCPs 39, 34, 36 and
, 115 required for a 0-2 mile evacuation l were going to be manned however, due to the requirements of the scenario, the Traffic Guides were reassigned to other
=
_ ,m - . . ..- - - -- v-,,.-.-,__# % e.-3, .,-_--e y...,, - - -,y-_ .-<,_,,p, -
,e._. _y,,.re,. , , . . .w.y -- . -
TCPs. (Refer to LERO Message No.
26R). Remaining Traffic Guides were also dispatched by 1222. The 32 Pre-assigned Traffic Guides required for a 0-2 mile evacuation arrived at their - .ts (26 posts, excluding the four iLPs mentioned above. Also more than one Traffic Guide required at some posts) by 1310.- This time frame is less than adequate because some Traffic Control Posts were not manned within 1-hour of the time the EBS Message was aired (1155). Objective 11 was partially met for Riverhead. l All Traffic Guides were able to establish communication with the Staging Area and radioed in upon their arrival at their TCP.
TCP 10 radioed in the Gravel Truck Accident to the Riverhead Staging Area at 1307. He was given re-routing instructions from the EOC at 1328.
Procedures for re-routing were verbally demonstrated to the Riverhead Field Controller and were adequate.-
The Traffic Guides at TCPs 13 and 14 were contacted at 1430 to determine traffic flow at their posts since they ,
were near the Gravel Truck Accident.
The response to the Gravel Truck traffic impediment was good.
Two of the 11 TCPs observed had no -
Traffic Guides present. TCP 73 radioed in at 1240 that he was at the post but was not there at 1435 and TCP 15 radioed in at 1235 that he was at his post but was not there at 1440. After interviewing the Controller and the Traffic Guides at those posts, it was determined that the Traffic Guides were there parked at a location where the Field Contro11er'could not see tnem (i.e., Traffic Guide for TCP 73 was parked in a driveway).
These objectives were met by the Traffic Guides.
4 It should be pointed out that later Cn in the drill, the EOC decided to
, extend the evacuation to include zones P and S. Since only 1/2 of the field personnel were invited to this drill per the scenario, no additional personnel were available to respond to this extension. The responses to this extension were therefore simulated.
. December 10: Port Jefferson Transportation - Staging Area received a messa'ge from EOC to dispatch Bus Drivers at 1025 for pre-staging of zones A-J, K, L, M, N, 0, R and at 1258 to evacuate the above zones. By 1115 all required Bus Drivers for pre-staging were dispatched. No additional Bus Drivers were required to be dispatched for evacuation purposes. All Bus Drivers were at the Transfer Points in time to support the evacuation.
The Pre-staged Transfer Points were contacted at 1300 to inform when to begin the evacuation. This is adequate per procedures.
Curbside pick-up was simulated for this drill and the controllers provided names of individuals to the Transfer Point Coordinators at Miller Place and
. Norwood Avenues (Refer to LERO Messages 42-46). Miller Place radioed in their curbside pick-ups at 1400 for Van F1, 1430 for Van F2 and 1450 for Van F3.
This was immediately transmitted to the Bus Coordinator at the EOC at 1410, 1440 and 1450 respectively and given to the Home Coordinator. Norwood Avenue radioed in their Curbside pick-ups at
- 1315 for Van F4, Bus G and Van Q were not radioed in. This information for Van F4 was immediately transmitted to
- the Bus Coordinator at the EOC at 1320
. and given to th.e Home Coordinator.
- Although Norwood Avenue did not radio in for Bus G and Van Q, this portion of the drill was simulated. The purpose of this portion was to check the communication links which were adequate.
Re-routing for- buses was not necessary.
Transfer Point Coordinators were dispatched to their points prior to the dispatching order (at 0940 and 0943) to support the Bus Driver Road Rally (Refer to Staging Area Objectives 13 and 14).
Objectives 9 and 10 were met by the Port Jefferson Transportation Group.
Route Alert Driver - Lead Traffic Guides received message of Siren Failures (Sirens #9 and #29) at 0938. Six Route Alert Drivers were dispatched on these two routes (routes-divided among the Drivers) at 1003.
In addition, the Lead Traffic Guides received a message to dispatch Route
, Alert Drivers for Deaf Notification at 1305. Dispatching was completed by
, 1330.
The Route Alert Drivers phoned in upon completion of their routes to receive direction from the Lead Traffic Guides. Deaf notification was completed at 1420 for zone K and 1500 for zone F. Siren failure notification was completed at 1210 for siren #9 and 1350 for siren #29. No time frame for completing a route is required. ,
At 1245, the EOC notified the Staging Area to have the Route Alert Drivers re-notify the public for Siren Failures
- 9 and #29. This was not performed due to a lack of field personnel (only 1/2 of the required field workers were invited per the scenario). What would be done was discussed with the controller.
Thess objectives were met.
Road Crews - Staging Area received message to di: patch Road Crews 1250 for Road Crews 2009, 2011, 2012 and all tankers and 1255 for Road Crew 2010. All Road Crews were dispatched by 1325. This time frame is adequate.
l
i Road Crew 2010 was initially dispatched by the Staging Area at 1255 to the Duck Truck Accident. He was contacted at 1300 by the EOC and told to report to l accident. -Road Crew 2010 arrived at !
the accident at 1352 and reported to the EOC at 1400 that the accident had ,
been cleared. This time is less than -
adequate. It should be noted that the EOC did not dispatch a Road Crew when first notified of accident (at 1245)
! because at that time evacuation was not the PAR. The EOC assumed that prior to an evacuation recommendation, County Police would handle.this situation as part of their normal duties. Once the evacuation PAR was made at.1248, LERO responded to the accident by dispatching Road Crews at 1255.
Communications were establislied.
Objectives were partially met by the Road Crews. Reporting to an accident quickly, will be stressed in future training and drills.
Evacuation -
Route Spotters - Lead Traffic Guides received message to dispatch Route Spotter 1001 at 1030 and remaining Route Spotters at 1315.
Route Spotter 1001 was dispatched at 1045 and the others were dispatched by 1348. These tim'es are adequate.
EOC contacts Route Spotters 1001 at approximately 1230 to have him respond to Duck Truck acci~ dent. . Route Spotter arrives at scene at approximately 1245 and relays status of accident and
! requests a Road Crew. Continuous communication occurred between the EOC and Route Spotter 1001 until 1400 (when accident was cleared). Communications were good.
- Objectives were met for Route Spotters.
[
I
Traffic Guides _ The General Emergency was declared at 1202. PARS of evacuation of zones A-J, K, L M, N, 0, R made-at 1248. Traffic Guide Posts to be manned sent to Port Jefferson at 1258. Pre-assigned Traffic Guides required for a 0-2 mile evacuation (6) were dispatched by 1314. Remaining Traffic Guides were dispatched by 1345. The six preassigned Traffic Guides required for the 0-2 mile evacuation arrived at their 5 posts (TCP 5 requires 2 Traffic )
Guides) by 1346. This time frame is ;
adequate as it falls within 1-hour of j the time the EBS Message was aired '
(1257). Obje:tive 11 was met for Port Jefferson.
All Traffic Guides established communications with the Staging Area.
All TCPs observed by the Port Jefferson Field Controller had Traffic Guides at their posts when visited.
No re-routing was required for Port Jefferson Traffic Guides.
Patchoaue Transportation - Sta'ging Area received message from EOC to dispatch Bus Drivers at 1029 for Pre-stage of zones A-0, R and at 1257 to evacuate above zones. All Bus
! Drivers (Special and General Population) were dispatched by 1100 for pre-staging. No additional Bus Drivers were required to be dispatched for evacuation purposes. All Bus Drivers were at their Transfer Points in time to support the evacuation.
Pre-staged Special Population Bus Drivers returned to the Staging Area by 1120.. They were dispatched on their assignments by 1300.-
Y -
l The pre-staged Transfer Points were contacted at 1300 to inform when to
, begin evacuation. This is adequate per j procedures.
Curbside Pickup was simulated for the drill and the controllers provided names of individuals to the Transfer Point Coordinators at Brookhaven National Laboratory and Coram Plaza Shopping Center (Refer to LERO Hessage Nos. 42-46). The Brookhaven National Laboratory radioed in their curbside pick-ups at 1440 for Bus B, C, D and at 1445 for Van E. Coram Plaza radioed in their Curbside Pick-ups at 1455.
Patchogue Bus Dispatcher simulated this information being sent to the EOC due to it being near end of drill. The following through with information to the proper positions will be stressed and observed in future drills.
Re-routing of Buses was not necessary for Patchogue.
Transfer Point Coordinator were dispatched to the points by 1030 and declared their Transfer Points operational by 1105.
These object,1ves were met by the Transportatibn Group.
Route Alert Drivers - Lead Traffic Guides received message of siren failures (Sirens #19 and #40) at 0940. Two Route Alert Drivers were dispatched on these two routes at 0950.
In addition, the Lead Traffic Guides received message to dispatch Route Alert Drivers for Deaf Notification at
, 1313. Dispatching was completed by 1315.
These dispatching times are excellent.
Route Alert Driv ~ers phnned in up:n completion of their routes to receive direction from the Lead Traffic Guides. Deaf Notification was completed by 1422. Siren failure notification was completed at 1118 for Siren #19 and 1130 for Siren #40. No time frame for completing a route is required. Lead Traffic Guides will be encouraged to dispatch multiple Route Alert Drivers, when they are available, to expedite the Route Alerting Process.
At 1254, the EOC requested that Routes for Sirens #19 and #40 be re-run. Two other Route Alert Drivers were immediately dispatched (dispatch form indicates 1254). These routes were not completed by drill termination.
Objectives 9 and le were met by the Patchogue Route Alert Drivers.
Road Crews - Staging Area received message to dispatch Road Crews at 1310. All Road Crews were dispatched by 1312. This time frame is excellent.
Road Crew 2005 was contacted by the EOC at 1410 to report to the Cesspool Truck
. accident. They arrived at the accident at 1440 and reported per the scenario that accident would take over 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to clear. They were instructed by the EOC to remain at the location.
Communications were established with all Road Crews. Objectives 9 and 10 were met by the Road Crews.
Evacuation Route Spotters - Lead Traffic Guides received message to dispatch Route Spotters at 1020 and were dispatched by 1025. This time was adequate.
The EOC requested at 1305 that routes 1010 and 1011 were also to be patrolled. This was simulated by the Staging Area since no personnel were available (only 1/2 of the field workers were invitec for this drill per the scenario).
)
-O No Route Spotters were requested to respond to the traffic impediments.
Communications with the EOC was
, maintained by the Route Spotters.
These. objectives were met for the Route Spotters.
Traffic Guides - The General Emergency was declared at 1202. PARS of. evacuation of zones A-0, R made at 1250. The Traffic Guide
~
Posts to be manned sent to Patchogue at 1311. Pre-assigned Traffic Guides required for a 0-2 mile evacuation (21) were dispatched by 1325. Remaining Traffic Guides were dispatched by 1325 also. The 21 pre-assigned Traffic Guides required for a 0-2 mila evacuation arrived at their posts (13 posts; more than one Traffic Guide.
required at some posts) between 1324 and 1401 (TCP 77 did not arrive until 1447). Other than TCP 77, this time was adequate as they fall within 1-hour of the time the EBS Message was aired (1257). Objective 11 was partially met for Patchogue. The importance of arriving in a timely manner will be stressed to the Traffic Guide at TCP 77 at future training sessions and drills. In addition, TCP 126 did not radio in their time of arrival. The 4-importance of transmitting arrival times will be stressed in future drills and training sessions.
The field controller did not observe the times of arrival of Traffic Guides due to the lateness of the evacuation order and his requirements per the scenario, he observed TCP 64 only.
The Traffic Guide at TCP 64 radioed in the Cesspool Truck Accident to the Staging Area at 1353. This information was relayed to the EOC at 1400.
Re-routing information was transmitted to TCPs 63 and 64 from the EOC at 1417. .This response time is adequate.
- 35 -
Communications were established and maintained for all Traffic Guides and all transmitted their arrival at their TCPs by 1447, except for TCP 126
These objectives were met by the Traffic Guides.
Riverhead Transportation - Bus Dispatcher received message from EOC to dispatch Bus Drivers at 1040 for pre-stage of rones A-0, R and at 1257 for evacuation of the above zones. By 1116 all required Bus Drivers for pre-staging were dispatched. No additional Bus Drivers were required to be dispatched for evacuation purposes.
All Bus Drivers were at the Transfer Points in time to sup7 ort the evacuation. -
The pre-staged Transfer Points were contacted at 1257 to inform when to begin evacuation. This is adequate per-procedures.
Curbside pick-up was simulated for this drill and the controllers provided
, names of individuals to the Transfer Point Coordinator at Shirley Hall (Refer to LERO Message Nos. 42-46).
The names were radioed in to the Staging Area at 1400. This information was promptly relayed to the EOC at 1415. This time frame is adequate.
The Brookhaven Substation Transfer Point Coordinator received a message from EOC at 1345 to re-route Bus Route J-1.due to the Cement Truck traffic impediment. This information was adequately relayed to the Bus Drivers.
This is good communications and response.
Transfer Point Coordinators were dispatched to their points prior to the dispatching order (at 1030) to support the Bus Driver Road Rally (Refer to Staging Area Objectives 13 and 14).
All Transfer Points were operational by 1103. .
These objectives were met by the
- Transportation Group.
Route Alert Drivers - Staging Area received siren failure message at 0937. Lead Traffic Guides received message of siren failure (Sirens #99 and #107) at 1011. Two Route Alert Drivers were dispatched at 1018. The time delay between'the timeliness the Staging Area received the message and the time given to the Lead Traffic Guide is not adequate.
The importance of the timeliness of distributing information will be stressed in future training sessions and drills.
In addition, the Lead Traffic Guides received message to dispatch Route Alert Drivers for Deaf notification at 1315 for zones E, J. N and at 1400 for
. zones P and S. Route Alert Drivers were dispatched at 1326 for zones E. J,
, N and at 1415 for zones P and S. This
- time frame is adequate.
The Route Alert Drivers phoned in upon completion of their routes to receive direction from the Lead Traffic Guides. Deaf Notification was completed at 1440 for zone E and 1418 for zone J. Time did not permit for zones N. P and S to be completed.
l
Siren failure notification was completed at 1050 for Siren #99 and 1130 for siren #107. In addition, the EOC requested at approximately 1259 that the routes be run again for sirens
- 99 and #107. These new Route Alert Drivers were dispatched at 1258 and phoned in upon. completion of their routes at 1405 for siren #99 and 1406 for siren #107. No time frame for completing a route is required. Lead Traffic Guides will be encouraged to dispatch multiple Route Alert Drivers, when they are available, to expedite the Route Alerting Process.
All Route Alert Driver information was relayed to the Special Facility Evacuation Coordinator.
These objectives were met by the Route Alert Drivers.
Road Crews - Staging Area received message to dispatch Road Crews at 1309. All Road Crews were dispatched by 1315. This time frame is adequate.
The EOC contacted Road Crew 2004 at 1342 and Road Crew 2003 at 1328 to proceed to Cement Truck accident. Road Crew 2004 arrived at accident at 1345.
At 1350, Road Crew 2004 radioed in to the EOC that removal of impediment would take over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. He also requested another Road Crew. At 1405, Road Crew 2003 calls in to EOC, he had problems with his radio and went to Road Crew 2002 and radioed in from there. He is instructed to proceed to accident. Road Crew 2003 arrives at accident at 1423 and radios in to EOC.
At.l.400, the EOC contacts Road Crew 2001 to proceed to accident. At 1450 EOC contacts Road Crew 2004 to contact Road Crew 2001. At 1455, Road Crew 2004 contacts EOC to inform that he could not reach Road Crew 2001.
{
At 1500 EOC contacts Road Crew 2004 for status. Road Crew 2004 indicates clearing of accident will take another hour.-
Communications with Road Crews were established and adequately maintained with the EOC with the exception of Road Crews 2001 and 2003. However, Road Crew 2001 responded at 1339 to injest KI. The non-communication of Road Crews 2001 and 2003 was brought to the attention of the Emergency Preparedness
. group and will be observed in future drills.
Evacuation Route Spotters - Lead Traffic Guides received message to dispatch Route Spotters at 1021 and were dispatched at 1025. This time frame is excellent.
Route Spotter 1009 called in Cement Truck accident at 1305 to the EOC.
Route Spotter 1007 contacted the EOC at 1357 to report on his traffic conditions. At 1404, Route Spotter 1009 contacts the EOC to inform of Road Crew 2004 arrival.
Communications was maintained by the Route Spotters and EOC on a regular basis. These objectives were met.
Traffic Guides - The General Emergency was declared at 1202. PARS of evacuation of zones A-0, R made at 1250. The Traffic Guide Posts to be manned sent to Riverhead at 1309. Pre-assigned Traffic Guides required for 0-2 mile evacuation (26 of the 36 required) were dispatched by 1327. Note that TCPs 3, 7, 128, 115, 127, 73, 108, 39, 36 and 62 required for a 0-2 mile evacuation were going to be manned, however, due to the requirements of the scenario, were re-assigned to other TCPs. (Refer to LERO Message No. 30R). Remaining Traffic Guides were also dispatched by 1327. The 26 preassigned Traffic l
l
Guides required for a 0-2 cile evacuation arrived at their posts (20 Posts, excluding the 10 TCPs mentioned above. Also, more than one Traffic Guide required at some costs) by 1415.
. This time frame is less in adequate because some Traffic Coni 'J Posts were not manned within 1-hour or the time the EBS Message was aired (1257).
Objective 11 was partially met for Riverhead.
All Traffic Guides were able to establish communications with the Staging Area and radioed in upon their arrival at the TCP, with the exception of TCP 87. His radio is being checked by the Emergency Preparedness Group and will be observed in future drills.
The two TCPs observed by the Field Controller had Traffic Guides at their posts when visited.
TCPs 16, 15, 29 and 19 were contacted by the Staging Area on re-routing at 1331 due to the Cement Truck accident.
The implementation of the re-routing was simulated by the Traffic Guide at TCP 16 and proved adequate.
Objectives 9 and 10 were met by the Traffic Guides.
Stacina Area Obiective 12 December 2 &
i December 10: Port Jefferson. Patchoaue and Riverhead Field Controllers observing various locations (i.e.,
Transfer Points. TCPs) reported field workers reading their dosimeters every 15 minutes and aware of their usage and limits. New LERO Badges were distributed to field workers containing pertinent radiological information. Field workers were briefed on the use of
- these badges and field workers were urged to refer to these badges when necessary.
All field workers were notified when to injest KI and don protective clothing.
This objective was adequately met.
December 2: Port Jefferson A controller initiated LERO Message No. 46 at- .
approximately 1430 stating that TCPs 4, 5, 6 and 86 were reporting 4 Rem readings. The EOC responded quickly reporting at 1437 to have these Traffic Guides proceed to the ENDF. No replacements were dispatched because it was late in the scenario nor were higher doses authorized. The response time was adequate. '
, December 10: Port Jefferson A controller initiated LERO Message No. 40 at 1405 to the Bus Dispatcher simulating that personnel at the Miller Place Transfer Point were reporting 4 Rea readings. The EOC responded quickly and by 1430 reported that the Director of Local Response has authorized readings to 10 Rem. This response time is adequate and proper procedures were followed. (Refer to EOC General Comments for December 10 on the EOCs response to this message).
Patchoaue ,
O'ne road crew member of the two man crew for Road Crew 2005 was not observed to read his dosimeters every 15 minutes. The importance of reading his dosimeters was .
stressed at the location.
Stacina Area Obiectives 13 and 14 December 2 &
December 10: Port Jefferson. Patchocue and Riverhead Make-up sessions for Phase II of the Bus Driver Driving Instruction Training were held at both drills. These make-up sessions were Phase II of LILCO's response to a i deficiency cited in the FEMA Post Exercise Assessment for the February 13, 1986 Exercise regarding Bus Drivers
- who were unable to find their assigned locations. The purpose of these sessions was to familiarize LERO Bus Drivers with their appropriate Transfer Points and the c new Bus Company yard - Suburbia Bus Corp. in Bohemia.
l In addition, Bus Drivers from the Riverhead Staging Area were required to travel to Baumann and Sons Buses. Inc.
in Westhampton.
t 1
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As you may recall, Phase I of the Bus Driver Driving Instruction Training required the Bus Drivers to travel to seventeen (17) Bus Company yards. Upon the conclusion of Phase II, our resplanse will be completed since LERO Bus Drivers will have visited all LERO-contracted Bus Company yards and-their appropriate Transfer Points by following driving instructions similar to those to be used in an actual emergency.
Refer to Section 4.4 of both scenarios for further details. For both drills, thirty-eight (38) Bus Drivers participated out of the 66 Bus Drivers scheduled
- resulting in a 58% attendance rate.
The sessions were incorporated as part of the LERO drills scheduled for these days. The Bus Drivers involved in the make-up Road Rallies, instead of performing their normal LERO functions, were di.spatched to travel to all Transfer Points coinciding with their Staging Areas and to the Suburbia Bus Corporation in Bohemia. As mentioned above, Riverhead Bus Drivers 3 additionally had to travel to the Baumann & Sons Buses, Inc. in Westhampton. Only Riverhead Bus Drivers were required to travel to this yard since only five (5) buses are contracted at this yard and will most often be assigned to the Riverhead Staging Area in an emergency.
Upon arrival at their Staging Areas, Bus Drivers signed-in and received their dosimetry. At their drill briefings, Bus Dispatchers briefed the Bus Drivers on the specifics of their assignments and assigned a drill deadline time of 1500 whereby all Bus Drivers were instructed to proceed to the ENDF to hand in their i equipment, driving instructions and verification cover sheets.
j Make-up Bus Drivers were dispatched by the
! Transportation Controllers (one per car) from their Staging Area. Before leaving, the Bus Drivers received the Session's Driving Instructions II, the Session's Verification Cover Sheet II (inserted into the Driving Instruction Book), and a box lunch.
Transfer Point Coordinators were assigned to their i Transfer Points to perform as controllers for'the session. The Transfer Point Coordinators were briefed by the Bus Dispatchers of their responsibilities. Two
- other controllers were assigned to the two Bus Company yards.
Transfer Point Coordinators / Controllers set up at their Transfer Points as normal and the Bus' Company controllers set up outside the Bus Company yard at an area void of any complications. All placed orange cones near their location. Upon arrival of the Bus Drivers, the controllers hole-punched, initialed and wrote the time of the Bus Driver's arrival on each Bus Driver's
. Session Verification Cover Sheet II. Note that each
. controller had either a heart, diamond, club or spade-shaped hole-punch to avoid unauthorized marking of the cover sheet.
After traveling to all of their assigned locations, Bus Drivers then traveled to the EHDF for monitoring and possible decontamination. Also at the EHDF, Bus Drivers handed-in their driving instructions and verification cover sheets.
For the December 10 drill, one (1) Bus Driver from the Patchogue Staging Area failed to locate the Suburbia Bus Ccrp. in Bohemia and arrived at the EWDF with Suburbia not verified.
In addition, the Bus Controller at Baumann & Sons Buses, Inc. in Hesthampton was not permitted to remain at the location since the yard is located on Suffolk County property. All Riverhead Bus Drivers participating in the December 10 make-up session will be credited for this location as all indicated they traveled to the location, but no controller was there. Refer to memorandam from Bruce P.M. Kobel, dated 12/11/86, "Baumann Situation" for further details.
These sessions were the last to be held and concludes LILCO's initial response to the Bus Driver deficiency sited by FEMA. A final report summarizing this entire effort will be issued at a later date.
For the bus drivers who had already completed Road Rally training, the final response to this deficiency was initiated for these drills. All Bus Drivers who previously participated in the Bus Driver Driving Instruction Training Sessions were involved in the Bus Driver Maintenance System as described below.
l LERIO instituted a maintenance system to ensure that Bus Drivers are assigned to different Bus Company yards and Transfer Points during these and future drills and are not assigned to the same locations each time. This maintenance system consisted of the four steps outlined below:
- 1. During pre-drill preparation, LERIO arranged for buses to be available at only a few of the Bus Company yards per drill. For these drills, Suburbia Bus Corp. in Middle Island, Baumann & Sons in Bohemia and Westhampton, and United Bus Corp. in Coram. The yards will be rotated for each subsequent drill to ensure that Bus Drivers have the opportunity to visit all the yards and will not be driving to the same yard each drill.
- 2. Bus Dispatchers were told not to call for volunteers for assignment to a specific Bus Company yard or Transfer Point. This eliminated the problem of Bus Drivers familiar with a certain location volunteering for assignment to that location.
- 3. A computer program is being developed to track the E progress and validity of the Maintenance System.
After each drill, LERIO collected the Bus / Van Dispatching Forms (Attachment 7 of OPIP 3.6.4) which were initialed and hole-punched by controllers at the above Bus Company yards. This data will be input into a spreadsheet program.
- 4. This computer report will be reviewed periodically to ensure the effectiveness of the system and to allow for immediate resolution of any problems, should they occur.
i ENC Obiettive 1 (LERO Oniv)
December 2: LERO ENC members were told to report at 0800 with all required staff present by 0845. Clerical assistance normally supplied by the EOC was not provided per the drill requirements.
December 10: LERO ENC members were told to report at 0800 with all required staff present by 0830. Clerical assistance normally supplied by the EOC was not provided per the drill requirements.
ENC Obiective 2 (LERO Oniv)
December 2 &
December 10: The ENC would contact the EOC and the EOC would maintain staffing of the ENC through rosters. This was performed at both drills. This objective was met.
ENC Obiective 3 (LERO On1v)
December 2: Six simulated media briefings were held and were adecuate and timely. Presentations were understandable and clear.
Maps and other visual aids were available. It should be noted that the briefing of 1155 was not actually held because of non-LERO related problems with the briefing room and was merely stated.as being held. This objective was met.
December 10: Four of the five simulated media briefings were held and were adequate and timely. One exception is the first briefing which was not held until 1000 while the Alert was declared at 0808. This delay was a result of LILCO personnel (onsite) r.ot arriving until later since they were
.not pre-staged. LERO, however, was ready sooner. This objective was met.
ENC Obiective 4 (LERO Oniv)
December 2 &
December 10: This function was adequately simulated as no other agencies.
participated in these drills per the scenario. This objective was met.
ENC Obiective 5 (LERO Oniv)
December 2 &
December 10: Rumor control was established and performed adequately for both drills. The response to questions was performed in a timely manner (average of 15 minutes).
l ENC Obiective 6 (LERO Oniv)
December 2 &
- December 10
- For both drills, only a portion of the ENC was activated l- due to outside commitments of the Holiday Inn. However, i space was adequate for the area activated. Because of this, the telecopier was located in the hallway making the telecopying of information inconvenient. However, this did not hinder ENC operations.
LERO News Release Paper ran out during the drills. This i
) was brought to the attention of the Emergency Preparedness Stiff and an adequate supply of this paper will be available. I" ENC Obiettive 7 (LERO Oniv) ;
December 2 & .
December 10: This objective was not observed by the ENC LERO
. Controller. This is not.a LERO concern but an onsite ;
concern and will be removed as a LERO objective for further drills, i
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ENC Obiective 8 (LERO Oniv) ,
December 2 & '
3 1 December 10: The ENC copying capabilities were adequate for both .- l drills. No problems ytre observed. This objective was met.
, t .
8,
' ENC Obisctive 9 (LERO Oniv) [ ,
December 2 & '
s December 10: Two LERO Spokesper' sons were used for both drills. The t reason was that one'was being trained by the other far this position as this was the first dr! for this LERO " t Spokesperson. In-light of this,dhe new LERO Spokesperson -
; performed his job adequately and effectively.
q .,. 8 . s > ( \ E t i
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Areas Reauirina Corrective Action (ARCA) The following is a summary of LERO's response to the.ARCAs cited by FEMA for the February 13. 1986 Exercise. Refer to Part I of Attachment 1 of SNRC-1276 for details on the ARCAs. LQC-L December 2: Notification of FEMA was performed to a simulated' phone number by the Director. Refer to LERO Message No. 4 for the simulated phone number. December 10: Notification of FEMA was performed to a simulated phone number by the Director. Refer to LERO Message No. 5 for the simulated phone number. LQC-1 December 2: Notification of the LIRR was performed to a simulated phone number for this drill by the Evacuation Coordinator. Refer to LERO Message No. 4 for the simulated phone number. December 10: Notification of the LIRR was performed to a simulated phone number for this drill by the Evacuation Coordinator. Refer to LERO Message No. 5 for the simulated phone number. EOC-4 December 2 & December 10: Modifications were completed and reviewed with DOE prior to these drills. The new status boards were used in both drills. (Refer to memorandum to LERO File from D. Dreikorn, dated 1/9/87, " Meeting with DOE" for Status Board discussions). EOC-5 December 2 & December 10: The reporting of this data was not observed for these drills as DOE was not participating. 4 4
IQC-fi December 2 & December 10: The DOE did not participate in these drills thus no field data was extrapolated. During a meeting with the DOE (Refer to memorandum from D. Dreikorn, dated 1/9/87,
" Meeting with DOE") this matter was discussed and it was agreed that any extrapolated field data by DOE RAP will be indicated as such when reported to the EOC. Simulated field data (actual) was presented to the RHC by the controller and doses were projected based on this data.
These projected doses were placed in the appropriate columns. I.QC-1 December 2 & . December 10: No observation was made at either drill regarding the misstating of PAGs by the Health Services Coordinator. The corrective actions taken last spring was effective. EQC-E Not-Applicable EQC 1 December 2 & Dacember 10: The expedited dispatching of field personnel to respond to traffic impediments was not part of these scenarios. It will be practiced in future scenarios. EOC-10 Not-Applicable EOC-11 Throuah 15 Not-Applicable. Neither School Bus Drivers nor Ambulance /Ambulette Drivers participated in these drills. IE=1 December 2 & December 10: Both the EPZ Map and ECL Status Board were available at the ENC and were utilized in both drills.
MC:1 December 2: News Releases #1 and #2 were posted with minor cross-outs indicated on the releases. This was due to the computer not being in operation at the beginning of the drill. The remaining press releases were properly issued using the computer. December 10: All press releases were issued by the computer and did nat contain any marks which could add to confusion. , Port Jefferson-1 9 December 2 & December 10: New LERO badges containing radiological and dosimetry information were given to field personnel for both drills. Field members were instructed on the use of these badges. Field members observed by controllers were aware of their dosimetry and radiological requirements. Patchoaue-2 Throuah 5 December 2 & December 10: The new security procedure was implemented for these drills and security was observed to be adequate. Patchoaue-7 December 2 & December 10: The new LERO badges issued to field workers contain job specific information as well as the radiological and dosimetry information mentioned earlier. The Traffic Guide badges state that the Traffic Guide should inform evacuees to listen to the EBS station for latest information on the emergency. All field per:onnel were adequately briefed on the use of these badges. Patchoard-g December 2 & December 10: Field personnel responding to the road impediments for both drills maintained adequate communication with the EOC regarding the impediment. Any requests for additional support was transmitted to the EOC from the field. An example of this is evidenced by, on December 2, Road Crc'. 2002 out of Riverhead radioing in to the EOC at 1335 requesting a heavy wrecker to assist in removal of the gravel truck impediment. I
A Patchoaue-9 December 2 &
. December 10: The proper and accurate relaying of information from the Staging Area by the Transfer Point Coordinator to-the Bus Drivers was observed during both drills. This was evidenced by the relaying to Bus Drivers to don protective clothing, take KI and when to begin the evacuation routes.
A specific example to illustrate this was the Brookhaven Substation Transfer Point Coordinator accurately explaining ) the rerouting of zone J-l to the Bus Drivers during the ' December 10 drill. The re-routing instructions were given to the Transfer Point Coordinator by the EOC. Patchoaue-10 December 2 &
- - December 10
- As of the date of this report, more detailed maps for the non-institutionalized mobility-impaired pick-ups have not been developed. The same maps were used for these drills ,
that were used for the exercise. More detailed maps will be developed in the near future. Patchoaue-11 December 2 &
- December 10
- Administrative Support personnel assisted in the dispatching of Special Population Bus Drivers for both drills. For the December 10 drill, a request came in from the EOC to the Special Population Bus Dispatcher at 1034 to pre-stage an additional bus for the evacuation of the Millcrest Adult Home. This Bus Driver was dispatched at 1120 to the home. The Bus Dispatcher waited for the return of pre-staged Special Population Bus Drivers who were dispatched at 1030. This is a good response for two reasons: 1) For the ARCA (resulting from February 13 Exercise), it took 40 minutes for a bus to be dispatched to a Bus Company, pick-up a bus, then proceed to the school.
For December 10, the Bus Driver proceeded directly to the Millcrest Adult Home because he already had the bus. Even though it took 46 minutes to dispatch the bus, it would arrive at the home well before the bus which wasn't pre-staged. 2) An evacuation wasn't declared until 1250, therefore this bus would already be at the'home to assist if an evacuation was called. ,
Patchoaue-12 December 2 & December 10: The briefings held by the Bus Disnatchers at Patchogue did not contain any misleading information. As stated previously, new LERO badges containing radiological and dosimetry information'were used for both drills. The Bus Dispatchers adequately and correctly briefed Bus Drivers on the use of these badges and the information on them. Patchocue-13-16 December 2.& December 10: New LERO badges containing radiological and dosimetry information, including the use of KI and authorization of higher dose limits, were given to field personnel for both drills. Field members were adequately briefed on the use of these badges. Those field members questioned by controllers were aware of these requirements. Bly1-Sead-l December 2 & December 10: Times of the update were properly placed on the status-boards during both drills. (Refer to Staging Areas Objective 7 for further information). , Bjverhead-3 December 2 & December 10: The Brookhaven Substation Transfer Point was used at both drills. No problems were observed,~although weather was not inclement during the drills.
/
Riverhead-4 Throuah 6 December 2 & December 10: New LERO badges containing radiological and dosimetry information, including the use of K1 and authorization of higher dose limits, were given to field personnel for both drills. Field members were adequately briefed on the use of these badges. Those field members observed by controllers were aware of these requirements.
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Recention Center-1 Not Applicable. The new Reception Centers were not activated for these drills as they are still .in the construction phase. Conarecate Care-1 Not Applicable. Congregate Care Facilities did not participate in these drills per the scenario.
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n . Markovich Attachment cc: B. R. McCaffrey w/ Attachment C. A. Daverio w/ Attachment V. M. Palmiotto w/ Attachment LERO File w/ Attachment i I l
m . . .
' ATTACHMENT 1 . LILCO Emergency Preparedness Drill Scenario Scenario No. 8A - Rev. 1 1.2. LERO OBJECTIVES A. Emergency Operations Center (E0C)
- 1. Demonstrate the sbility to receive initial and follow-up emergency notifications.
- 2. Demonstrate the ability to activate the Local Emergency Response Organization (LERO) EOC in a timely manner.
- 3. Demonstrate through rosters, the ability to maintain l staffing in the LER0 EOC on a 24-hour basis.
- 4. Demonstrate that the LER0 EOC has adequate space, equipment, and supplies to support emergency operations.
- 5. Demonstrate that the LERO can establish appropriate .
I communication links, both primary and backup systems (communication with the State and county via RECS to be simulated).
- 6. Demonstrate that the LERO EOC has adequate access control and that security can be maintained.
- 7. Demonstrate that messages are transmitted in an accurgte and timely manner, messages are properly logged, that status boards are accurately maintained and updated, that frequent and appropriate ;riefings are held, and that incoming personnel are briefed.
- 8. Demonstrate that the appropriate official is in charge and in control of an overall coordinated response including decisions on protective action recomendations.
~
- 9. Demonstrate the organizational ability necessary to effect en early dismissal of schools within the 10-mile EPZ.
- 10. Demonstrate the ability to prepare and implement EBS in a
! timely manner (i.e., within 15 minutes after command and l control decision for implementation of protective action recomendations).
- 11. Demonstrate the ability to assess the effect of road impediments upon evacuation traffic and develop and implement timely response actions. These actions may include rerouting and the broaocast of an associated EDS message, as necessary.
1-6
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_.w., ATTACH 1ENT 1 F ~ LILCO Emergency Preparedness Drill Scenario Scenario No. 8A - Rev. 1 B. Emergency News Center (ENC)
- 1. Demonstrate the ability to activate LERO furetions at the !
ENC in a timely manner.
- 2. Demonstrate through rosters the ability to maintain
- . staffing of LERO functions at the ENC on a 24-hour basis.
- 3. Demonstrate the ability to brief the media in a clear accurate, and timely maner.
.4. Demonstrate the ability to share information with other agenc_fes at the ENC prior to its-release.
- 5. Demonstrate the ability to establish and operate rumor control in a coordinated manner.
6.. Demonstrate that the ENC has adequate space, equipment, and supplies to support emergency operations.
- 7. Demonstrate that the ENC has adequate access control and that security can be maintained.
- 8. Demonstrate that the ENC has adequate reproduction capabilities to support rumor control and media briefing activities.
- 9. Demonstrate the effective use cf the LERO spokesperson to present timely and accurate information to the media.
4 C. Staging Areas
- l. Demonstrate the ability to receive emergency notifications.
- 2. Demonstrate the ability'to activate the staging areas in a timely manner.
, 3. Demonstration through rosters, the ability to maintain staffing at the staging areas on a 24-hour basis. l 1-7 l l
~ , ATTACHMENT 1 __
N LILC0
- Emergency Preparedness Drill Scenario Scenario No. 8A - Rev.1
- 4. Demonstrate that the staging areas have adequate space, parking area, equipment, and supplies to support emergency operations. 1
- 5. Demonstrate that the staging areas can establish '
F ' appropriate communication links with the LERO EOC and field personnel .using both primary and backup systems.
- 6. Demonstrate that the staging areas have adequate access control and that security can be maintained.
- 7. Demonstrate that messages are transmitted in an accurate and timely manner, messages are properly logged, that status boards are accurately maintained and updated, that appropriate briefings are held, and that incoming personnel are briefed.
8. Demonstrate that the appropriate official is in charge and in control of an overa.1 response assigned to the staging area.
- 9. Demonstrate the ability to dispatch to and direct emergency -
workers in the field.
- 10. Demonstrate the ability to communicate with all appropriate locations, organizations, and field personnel. ,
- 11. Demonstrate the ability to assign Traffic Guides to Traffic Control post'. within the two mile EPZ and to dispatch traffic guides to Traffic Control Posts in a timely manner at the appropriate, time.
- 12. Demonstrate knowledge on the part of emergency workers of dosimetry and Potassium Iodide usage procedures and the ,
' procedures for authorization of radiation exposures above j permissable Ifmits.
- 13. Continue bus driver training to ensure bus drivers are familiar with allius yards and transfer points.
- 14. Institute the Bus Driver Maintenance System to ensure LERO Bus 9 rivers do not continually travel to the same Bus Company yards and Transfer Points. In addition, these drills will serve as a make-up for Phase II of the Bus Drivers Driving Instruction Manuals.
i l 1-8 1
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b i-ATTACHMENT 10 l i
g/Ed_'O LONG ISLAND LIGHTING COM PANY SHOREHAM NUCLEAR POWER STATION p.o. sox sie. NonvM COUNTRY Ro AO e WACING RtygR, N,y.11792
. 1 JOHN 0. LEONAAD. J4
. ......... - a ...
SNRC-1269 JUN 2 01986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Submittal of LILCO's Response to the FEMA Post Exercise Report For Shoreham . Emergency Exercise of February 13, 1986 Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 F
Dear Mr. Denton:
On April 30, 1986 the NRC Region I forwarded to LILCO the FEMA Region II Post Exercise Assessment for the Shoreham Emergsney Exercise held on February 13, 1986, along with a request for LILCO's response. This assessment identified five deficiencies and 38 Areas Requiring Corrective Action (ARCA). LILCO's response to the FEMA assessment, appropriate remedial actions, and a schedule for implementation are detailed in Enclosure 1. LILCO believes that these actions, when complete, will enable the NRC to conclude, with reasonable assurance, thalt appropriate measures can be taken to protect the health and safety of the ! public living in the Shoreham vicinity in the e: vent of a radiological emergency. / 4 LILCO is issuing, under separate cover, Revision 7 of the SNPS Local Offsite Radiological Emergency Response Plan and Procedures to resolve those deficiencies identified by the FEMA exercise casessment requiring plan and/or procedure changes. Wo ask that you cause a request to be made to FEMA,' pursuant to the NRC-FEMA Memorandum of Understanding, for an expedited review of LILCO's response to the FEMA Exercise Assessment. To this ond, we are forwarding under separate cover sixteen (16) copies directly to members of the RAC.
son-ut v - Pcg3 2 Should you have any questions, please contact this office. l y John D. Leonar
' YA' f . / .
Jr Vice President - uclear Operation CAC:ck Enclosures cca J. A. Berry R. Caruso/R. Lo O l l l l l l l t t O l e.
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- Q-nu.AIED CORK @N 00f.KETED USNRC March 20, 1987 1R MM 23 PS :24 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION FF E Of M M 1 Before the Atomic Safety andLicensinoBoafd NC
)
In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5
) (EP Exercise)
(Shoreham Nuclear Power Station, ) Unit 1) )
)
CERTIFICATE OF SERVICE I hereby certify that copies of DIRECT TESTIMONY OF WILLIAM LEE COLWELL, DEPUTY INSPECTOR PETER F. COSGROVE, PHILIP EVANS, CHARLES B. PERROW, FORD ROWAN, LIEUTENANT JOHN W. STREETER, JR., AND HAROLD RICHARD ZOOK ON BEHALF OF SUFFOLK COUNTY REGARDING CONTENTION EX 50 -- TRAINING OF OFFSITE EMERGENCY RESPONSE PERSONNEL, and the Attachments thereto, have been served on the following this 20th day of March 1987 by U.S. mail, first class, except as otherwise noted. John H. Frye, III, Chairman
- Dr. Oscar H. Paris
- Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Frederick J. Shon* William R. Cumming, Esq.*
Atomic Safety and Licensing Board Spence W. Perry, Esq. U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C. 20555 Federal Emergency Management Agency 500 C Street, S.W., Room 840 Washington, D.C. 20472
\
(*. N Anthony F. Earley, Jr., Esq. Joel Blau, Esq. General Counsel Director, Utility Intervention Long Island Lighting Company N.Y. Consumer Protection Board 175 East Old Country Road Suita 1020 Hicksville, New York 11E01 Albany, New York 12210 Ms. Elisabeth Taibbi, Clerk W. Taylor Reveley, III, Esq.* Suffolk County Legislature Hunton & Williams Suffolk County Legislature P.O. Box 1535 Office Building 707 East Main Street Veterans Memorial Highway Richmond, Virginia 23212 Hauppauge, New York 11788 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm. 195 East Main Street 1717 H Street, N.W. Smithtown, New York 11787 Washington, D.C. 20555 Mary M. Gundrum, Esq. Hon. Michael A. LoGrande New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York. 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, Esq. Fabian G. Palomino, Esq. Suffolk County Attorney Special Counsel to the Governor Bldg. 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway State Capitol Hauppauge, New York 11788 Albany, New York 12224 Richard G. Bachmann, Esq.* Stephen B. Latham, Esq. Myron Karman, Esq. Twomey, Latham & Shea Charles A. Barth, Esq. 33 West Second Street George E. Johnson, Esq. Riverhead, New York 11901 U.S. Nuclear Regulatory Comm. Office of General Counsel Washington, D.C. 20555
h David A. Brownlee, Esq. Mr. Jay Dunkleburger Kirkpatrick & Lockhart New York State Energy Office 1500 Oliver Building Agency Building 2 Pittsburgh, Pennsylvania 15222 Empire State Plaza Albany, New York 12223 Lawrence Coe LanpKer KIRKPATRICK & LOCKHART 1800 M Street, N.W. South Lobby - 9th Floor Washington, D.C. 20036-5891
- By Hand l
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