ML20204B726

Transcript of Lilco Testimony on Contention Ex 50.* Testimonies of DM Behr,Ca Daverio,Me Goodkind,Mk Lindell, Ds Mileti,Ed Pursell & Ja Weismantle Re Contention Ex 50. W/Certificate of Svc.Related Correspondence

ML20204B726
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/20/1987
From:	Behr D, Daverio C, Goodkind M, Lindell M, Mileti D, Pursell E, Weismantle J LONG ISLAND LIGHTING CO.
To:	Atomic Safety and Licensing Board Panel
References
CON-#187-2897 OL-5, NUDOCS 8703250137
Download: ML20204B726 (200)

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{{#Wiki_filter:- - - - - - - ) 2891 pasm DOCMETED USNRC 1r/ MAR 23 PI2:30 f0CYT h 5 bYI BRANCH UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board } in the Matter of ) ) ) LONG ISLAND LIGi'. TING COMPANY ) Docket No. 50-322-OL-5 ) (EP Exercise) (Shoreham Nuclear Power Station, ) Unit 1) ) ) LILCO'S TESTIMONY ON CONTENTION EX 50 ) s Hunton & Williams ) 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 ) March 20,1987 0703250137 8703po COM t l'Dil ADOCK 00000322 1 PDft J )

r- ) UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ) Before the Atomic Safety and Licensing Board In the Matter of ) ) ) LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5 ) (EP Exercise) (Shoreham Nuclear Power Station, ) Unit 1) ) LILCO'S TESTIMONY ON CONTENTION EX 50 ) Hunton & Williams ) 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 ) March 20,1987 l ? ? l t

) 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION D Before the Atomic Safety and Licensing Board ] In the Matter of ) ) LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5 ) (EP Exercise) (Shoreham Nuclear Power Station. ) Unit 1) ) J LILCO'S TESTIMONY ON CONTENTION EX 50 3 1. Q. Please state your name and business address. A. (Behr] My name is Dennis M. Behr. My business address is The Behr Con-sulting Group, Inc.,366 Veterans Highway, Commack, NY 11725. l] l [Daverlo] My name is Charles A. Daverlo. My business address is Long Island Lighting Company, Shoreham Nuclear Power Station, Wading River, NY 11729. (Goodkind] My name is Mary E. Goodkind. My business address is Impell Corporation,2345 Waukegan Road, Hannockburn,IL 60015. 'O (Lindell] My name is Michael K. Lindell. My business address is School of Psychology Georgia Institute of Technology, Atlanta, GA 30332. i O (Mileti] My name is Dennis S. Mileti. My business addre.a is Department of Sociology, and/or !!azards Assessment Laboratory, Colorado State Uni-versity, Fort Collins, CO 80523. O O

) 2-(Pursell] My name is Elliott D. Pursell. My business address is Human Y Resource Systems,219 Pollock Street, New Bern, NC 28560. (Weismantie] My name is John A. Weismantle. My business address is ) Long Island Lighting Company,1660 Walt Whitman Road. Melville, NY 11747. 2. Q. Please summarize your professional qualifications relating to Contention ) EX50. A. (Behr] I am a principal in The Behr Consulting Group which provides con-sulting services for Long Island Lightini' Company ("LILCO") on emergency ) planning issues particularly as they re; ate to the training program for the Local Emergency Response Organization ("LERO") workers. My profession-al qualifications are being offered into evidence as part of the document ) entitled " Professional Qualifications of LILCO Witnesses on Exercise Con-tentions." My f amiliarity with the lasues raised in Contention EX 50 stems primarily from my work as a consultant with The Behr Consulting Group ) and with my previous employer, Impell Corporation. Through both of those entitles I have worked on developing and implementing the training pro-gram for LERO workers. Most recently, my work has centered on devel- ) oping the changes in the LERO training program that are directed at reme-dying the items raised in the " Post-Exercise Assessment: February 13, 1986 Exercise of the Local Emergency Response Organization (LERO), as specified in the LILCO Transition Plan for the Shoreham Nuclear Power Station, New York April 17,1986"(" Post-Exercise Assessment"). l In addition, I have participated in a number of Federal Emergency Management Agency (" FEMA") exercises for other power plants. This l experience provides me with a basis to compare the performance of LERO again*t the performance of other offsite organizations in FEMA exerciscs. l [

- (Daverio] I am the Assistant Department Manager of the Nuclear Operations Support Department for LILCO. My professional qualifications are being offered into evidence as part of the document entitled "Profes-sional Qualifications of LILCO Witnesses on Exercise Contentions." My ) familiarity with the lasues raised in Contention EX 50 stems primarily f rom my work in developing and implementing both the Shoreham Nuclear Power Station Local Offsite Emergency Response Plan (the "LILCO Plan") and the ) training program for LERO, from my participation as Lead Controller for LERO in the February 13, 1986 Exercise, and from my prior testimony on the LERO training program. (Goodkind] I am a consultant with Impell Corporation. My professional qualifications are being offered into evidence as part of the document enti-3 tied " Professional Qualifications of LILCO Witnesses on Exercise Conten-tions." My familiarity with the issues raised in Contention EX 50 stems from my 15 years of experience as a consultant to the nuclear power indus-h try. That experience includes exerclae evaluation as a FEMA observer at eight offsite exercises, development of emergency plan procedures and training, exercise participation as a controller, and preparation of interim 3 finding reports with FEMA. I am a certified safety professional with expe-rience in preparing and conducting training for emergency response per-sonnel. J (Lindell] 1 am a visiting Associate Professor of Psychology at the Georgia Institute of Technology. My professional qualifications are being offered into evidence as part of the document entitled " Professional Qualifications 3 of LILCO Witnesses on Exercise Contentions." My familiarity with the r3 l

). 4 issues raised by Contention EX 50 stems primarily from my knowledge of D the theoretical and empirleal literature on emergency behavior and organi-zational behavior, from my own research, and from my experience with the NRC in evaluating radiological emergency response plans and full scale D-emergency exercises, and conducting inspections of emergency response facilities, in partleular, I have conducted studies for the NRC and DOE on t the staffing of emergency organizations and the design of facilities and D equipment for emergency organizations. Finally, I have developed an emergency response plan for a chemical company and have served as a r t trainer in short courses on radiological preparedness. 3 (Mileti] I am a Professor of Sociology at Colorado State University. My professional quallfloations are being offered into evidence as part of the O document entitled " Professional Quallfloations of LILCO Witnesses on Exer-clae Contentions." My familiarity with the issues raised by Contention EX 50 stems primarily from my knowledge of the theoretical and empirical 3 literature on the emergency behavior of organizations and organizational behavior in general, from my own research, and from my prior work with and testimony about the LILCO Plan. In particular,I have investigated the O behavioral aspects of the Three Mile Island Accident, studied the behavior l of complex organizations in emergencies and disasters, and conducted, with others, a detailed theoretical and empirical review for the Nuclear Regula-O tory Commlaston of the factors which affect and determine organizational effectiveness in emergency response in order to estimate the adequacy of l existing emergency planning regulations. D r i

. [Pursell] I am President of Human Resource Systems. My professional i qualifications are being offered into eviden<:e as part of the document enti-tied " Professional Qualifications of LILCO Witnesses on Exercise Conten-tions." My familiarity with the issues raised by Contention EX S0 stems ) primarily from my years of work in training and performance appraisal. I have developed, conducted,. and evaluated training programs.- These [ training programs include: performance appraisal, minimizing rating errors, employee selection procedures, training trainers, test validation techniques, interviewing skills, and assessment centers which include job simulation exercises. y (Weismantiel I am Vice-President of Engineering for LILCO. My profes-stonal qualifications are being offered into evidence as part of the docu- ) ment entitled "Profeestonal Qualifications of LILCO Witnesses on Exercise Contentions." My familiarity with the issues raised by Contention EX S0 stems primarily from my work in developing and implementing the LILCO ) Plan for Shoreham, as well as my participation as the Manager of Local Response in the February 13,1986 Exercise. 3. Q. Please summarize the issues raised by Contention EX 50. ) A. (Panel]II Contention EX 50 alleges that a large number of training deficiencies were revealed by the Exercise and that those training deficiencies collectively demonstrate a fundamental flaw in the LILCO j Plan because inadequate training prevents implementation of the LILCO ( Plan and Procedures. Each subpart of Contention EX $0 contains a 1 L-i 1/ For the sake of brevity, when all seven witnesses on the training panel sponsor an answer, the response will be attributed to the panel. Where an answer is sponsored by selected members of the panel, each witness will be listed. ) separate ground on which Intervenors a!!ege Exercise events demonstrate that the LERO training program has not effectively trained LERO person-nel to respond to an emergency. Contention EX 50.A alleges an inability to respond effectively to D unanticipated and unrehearsed situations. Contention EX 50.B alleges an inability to follow and implement the LILCO Plan and Procedures. J Contention EX 50.C alleges an inability to communicate necessary and sufficient data and information, to inquire and obtain such information, or to recognize the need to do so. J Contention EX 50.D alleges an inability to follow directions given by superiors during an emergency. Contention EX 50.E alleges an inability to exercise independent judgment or good judgment, or to use common sense. Contention EX 50.F alleges an inability to deal with the media or otherwise to provide timely, accurato, consistent, and nonconflicting infor-mation to the public, through the media,in an emergency. Contention EX 50.0 alleges an inability to provido training to school bus drivers and ambulotto drivers. Contention EX 50.11 alkges a deficiency in the areas of dosimetry, exposure control, and rotated areas. Finally, Contention EX 50.1 allegoJ that LILCO's proposals to correct ,) any problems identitled during the Exorcise will not be successful. The specillo allegations raised in each of the subparts of Contention EX 50 are, in accordanco with the Licensing Iloard's instructions of g December 4.1986 and Prehearing Conferenco Order of February 13. 1987, )

b, 1 consolidated with the bases of Contention EX 45. Contention EX 42 is subsumed in Contention EX 50. We therefore have treated the alleged mis-takes raised in Contentions EX 42 and EX 45 under the speelfle subparts of Contention EX 50 in whleh they are cross-referenced. Contention EX 50 and the other admitted contentions consolidated with Contention EX 50 are l set out in their entirety in Attachment A. l 4. Q. Would you summarine the conclusions you have reached on the lasues raised - by Contention EX 507 ( A. (Panel) Yes. The issues raised by Contention EX 50 are not supported by t the results of the Exercise as described in the Shoreham Post-Exercise ) i Assessment or by past experience with organizations in emergencies. When 4 one reviews the results of the Exercise, it becomes clear that the Exercise demonstrated that the LERO training program was successful. On the day ) of the Enereise, LERO notified and mobillaed all field personnel (approxi-mately 1,000 field workers) and a full complement of EOC, staging area and reception conter personnel. This is markedly different from other nuclear ) pnwer plant exercises where only a fraction of the total emergency work i force is mobilized for FEMA evaluation, in our opinion, the February 13 j Exercise was a more realistle evaluation of LERO's ability to respond to an ) L emergency both because the entire organlaation was notified and mobilized [ t and because FEMA could choose at random any member of the organization } to evaluate. FEMA found generally that those LERO workers evaluated correctly and effectively implemented the LILCO Plan and Procedures and f i that the LERO organisation was able to provide an effeettve response. l' l While it is true that there were some instances during the Exercise in which individual LERO workers did not perform their jobs perfectly. [ [ r ( ) i

) : perfect performance is not to be expected in any drill, exercise, or emer-l )- geney and it is not necessary for an offeetive response. I Not only do we disagree with the conclusions reached in Contention IX 50, but we believe that the Shoreham Post-Exercise Assessment demon- ) strates that the LERO training program was effective. We looked at the results of the Ezereise as reported in the Shoreham Post-Exercise Assess-l t ment using three different methods of analysist all indleate that the LERO

• i

) training program offeetively trained personnot to carry out their emergen-i ey jobs. First, as Des. Lindell and Milett will testify, during the Exercise, LERO exhibited the three beste factors for organisational offsetiveness. ) Soeond, as Mr. Pursell will testif y, a content analyals of the Shoreham Post-Emeroise Assessment using the critical incident analysis technique twveals that, in FEMA's opinion, LERO performed very well overall. Third, as Mr. Rohr and Ms. Goos 5dnd will testify, the Shoreham Post-Exercise Aabess-ment compares favorably with other FEMA post-exercise assessments in i i FEMA Region !!. b i Finally, it is our opinion that the mistakes which occurred during the j Enorelse and are referenced in Contention EX $0 do not demonstrate either a failure of the organization to funetton effectively or a failure of the 1 LERO training program. An offatte emergency response organization such as LERO is not likely to suf fer a total f ailure in an emergency as a result of f i l i mistakes made by individual members. Experience has shown that even l emergency organizations without speelallaed training accompilah their overall objectives during an emergency. In addition, the speelfle incidents referenced in Contention EX 80 are neither singly nor colleettvely of a ) nature or gravity that would demonstrate a fundamental Inability on the part of LERO to protect the health and safety of the public. t

f .g. 4 5. Q. Why do you rely on just the Shoreham Post-Exercise Assessment as your j data base when there are other sources such es player documents, FEMA l critique forms, and LILCO observer forms? A. (Behr, Goodkind Lindell, Milett, Pursell] There are basically two reasons why we used the Shoreham Post-Exercise Assessment as our data base. I ) First, it is a comprehensivo and cohesive picture of Exercise events col-lected by a group of objective observers who were to evaluato the events using basically the same criteria. Second, it is the only data source avall- ) able that can be meaningfully compared with other FEM A post-exerciso as-sessments. ) 6. Q. Would you anticipato that thoro would be perfect performance by LERO7 A. (Behr, Daverlo, Goodkind] In our experience as emergency planners, we have never soon olther a drill or exercise whero perfect performance was ) demonstrated. Of course, in evaluating the Shoreham Post-Exercise Assessment it is important to keep in mind what we believe is the two-fold i purpose of FEMA's evaluation. That two-fold purpose is first, to assess tho ) ability of the omorgency responso organization to protect the health and safety of the public and second, to apply FEMA's expertiso to botter the responso capability. In short, wo do not expect to sco, nor do wo bollovo ) that FEMA expects to find, an offsito organization that has perfect per-formance. FEMA's imptomontation of this philosophy can bo observed at two ) sitos in New York Stato--the Nino Milo Point Nuclear Station, which also includes the James A. Fitzpatrick plant, and the Robert E. Ginna Nuclear j Power Station. Af ter six years of emergency preparedness activity by Now ) York Stato, the threo countics involved at theso sites, and thrco utility companied, and af for sovon FEMA graded oxorcisos. FEM A cortilled theso (

)- 10-two sites in accordance with 44 C.F.R. 5 350, which establishes a policy ) and procedurc for review and approval of offsito emergency preparedness programs. FEMA gives 5 350 certification based on a finding that the health and safety of the public can be reasonably assured. The Nino Milo ) Point Emergency Preparedness Program was certified at a time when there were still 31 outstanding ARCAs. The Olnna Program was certifled af ter receiving 24 ARCAs for their last exerciso held in December 1985. These ) two programs remain the only programs in FEMA Region 11 that have received 5 350 certifications. Atter all these years of training and exercis-Ing, the two sites that have met FEMA's standards for certification have ) many correctivo actions yet to implement. With respect to the Shoreham Exerciso it is also important to remember that LERO mobilized over 1,000 people, any one of whom could have been selected by FEMA for evaluation on a number of f actors. That alone would make a finding of perfect performance by overy person improbablo if not impossible. (Pursell] I have spent 14 years developing training programs and ovaluating the performanco of personnel. Never havo f seen an instanco in ) which overy Individual in a largo organization achloved perfect perfor-mance in tho oxocution of his job function nor would I expect to sco that. Variations in performanco are to be expected. ) 7. Q. Ilut lan't Iwrfoot performanco necessary to Ituuro that public health and safety will be protected? A. (Lindell. Mllott) No. Our rer.carch and experience with omorgency resporuo organizations is quito consistent with studios of organizations in other sottings: it indicates that perfect performanco on the part of each )

J .u-Individual member or subunit within an organization is not needed in order for the organization as a whole to achieve its goals. First, it is important to draw a distinction between the performance of an individual and the performance of an organization. Organizations, not individuals, are the appropriate units of analysis for assessing the effectiveness of emergency response, it is quite possible not to have all individuals do their work per-factly in an emergency and still have the emergency response organization D achieve its objective of protecting the public health and safety. Put sim-ply, this contention focuses on the wrong unit of analysis. Emergency response is by organizations and not Individuals. 8. Q. But don't the errors made by individuala during the Exercise reveal a training problem? A. (Lindell, Mllett) No. There are several reasons why that is an erroneous conclusion. First, we do not believe that there is a training " problem" because we do not believe that there was a performance " problem". Olven the design of LERO, as outlined in its emergency plan and implementing procedures, and the actions of LERO personnel on the day of the Exercise, it is our judgment that the organization could offectively perform its goals in an actual radiological emergency. More specifically, we believe that LERO could have protected the public health and safety by promptly nott-fying the public within the 10 mile EPZ, by making timely and appropriate decisions regarding protective actions, and by facilitating the implementa-tion of evacuation through effective transportation support and traffic I I management. g U l l

h Second, as we previously described, Individual performance errors do ) not necessarily imply a training " problem". Individual performance is affected by a number of factors. These include the knowledge, skills, and abilities that individuals bring to the job (which are determined by the per- ) sonnel selection, placement, and classification policles of the organization): the training that individuals receivet the equipment that is usedt the mate-rials (especially job performance aids such as maps and checklists) that are ) provided; and the f acilities in whicu ir.dividuals perform their tasks. In order to prevent the recurrence of individual performancJ errors, an organization should identify those changes in personnel placement, ) training, equipment, materials, and facilities that are most likely to pro-duce the desired level of performance. An examination of the individual performance errors (deficiencies and ARCAs) Identitled by FEMA during ) the Exercise reveals that almost half of them had little or nothing to do with training but rather concerned equipment or proceduros. For most of the training related performanco errors, FEMA recommended correction ) with refresher training to improve !.ERO workers' knowledge of specific

facts, in our judgment, most of these recommendations for refresher training would be more appropriately corrected by means of job perfor-

) manco aids, such as fact sheets and checklists. As discus.cd in tho testimo-ny on Contention EX 50.I, LILCO h.us developed job performanco alds to correct these problems. Third,if there were systomic problems One would expect that exer-cise objectives that were common to more than one subunit within the !.ERO organization would exhibit a consistent pattern of deficloncles and ARCAs. Wo examined the Post Exorciso AswMmont to dolormino whethor )

) such patterm existed. Contrary to the " training failure" hypothosts, LERO personnel tended as a group to meet the objectives of the Exercise. What performance errors were otmerved tended not to be systemic. That is, when one LERO subunit did not meet, or only partially met an objective, there was at least one other subunit that did meet the objectivo. For examplo, while there were some deficiencies and ARCAs notod for the Patchogue and Riverhead Staging Areas, the Port Jefferson Staging Area ) did not display almilar problems, in summary, neither FEMA's recommen-I dations regarding training, nor tro pattern of evaluattom of the Exercise objectives, provides any Indication of a systemic deficiency in the LERO ) training program. 9. Q. Ilut wouldn't the type of mistakes made during the Exercise lead to a fall-ure of the LERO organization? ) A. (Lindell, Milett) There are a varloty of reasom why individual mistakes of the type made during the Exercise would not lead to failure of the entire organizational respomo in an actual emergency. First, LERO previously analyzed the demands of the omorgency situation to which it would be ro-sp)nding and the organizational functiom that must be performed to re-spond to these demands. LERO has developed a plan and a training pro-gram to ensure that the organization has a clear understanding about what needs to be done and who l respomlblo for accomplishing those tasks. Second, LERO maintains information and control systems designed ) to detect and correct individual performance orrors before these orrors can produco severo and irreversiblo comoquences. LERO has established back-up mechanisms for accomplishing critical tasks which may bo olther rodun-

d. int (e.g, independent and Identical), or diverso fo,g, indopondent.ind J

) .g4 functionally equivalent although not identical), or both. These backup ) mechanisms provide flexibility that assures that important goals will not be threatened by individuals falling to report for duty or performing their tasks incorrectly, or, for that matter, by failures of equipment or inade-quate facilities. Finally,1.ERO has multiple methods for detecting and interpreting unexpected situations during an emergency and for monitoring the quality ) and timeliness of each subunit's performance of its emergency response assignments. This enhances the overall interorganizational response. )

10. Q.

Are there any other means to tell whether an organization such as LERO will be able to respond of f actively to an emergoney'l A. [Lindell, Milett) Emergency response organizations are like most other organizations. On tx)th theoretical and applied grounds, organizational be- ) havior in relation to emergenclos reflects the findings of rosearch on com-plex organizations In general. Research into what f actors promoto coordination and cohesion (im-portant antecedents to effective emergency response) suggests that three f actors are important, in general terms, these f actors are a c! car under-standing about what to dot flexibility in approach: and a good idea about the ) overall inter-organizational omergoney response. These f actors are dis-tilled from general research on complex organizational effectiveness and speelfic research on actual organizational emergency response. They have been empirically illustrated as rolovant to oxercise assessments at nuotoar i power plants. $tg NURE0/CR-3524 J.11. Sorensen, E. D. Copenhaver, D.

5. Milott, and M. V. Adlor, OfgnfilfallapplillLqt(gettin_Regiqtlingingly

) D0nalM_arld._Respom'!. report prepared for the Olvision of Facility 1 l i

) Operations Offlee of Nuclear Regulatory Research, U. S. Nuclear Regulatory Commission. Washington, D.C. by Oak Ridge National Labora-tory Oak Ridge, Tennesse (1984). ]

11. Q.

The factors that you've outlined to assess organizational of fcctiveness seem fairly abstract and all-inclusivo. Are there more specific things that one can look at to measure organizational offectiveness? A. (Lindell, Milett) Yes, the three basic factors are in fact each comprised ] of subfactors. First, the f actors that demonstrate a clear understanding about what to do are basically those which demonstrate a knowledge of intra-D organizational relations. They are: role definition (clearly defined respon-sibilities): authority (clearly defined powers and authority hierarchy): terri-tory (clearly limited boundaries of authority): priority setting (understood 3 mechanisms for setting priorities): normativeness (similarity between nor-mal and omergency renponsibilities): legitimacy (responsibilities are viewed as significant): communications ability (ease and clarity of accessing infor-D mation): and knowledge (lovel of understanding about responsibilities). Flexibility in approach is generally characterized by both intra and inter-organizational flexibility such as: formalization (ability to deviato O from written procedures): adaptability (ability to respond to new situa-tions): and control (ability to exerciso and retain authority). Finally, an understanding about the overall inter-organizational 3 omorgency responso or, stated another way, the inter-organizational not-work, may be demonstrated by: domain (clearly defined division of respon-sibility): disputo resolution (mochanism for negotiating differencos): legiti-3 macy of roles (acceptanco by other organizations): resourco adequacy (sufficient resources to perform rolo): autonomy (ability to relinquish for ko the good of the system); communications ability (high level of linkages between organizations); authority (network hierarchies are clearly estab-11shed); interaction clarity (organizations know with whom to interact); and knowledge (functioning of the system is understood). )

12. Q.

Ilow do you know that these factors will show whether an emergency response organization is effective and, therefore, whether the training pro-gram was eifective? ) . A. (Milett] In the early 1980's, three members of the staff at Oak Ridge National Laboratory (ORNL) and I performed research for the NRC to determine if existing emergency planning regulations and guidelines had led ) ' to effective interf aces between utilities and offsite emergency planning or-ganizations. The results of our research were published in NUREG/CR-3524, Organizational Interface in Reactor Emergency Planning and Re- ) sponse (1984), and then in other publications and papers. Our work sought to accomplish the following tasks: (1) review and summarize the results of actual studles on organizational effectiveness in ) non omergency situations; (2) review and summarize the results of actual studies on organizational offectiveness in responding to omorgencies; (3) develop an integrated theory about the determinants of organizational of- ) foetiveness in rerponding to omorgencies based on the empirical record produced by past studies; (4) review omorgency plans at nuclear power plants:(5) conduct two caso studies at nuclear plants which focused on the ) factors that the theory wo developed suggested as datorminants of effec-tivonossi and (6) observo a test exercise, in light of the same f actors, to collect further data about interf aco and organizational offectiveness. ) ?

I. _t7_ The results of our work enabled us to comment on the adequacy of existing emergency planning regulations, feel confident that the f actors we identified are sound predictors of organizational effectiveness in response to emergencies, and illustrate that these same factors are useful in ) evaluating exercises.

13. Q.

What if the theory turns out to be incorrect? y A. [Lindell, M11eti) We think it unlikely that the theory discussed in NUREG/CR-3524 will prove inapt for two reasons.' The theory was derived by identifying from actual empirical studies, common attributes of effec- ) tive organizations. Those attributes were then assessed in light of both the functions that would need to be performed in a radiological emergency and the human and material resources required to accomplish those functions. ) The theory, consequently, proposes what would constitute attributes of an ideal emergency response organization in a radiological emergency.

14. Q.

How were the factors that are critical to an effective emergency organiza- ) tion demonstrated by the LERO organization and its performance during the February 13 Exercise? A. [Mileti] First, these factors, which were identified as important for orga-nizational effectiveness in response to emergencies, were taken into ) account in the LERO Plan and training program. Babb e_t al. ff. Tr.11,140, at 5,22-23. In my opinion, the incorporation of these concepts in the Plan and training program increases the probability that the LERO organization y will be effective in its response to an actual emergency. Second, during the February 13 Exercise, LERO exhibited all of the factors described in NUREG/CR-3524 that are critical to effective emer- ) gency response. )

f The method used to apply the NUREG/CR-3524 factors -to the February 13 Exercise can be described as follows. First, the Shoreham Post-Exercise Assessment was selected as the data base. Second, each organizational subdivision within LERO (as those subdivisions were defined I in the Assessment) was treated as if it were a separate organization. Third, FEMA comments for each objective were reviewed in terms of whether or not those comments provided any information about the factors in i NUREG/CR-3524. If no information was provided on any one of the factors in NUREG/CR-3524, then no judgment concerning that factor was recorded. If a FEMA comment existed, however, that did cast light on one ) or several factors in NUREG/CR-3524, then that comment was used as an indicator of one or more factors. For example, the FEMA comment ... verification of this initial notification was received within 15 ) minutes... " was taken as indicative of there being adequate resources to accomplish this task and that role definition was also clear enough to have this task performed. In this way, each of the LERO subunits was appraised ) in reference to each FEMA objective and in reference to each of the effec-tiveness factors listed in NUREG/CR-3524. Fourth, scores were recorded as follows: 0 (no data was available in Shoreham Assessment on which to judge a particular factor); C (the Shoreham Assessment illustrated that a positive score should exist, and a positive score would suggest " cohesiveness" to use the term in NUREG/ ) CR-3524); pC (the Shoreham Assessment illustrated that there was both a positive and negative aspect to what was observed, for example, "Patchogue bus drivers were not gotten out on time" - but this would not ) have created a major response problem - and thus a " partially cohesive"

I + 1 l score was recorded); and U (a totally negative FEMA comment was }- observed and was recorded as "uncohesive"). Neutral values were not recorded since they were not obvious in the Shoreham Post-Exercise Assessment, although they could have been imputed from an absence of data. I This process resulted in a score of C, pC, U or O for each of the fac-tors in NUREG/CR-3524, the FEMA objectives listed, and the nine organi-zational subunits in LERO exercised in February 1986. The results of this review produced the findings listed in tables in Attachment F. )

15. Q.

Was there any difference between the analysis in NUREG/CR-3524 and the analysis of the Shoreham Post-Exercise Assessment? A. [Miletil There were differences between the method of assessing organi-zational effectiveness for.LERO based on the Exercise and the method in NUREG/CR-3524. There are several reasons for these differences. First, -the research performed for NUREG/CR-3524 had the factors clearly estab-lished before data collection began. Consequently, we were able to develop ) e and use measures that squarely addressed each of the factors in NUREG/CR-3524 for evaluating each of the organizations in the exercise and the case studies. This was not the case in our assessment of the ) Shoreham Exercise. There it was necessary to use indirect measures; we had to infer the NUREG/CR-3524 factors from the text of the Shoreham Post-Exercise Assessment. The persons who evaluated the Exercise did not ) seek to measure our social science factors as they conducted their exercise evaluation, and different exercise evaluators looked for different things de-pending on what part of LERO and what FEMA objective they were ) evaluating. Consequently, the data base available to us on the Shoreham )- I

O Exercise was more limited than if we had desigried the sort of social sci-ence study used in NUREG/CR-3524. Intercstingly, however, the evaluators of the Shoreham Exercise did produce a good deal of information from which we could reach conclusions about the factors in NUREG/CR-3524. This suggested to us that the effectiveness factors in NUREG/CR-3524 do underlie emergency planning and exercise evaluations. Second, no valid way existed to integrate the scores compiled on the

O basis of the Shoreham Post-Exercise Assessment into single scores (cohe-sive versus uncohesive) for each factor within each organizational subdivi-sion of LERO.

We were able to develop composite scores in NUREG/

O' CR-3524 on each factor for each organizational subdivision because we had employed the factors when collecting the data. Since the factors were not specifically used in FEMA's assessment of the Shoreham Exercise, our as-

O sessments were unstandardized (they were inferred from the text of the FEMA Assessment of the Exercise). Consequently, it would be quite sus-pect to reduce the findings presented in Attachment F to composite orga-nizational scores as we did in NUREG/CR-3524.

l

16. Q.

What can you conclude about the LERO training program based on your analysis? A. [Miletil Within the limits imposed by the available data, the analysis dem-onstrates that LERO exhibited a high effectiveness potential during the Exercise. Obviously (see Attachment F), the Shoreham Post-Exercise As-l- sessment documented a much greater potential for LERO cohesion and ef-l l fectiveness than it documented potential uncohesiveness or effectiveness 1. pr blems. The analysis clearly suggests that the LERO training program O has produced an organization with high potential for effectiveness in O-

. response to an emergency. The training program, in my judgment, appears ? to be fundamentally successful.

17. Q.

- Are there other means to establish whether the organization as a whole functioned effectively? )? [Pursell) - Yes. I have employed two means of analyzing the results of the A. Exercise to determine whether it is likely that the LERO organization will be able to protect the health and safety of the public. One is a content )~ analysis of the Shoreham Post-Exercise Assessment using the critical inci-dent analysis technique. The other is to consider the degree to which LERO was able to meet the Exercise objectives. y [Behr, Goodkind] We analyzed the results of the Shoreham Post-Exercise Assessment by comparing FEMA's assessment of LERO with its assessment 7 of other offsite emergency response organizations for nuclear plants in FEMA Region II.

18. Q.

What is the critical incident analysis technique? A. [Pursell] The critical incident analysis technique is a process for col-lecting and categorizing observations of human behavior for use in, among other things, evaluating demonstrated performance. The technique is widely applied and accepted, and is used in a variety of settings, including the development of job analyses, the designing and evaluation of trr.ining programs, and performance appraisals. ) With this technique, an incident is any observable behavior "that is sufficiently complete in itself to permit inferences [either positive or neg-ative] and predictions to be made about the person performing the act. To ) be critical, an incident must occur in a situation where the purpose or the )

p. intent of the act seems fairly clear to the observer, and where its conse-quences are sufficiently definite to leave little doubt concerning its effects [ positive or negative)." J. C. Flanagan,"The CriticalIncident Technique," 5 Psychological Bulletin 372-358 (1954). In practice, the technique, as applied to an evaluation of a training L program, involves several steps. First, the objectives of the behavior to be observed must be clearly defined.- Next, data are gathered by evaluators T who observe the performance to be evaluated and record the " critical inci-dents." The criticalincidents are categorized as either positive or negative in the attainment of the objectives. Finally, the data are compiled, creating a picture of the relative efficacy of the performance.

19. Q.

Why is it appropriate to use the critical incident technique to analyze the Shoreham Post-Exercise Assessment? ) A. [Pursell] The critical incident analysis technique is appropriate because the Shoreham Post-Exercise Assessment contains all of the necessary ingredients for use of the technique. The Exercise objectives are clearly defined in the Assessment. The Assessment records the occurrence of inci-dents observed by FEMA during the Exercise. These observations can be categorized as either positive or negative in the attainment of the Exercise objectives, and a view of the overall performance of LERO can thereby be generated. 1

20. Q.

How was the critical incident analysis technique applied to the Shoreham Post-Exercise Assessment? A. [Pursell] First, we established a list of criteria for classifying the inci-dents reported in the Aasessment so that different evaluators could per-form their own assessment and attain comparable results. The criteria )

C; ~23-o were designed to ensure that the classification process was done as objec- - tively as possible. See Attachment E. Observable behavior would be classi-fled as either positive or negative. Statements that did not report behav-ior, but were, for instance, statements about procedures, recommendations, O or were factual, were classified as neutral. The analysis was limited to information reported in the Shoreham Post-Exercise Assessment; incidents. known to have occurred during the Exercise, but not specifically reported - 'O ' in the Assessment, were no't included. Next, a three-man team analyzed every sentence in pages 27-83 of the Shoreham Post-Exercise Assessment; the summary portions highlighting O the deficiencies and ARCAs were not analyzed. Each incident of reported - behavior was given either a positive or negative classification. The total number of positive and negative responses was then tallied and recorded. O The same team also performed an analysis of the Post-Exercise Assessment of th3 August 24-25, 1983, Indian Point Compensating Exercise. A second three-man team performed an analysis of the Shoreham Post-Exercise O Assessment employing the same criteria. This second analysis serves as a reliability check.

O

21. Q.

How were the individuals who performed the evaluation chosen? A. [Pursell] To ensure the validity of the analysis, each group included one person experienced in the application of the criticalincident analysis tech-I M nique. I performed that function for the first group, and my colleague, Philip Lichtenfels, did so for the second group. It is also important to have someone involved in the analysis who is familiar with the behavior to be N evaluated. Thus, the other two people in each group were chosen for their extensive familiarity with the LILCO Plan and with the Exercise itself. In 1 lO

.. this way, we were able to ensure that the evaluators had sufficient knowl-O edge of their task and of.the activity evaluated to perform accurately the critical incident analysis. O

22. Q.

In performing a critical incident analysis is there any weighting of the crit-ical incidents? A. [Pursell] No. Each critical incident is categorized simply as positive, negative, or neutral. The critical incident analysis technique does not O-involve a weighting of incidents because that would introduce subjectivity into the process. Moreover, when a large number of incidents are observed (over 1,000 in the case of the Shoreham Post-Exercise Assessment), the O very strong and very weak incidents in each category will tend to cancel each other out. O

23. Q.

If there'is no weighting of the positive and negative criticalincidents, how does one take into account FEMA's characterization of some of the inci-dents as deficiencies and others as ARCAs? A. [Pursell] The portions of the Shoreham Post-Exercise Assessment sepa-O rately setting forth the deficiencies and the ARCAs were not themselves included in the analysis since they concern conclusions, not observations of i behavior. Instead, we looked at the statements of FEMA's observations O upon which the deficiencies and the ARCAs are based. My overallimpres-sion of the Post-Exercise Assessment is that more statements were made l about individual deficiencies than about individual ARCAS and that more statements are made about each deficiency and ARCA than about each pos-itive observable. Therefore, it would appear that the deficiencies do have a greater impact on the results than do the ARCAs. 'O

o i

l

0:' 25

24. Q.

Why did you compare.the post-exercise assessment for the Indian Point Compensating Exercise with the Shoreham Assessment? g-i A. [Behr, Daverio] W'e wanted to find another exercise that provided as close a parallel as possible to the Shoreham Exercise. In our opinion as emergen-

g' cy planners who are familiar with other FEMA exercises, the Indian Point

- Compensating Exercise (August 24-25,1983) was the most appropriate for a number of reasons. First, both plants are located in FEMA Region II and,

O therefore, the exercises were evaluated by essentially the same group of persons. Second, Roger Kowieski was the RAC Chairman for the Shoreham Exercise and also the principal FEMA individual involved in the Indian

.O Point Compensating Exercise. In that role he would have, among other things, approved the scope of the exercise scenario and objectives. Third, for those exercises, Indian Point and LILCO were in similar positions O' because both offsite emergency response organizations were forced to deal with a situation in which a local government was not providing the offsite emergency response. Finally, the population of Rockland County - that O portion of the Indian Point EPZ for which the local government was not providing the offsite response - is comparable to the population of Shoreham's EPZ. iO

25. Q.

What were the results of the critical incident analyses performed on the Shoreham and Indian Point Post-Exercise Assessments? A. [Pursell] The results of each analysis were very positive. Specifically, D Group 1 found that 82% of criticalincidents noted in the Shoreham report were of a positive nature. Group 2 found that 83.1% of the critical inci-dents were positive. The results of the critical incident analysis of the Indian Point Post-Exercise Assessment were similarly positive; 87.2% of the critical incidents were positive. IO

I . 26. Q. What other information does the Shoreham Post-Exercise Assessment pro- ). vide that is useful in evaluating the performance of the LERO organiza-tion? A. [Pursell) The Shoreham Post-Exercise Assessment also reveals that FEMA evaluated LERO against the Exercise objectives 121 times (of ten an objec- )~ tive, such as SA-1, was evaluated more than once). Based on that evalua-tion, for 96.7% of the observations the objectives were found to have no deficiencies associated with them. In addition, for 95.9% of the observa- ) tions the objectives were either completely or partially met and for 74.4% of the observations the objectives were completely met. )-

27. Q.

What do these results tell you about the overall performance of LERO as assessed by FEMA? A. [Pursell] These results indicate to me that the LERO organization func-tioned extremely well during the February 13 Exercise. The results are even more impressive given the nature of FEMA's post-exercise assess-ments which generally identify individual performance errors in an effort to identify and correct any errors; they are not designed to be a positive reinforcer. Given the nature of the Shoreham Post-Exercise Assessment, then, it is particularly impressive that the results turned out so positive. While it would be inappropriate to use the percentages derived through the critical incident analysis as a " grade" for LERO's performance, l they do provide a means both of gauging LERO's performance and j comparing that performance with the performance of other organizations evaluated by FEMA. With the results at over an 80% positive level, as here,I am confident that the training program was effective. ) )

) - This confidence is further supported by comparing the results of the I analyses performed on the Shoreham Post-Exercise Assessment with that of the Indian Point Assessment, which I understand was the basis for a FEMA finding of reasonable assurance - a positive conclusion for FEMA. Based ) on my experience in the training field, the results of the analyses per-formed on the Shoreham and the Indian Point Assessments show an equiva-lent level of performance. )

28. Q.

How does the LILCO Post-Exercise Assessment compare with other post-exercise assessments for operating nuclear power plants other than the Indian Point Compensating Exercise? ) A. (Behr, Goodkind] We have examined 16 FEMA post-exercise assessments for other nuclear power plants now operating in FEMA Region II, including the assessment of the Indian Point Compensating Exercise. In our opinion, ) the Shoreham Post-Exercise Assessment compares quite favorably with the post-exercise assessments for these other plants.

29. Q.

What other post-exercise assessments have you compared with the ) Shoreham Post-Exercise Assessment? A. (Behr, Goodkind] The other FEMA post-exercise assessments with which we have compared the Shoreham Post-Exercise Assessment are: ) Nuclear Facility Exercise Date Indian Point March 3,1982 ) March 9,1983 August 24,1983 November 28,1984 June 4,1986 Oyster Creek March 16,1982 June 5,1985 S

_.. r Ginna January 21,1982 June 22,1983 }. September 26,1985 'J. A. Fitzpatrick August 11,1982 Salem October 23,1983 j October 23,1984 Nine Mile Point September 15,1981 September 28,1983 November 13,1985 )

30. Q.

Why did you choose these plants? A. [Behr, Goodkind] We made an etfort to examine as many exercise assess-ments as possible in FEMA Region II. Region II exercises were selected h r because they were evaluated by essentially the same group of persons, the ~ same FEMA coordinators approved the scope of the exercise scenario and objec'tives, and most of these exercises were in the State of New York. The exercise evaluations listed are those we were able to obtain within the time available. One other evaluation, which covered the April 19,1985, Reme- ~ dial Exercise at Indian Point was also obtained, but was not considered in J detail because of its limited scope. l

31. Q.

What were the comparisons that you made? )- .A. [Behr, Goodkind] First, we compared the exercises on a quantitative basis by counting the number of ARCAs and deficiencies. Second, we examined i FEMA's conclusions regarding the need for training in various functional 3 categories.

32. Q.

First, let's look at the quantitative assessment. How did you deal with the fact that FEMA has not always used the terms deficiencies and ARCAs 4 i when evaluating exercises? g A. [Behr, Goodkind] For each exercise that was considered, we looked at the l [ o i

. evaluation criteria defined by FEMA. An attempt was made to correlate earlier criteria with those currently used by FEMA to define deficiencies and ARCAs. For exercises during the 1981-1982 period, FEMA of ten did not categorize its recommendations in terms of significance. In these instances, FEMA citations were tabulated as a combined category of ARCAs and deficiencies. Later, FEMA distinguished significant deficien-cles from minor or other deficiencies, and areas of weak performance from ) areas of adequate performance. Significant deficiencies and weak areas were tabulated as deficiencies. Minor deficiencies and other deficiencies were tabulated as ARCAs. During the 1985-1986 period, current definitions ) of deficiency and ARCA were in use.

33. Q.

What were the results of your comparisons of the ARCAs and deficiencies? ) A. [Behr, Goodkind] ARCAs and deficiencies from sixtean exercises were tabulated in accordance with the criteria just discussed. The tabulation is shown in Attachment C. From this tabulation, the following comparisons ) can be made. The total number of ARCAs and deficiencies in the 16 exer-cises was 673, for an average of 42. This number compares to a total of 47 ARCAs and deficiencies at Shoreham. The number of ARCAs and ) deficiencies at Shoreham was exceeded at the following exercises: Indian Point (1982,1984,1986); Oyster Creek (1985); Ginna (1982); and Salem (1984). Looking at deficiencies alone, the to:al of four cited at Shoreham was equalled or exceeded at Salem (1984), Indian Point (1986), and Oyster Creek (1982). The 43 ARCAs at Shoreham can be compared to the follow-ing: 61 at Indian Point in 1984 and 68 at Indian Point in 1986; 48 at Oyster Creek in 1985; 59 at Salem in 1984; and 41 at Nine Mile Point in 1983. 3

) 34. Q. You also indicated that you have done a qualitative analysis of the post-exercise assessments. Please describe that analysis. ) A. (Behr, Goodkind] We have looked at the same 16 exercises in Region II to examine citations made by FEMA regarding the need for training. We have 3 summarized training citations into 12 categories. The results are shown in the table in Attachment D. It is interesting to note that the need for addi-tional training of emergency workers in radiation dosimetry and/or use of } KI was mentioned in every one of these exercise assessments. Such a find-ing obviously does not necessarily constitute a deficiency. The frequency with which FEMA cites the need for training is high. ) For three functions (emergency facility operations, field team operations, and decontamination procedures), a need for training was specifically cited in 12 of these 16 exercises. At Shoreham, a need for training was cited in ) five categories: EOC operations, fire / police functions (traffic guides, etc.), emergency worker dosimetry and use of KI, bus operations, and reception center operations in the area of public monitoring and decontamination. ) No training-related citations were made in the areas of public alerting, dose assessment, field team operations, decontamination, 24-hour staffing, ambulance driver or medical staff, and media relations. The lowest number l of training categories cited in any of the 16 exercises was four (Salem, 1983; Indian Point, August 1983; and Nine Mile Point,1985). The average number of training categories cited in the 16 exercises was 6.4, with a ) range of 4 to 11.

35. Q.

You identified a number of training related problems in these other post-exercise assessments. Were any of those recurring problems? 8 A. [Behr, Goodkind] Yes. Inspection of the table " Summary of Training Cita-tions" (Attachment D) shows that many of the same training problems D

r ) recurred and the need for training is generally on-going. Also, the nature of FEMA's evaluation is usually to cite any mistakes that are noticed, rath-er than to mark improvements that may have been made. Until perfect performance is achieved, it is likely that citations of training needs would ) continue. LERO acknowledges the need for continued training with its periodic training program. }

36. Q.

What does the recurrence of training related problems indicate about a training program? ~ A. [Behr, Goodkind] The mere recurrence of training related problems does not by itself indicate a flaw in a training program. We have never found an ) instance in which FEMA has stated that a training program is flawed in a basic or programmatic fashion, even though training citations recurred at all of the 16 exercises examined in detail. As Drs. Lindell and Mileti note, 3 training problems must be evaluated to determine whether they are individ-ual errors or systemic errors and to determine the cause of the problem and its solution. What is significant is that, at the Shoreham Exercise, emer-gency functions were carried out well, and numerous citations of good per-formance were made by FEMA. 3

37. Q.

What do these analyses tell you about the efficacy of the LERO training program? A. (Behr, Goodkind] The results of these analyses show that Shoreham's training program is as good or better than training programs for offsite organizations at other nuclear plants in FEMA Region II. The analyses also demonstrate that there is nothing unique about the training problems iden-tified in the Shoreham Exercise. Almost half of the citations concerning 3H j training in the Shoreham Post-Exercise Assessment refer to emergency O

c ) worker dosimetry, a category that we have seen mentioned in every exer- ) cise we reviewed. In Shoreham's case, the tac,k of improving performance is facilitated by the limited number of areas in which improvement is needed. See Attachment D. )

38. Q.

In addition to the analyses just discussed, have you analyzed the Exercise actions and events Intervenors cite as support for Contention EX 507 A. (Behr, Daverio, Weismantle] We have and find that they do not support the allegations raised in the subparts of Contention EX 50 or the overall allegation that the LERO training program is flawed. Intervenors cite every problem that occurred during the Exercise and claim that it illus-trates a fundamental flaw in the LERO training program. They do not dif-ferentiate between training problems and equipment or procedural prob-lems, nor do they recognize the context in which these individual problems arose. The specific actions and events on which Intervenors rely to support l their allegations in Contention EX 50 are difficult to ascertain. Interve-nors do not provide specific facts to support their allegations but instead give a litany of contentions and FEMA comments which are of ten redun-dant of each other. When the redundant references are eliminated, the 3 alleged factual support for Contention EX 50 is really limited to the 43 l ARCAs and 4 deficiencies cited by FEMA. Charts provided in Attachment I( B illustrate the redundancy between the contentions and :he FEMA com-J ments.

39. Q.

Can you briefly describe the charts in Attachment B7 G A. (Behr, Daverio) Yes. The subparts of Contention EX 50 reference many contentions and FEMA comments; of ten the same contentions and 3 L

e k ' l,. comments are cited for more than one subpart. We thought it inefficient-9 and ineffective to provide lengthy testimony for each item referenced in each contention subpart. Therefore, we developed the charts presented in Attachment B, which provide in one place shorthand information about each contention and FEMA comment cited in Contention EX 50. (With the exception of Contention EX 50.G, which cites not a flaw but a lack of training, there is a chart for each subpart of Contention EX 50.) The text of the testimony focuses on illustrative examples of Intervenors' references and places these examples, which we believe are isolated incidents, in their appropriate context. In the first column, the charts describe the subject of the cited con-tention and, if it is duplicative of a FEMA comment, the corresponding FEMA comment. The second column describes the relationship between - ) the cited contention and the training program. Generally, that relationship L can be characterized in four ways: Irrelevant (the problem is not related to training, but may involve equipment or procedures); factually baseless (the ) facts are not as reported); not based on an Exercise event; or minor and correctable (while related to training, the problem is minor or isolated and can be readily corrected). The third column details changes to LERO pro-cedures or training to respond to FEMA comments. The fourth column refers to the Regional Assistance Committee ("RAC") assessment of the 7 i " changes" described in the third column. i Because the contentions cited are generally duplicative of the FEMA comments, the charts address Intervenors' contentions and cross-reference the FEMA comments. In a few cases, referenced contentions are not based l on FEMA comments or FEMA comments have no corresponding contention. t

) These are also reported in the charts. The charts provide, in one place, a ) discussion of all of the references made in each contention subpart. CONTENTION EX 50.A )

40. Q.

What does Contention EX 50.A allege? A. (Behr, Daverlo, Weismantle] The contention, which is set out in full text in Attachment A, basically alleges that the Exercise demonstrated that the ) LERO training program failed to prepare emergency personnel to respond effectively to unanticipated and unrehearsed situations likely to arise in an emergency. )

41. Q.

Have you analyzed the Contentions and FEMA comments cited by Interve-nors as support for Contention EX 50.A? A. [Behr, Daverio, Weismantle] We do not understand exactly what Interve- ) nors mean by the term " unanticipated and unrchearsed events" used in Con-tention EX 50.A. To our way of thinking, just about everything that hap-pened during the Exercise had an element of surprise. LERO knew only ) that there would be an Exercise on February 13; a select group of LERO workers also knew the objectives against which LERO would be evaluated. The participants did not know the time events would be declared, the pro- ) gression of the accident, the free play messages, the area to be evacuated, the specific field locations to which they would be assigned (el, the traf-fic control point or stren routo), or a myriad of other things. Given FEMA's i D positive evaluation of LERO's performance in the Exercise, we find it diffi-cult to conclude that the LERO training program did not effectively train personnel to respond to unanticipated and unrehearsed events. S O

r 1 l We also find that none of the contentions and FEMA comments referred to in Contention EX 50.A describe actions or events that support Intervenors' position. igg Attachment B for a discussion of each item. As I discussed in the chart, many of the actions and events cited have absolutely i no relationship to training but are related to equipment, the number of per-l sonnel or procedures. They cannot be relied on as evidence of flaws in the - training program. Second, while some of the actions and events described may appear to support Intervenors' position, close scrutiny reveals that they do not. Finally, Intervenors cite some instances of problems related to training that are minor or isolated events and not indicative of a perva-sive flaw in the training program, e t

42. Q.

Can you provide some examples of actions or events referred to in Conten-l tion EX 50.A that do not relate to training? ) A. (Behr, Daverio] Yes. Contentions EX 38, EX 39, EX 44, EX 22.F. and EX 22.I do not relate to training. Egg Attachment B. For example, Con-r tention EX 22.1 alleges only that the scope of the February 13 Exercise was I) inappropriate by challenging the validity of the two-accident assumption. It does not support Contention EX 50.A's allegation that the Exercise dem-l onstrated LERO's failure to train personnel to deal with unanticipated and D unrehearsed events. In Contention EX 22.F and the first sentence of Contention EX 44, l both of which were incorporated into Contention EX 38, Intervenors allege that an emergency at Shoreham would provoke premature evacuation and a I substantial evacuation " shadow." Neither of these allegations is relevant to training. Exercise participants acted in a manner consistent with the Plan ) they were trained to implement; that Plan takes into account some I D l t

r )- !: evacuation shadow.~ Moreover, our understanding is that events that l occurred during the Exercise would not have produced a substantial shad- . ow, jg LILCO's Testimony on Contentions EX 38 and EX 39 at 71-73. k '43. Q. What do you mean when.you say that some of the referenced contentions r> appear to support Intervenors' position until more closely scrutinized? A. (Behr, Daverio, Weismantle] Some Exercise events may, at first blush,' appear to demonstrate a training problem. But when these events are ex- ) amined closely, they turn out to be either unrelated to training or,if relat-ed to training, isolated problems that can be remedied with straightforward additional training. A good example is LERO's response to the traffic impediments. LILCO's Testimony on Contention EX 41 describes in detail the specific actions taken in response to the impediments. We agree with that testimo-D ny and with its conclusion that overall LERO dealt appropriately with the impediments. jg LILCO's Testimony on Contention EX 41 at 8-22. While it is true that the Evacuation Route Caordinator failed to perform his D assignment as effectively as he could have by failing to transmit all of the information on the original free play messages and by failing to inform his co-workers and superiors of the accident, his actions do not condemn the 3 entire training program. Eg LILCO's Testimony on Contention EX 41 at 19-22. What is more important to an analysis of whether the training pro-gram enabled LERO workers to respond to unanticipated and unrehearsed 3 events is whether on a systemic basis LERO workers were unable to l respond to unanticipated and unrehearsed events. Specific instances of f positive actions taken in response to the traffic impediments demonstrate p that LERO, as an organization, was able to identify a problem and correct it even when that problem was unanticipated and unrehearsed. O ~-

i h L 44 Q. What specific actions were taken that indicate LERO's ability to deal offactively with unanticipated and unrehearsed events? A. '[Behr, Daverio, Weismantle] In evaluating LERO's performance, one noods to distinguish between the effects of impediments as they actually would occur during an emergency and the simulations of the impediments as they occurred during the Exercise. During an actual emergency, a grav- 'el truck or fuel truck blocking a major evacuation route would provide a number of cues to its existence. In our opinion, this would virtually elimi-j nate the delay experienced in the Exercise. First, an impediment would be visible to LERO personnel approa.'hing the location of the impediment. Second, if it blocked traffic from passing through, queues would develop ) that would be detected by LERO personnel. Third, a traffic impediment might well be reported by the Suffolk County Police Department or news ) media. LERO would fall to take action only if the impediment were not detected. Given the large number of LERO personnel, such as traffic ) guides, route spotters, bus etrivers and ambulance /ambulette drivers that are operating within the EPZ, it is extremely improbable that the existence of a traffic impediment would be overlooked. In fact, the presence of ) many LERO personnel in the field makes it likely that the time required to detect an impediment would be quite small. In the Exercise, notification of the " existence" of the impediments ) was accomplished by means of insertion of messages to the Evacuation Route Coordinator. However, the multiple impacts and information f sources that would result in an emergency from the existence of these impediments were not simulated. Much of the delay in responding to the l two free play impediment messages can be attributed to artifacts of the scenario which hindered detection or verificaticn of the impediments.

,j, t Once the existence of the traffic impediments was verified, the b Evacuation Coordinator and his staff at the EOC responded appropriately ~ to the problem. 3g3 LILCO Testimony on Contention EX 41 at 8-22. It is important to keep in mind that prior to the Exercise LERO personnel had received no training in dealing with traffic impediments that would block f major roadways. Indeed, studies by LILCO's Traffic Engineer, Ed t-Lieberman, which were accepted in the emergency plan portion of these proceedings, indicate that while some traffic accidents might occur during the evacuation, they probably would be of a minor nature and would not block major roadways. Lont Island Lightint Comoany (Shoreham Nuclear ) Power Station, Unit 1), LBP-85-12, 21 NRC 644, 795-796 (1985) ("PID"). Thus, LERO training focused on less severe accidents than were presented j in the Exercise. When the players at the EOC identified the traffic impedi-l monts and craf tad a response to those impediments, they were developing a response to an unanticipated and unrehearsed situation. What is important is the fact that the players recognized the need to keep evacuation traffic flowing and, in f act, accomplished that in an appropriate fashion. Af ter the traffic rerouting scheme was developed, rerouting infor-mation was transmitted to field personnel for implementation. In connec-tion with the rerouting of traffic, the Manager of Local Respoase had the good judgment to call Ed Lieberman, who had developed the traffic contro! strategy employed in the LILCO Plan, to confirm with him the validity of ) the rerouting. I In response to the fuel truck impediment, EOC personnel called the Miller Place Fire Department to deal with the possibility that the spilled fuel might ignite and, af ter determining whose truck it was, called the T

J, owner, Hess Oil, to coordinate its removal. When the Traffic Guide at TCP

1. 40 received the rerouting order for the fuel truck, he assessed the situa-tion and radioed the Lead Traffic Guide at the Port Jefferson Staging Area that an additional traffic guide and six traffic cones were needed to effee-tuate the rerouting. These events clearly demonstrate that LERO person-i i

nel grasped the nature of ' the unrohearsed impediment and responded accordingly even though they had not been trained to deal with such a se- ) vere roadway impediment.

45. Q.

But you have modified LERO procedures and training since the Exercise to deal more offectively with traf fic impediments? j ) (Behr, Daverio, Weismantle] Yes. The Plan always provided the option to l A. reroute traffic, but the LERO training program had not included training on rerouting because studies indicated that only minor accidents were proba-p ble. PID at 795-796. While we continue to believe that only minor acci-dents are likely to occur, we have revised our procedures and expanded our i training program to include rerouting and other tasks associated with major ) ~: traffic impediments. We consider these changes enhancements to a Plan I and training program that were already adequate. As we will discuss in our i testimony on Contention EX 50.I, the LERO training program now empha-sizes major traffic impediments.

46. Q.

You stated that several of the cited contentions raise minor, isolated, and insignificant training problems. Can you provide examples? A. (Behr, Daverio] Yes. As described in Attachment 8, Contentions EX 38 and EX 42 raise minor, isolated, and insignificant problems. Egg Attach- [ ment B. Contention EX 38.N. which states "LERO personnel frequently ) misstated facts and provided inaccurate Information", is illustrative. As l L

) factual support for this allegation Intervenors state only that "at 9:16, it was incorrectly announced that the Site Area Emergency had been declared at 8:23, and that plant shutdown had occurred at 5:15. The correct times were 8:19 and 5:15." and that "LERO incorrectly announced that the winter ) population of the EPZ is higher than the summer population." These mis-statements are isolated and so trivial that they cannot conceivably consti-tute or demonstrate a flaw in the LERO training program. Moreover, we understand that such precise details are not what the public uses to make decisions on appropriate protective actions. These trivial misstatements would have absolutely no effect on the public health and safety. See LILCO's Testimony on Contentions EX 38 and 39 at 45-47. We also note that these misstatements must be viewed in the context of an entire day's worth of accurate public information when assessing the efficacy of the training program. CONTENTION EX 50.B

47. Q.

What does Contention EX 50.8 allege? A. (Behr, Daverio] The contention, which is set out in full text in Attach-ment A, alleges basically that the Exercise demonstrated that LERO failed a to train personnel to follow and implement the LILCO Plan and Procedures.

48. Q.

Have you analyzed the Exercise actions and events cited by Intervenors as support for this contention? 3 A. (Behr, Daverio] We have and, in our opinion, they do not support the charge that personnel were not adequately trained to follow the LILCO Plan and Procedures. The Exercise involved about 1000 LERO personnel over a 12-hour period performing hundreds of tasks in accordance with the l lb l t

' Plan and Procedures. When considered in this context, it is clear that the ( )- sporadic instances cited by Intervenors do not support their allegation of a f pervasive failure in the training of LERO personnel to follow and imple-ment the Plan and Procedures. In addition, many of the instances cited are ) clearly not relevant to the training issue raised by Contention EX 50.B; oth-ers appear to be relevant but under closer scrutiny prove to be without merit because they are factually baseless.

49. Q.

What do you mean that the contentions cited as support for Contention EX 50.B are irrelevant to the training issues? A. (Behr, Daveriol Of the contentions cited, Contentions EX 36, EX 38, l EX 39, EX 45, and EX 49 contain allegations that have nothing to do with training. Some concern equipment problems; others document Intervenors' disagreements with LERO actions. Eg Attachment B. For example, Con- ) tention EX 36 alleges that LERO made inappropriate protective action ree-ommendations to the public to evacuate. It states that because a wind shif t had been predicted it m_ Lay have been more appropriate for individuals to remain in their homes until af ter the wind had shif ted, and that af ter such i a wind shif t such persons !n_gy have been able to evacuate with a likelihood of less exposure and smaller doses. Even if true, this allegation, that a dif- ) forent protective action should have been recommended, is totally irrele-vant to the lasue of whether the training program effectively trained LERO personnel to follow the LILCO Plan and Procedures, in fact, the Radiation ) Health Coordinator considered the predicted wind shif t and, based on prior LERO training, determined not to change the recommendation to evacuate the public which had already been broadcast in EBS messages. See LILCO's ) Testimony on Contention EX 36 at 11-12,15-16. Thus, the Exercise events i i e

described in Contention EX 36 reveal that, contrary to the allegation in ) Contention EX 50.B. LERO personnel actually followed and implemented procedures. )

50. Q.

What about Contention EX 49 which appears to illustrate an inability to fo!- low procedures? A. (Behr, Daverio] We do not believe that Contention EX 49 provides factual support for EX 50.B. Intervenors allege in Contention EX 49.A that the ) radiological monitoring procedure frequently took longer than the 90 sec-t onds prescribed in the procedures and, therefore, that the LERO training program did not effectively train personnel to follow procedures. This con-tradicts the Shoreham Post-Exercise Assessment which noted that such l monitoring on several occasions, not frequently, took longer than 90 sec-onds, (Shoreham Post-Exercise Assessment at 80) and ignores FEMA's depo-sition testimony that monitoring was generally timely, except when the FEMA evaluator himself was monitored. See Deposition of Kowleski e_t al. (Jan. 29,1987) at 203-205. Thus, according to FEMA, monitoring was gen-erally accomplished within the prescribed time in accordance with proce-i j dures; occasionally it took longer. jgg LILCO's Testimony on Contention i EX 22.A and EX 49 at 8-9. Occasional deviations from procedural time j frames are not evidence of an inability to implement the procedure or of a I flaw in the program that trains personnel to implement procedures. In Contention EX 31, dealt with in Contention EX 49.A. Intervenors allege that there was insufficient staff at the reception center to monitor the expected numbers of evacuees. The quantity of personnel available is irrelevant to the issue of whether LERO trained personnel to follow proce- } dures. Similarly. Contention EX 49.B. in which Intervenors criticize the ) scope of FEMA's evaluation because FEMA did not evaluate LERO's " alter-nate monitoring plan" during the Exercise, does not indicate a training problem.

51. Q.

You stated several of the cited contentions raise issues that are insignifi-cant or minor. Can you provide examples? A. (Behr, Daverio] Yes. Contentions EX 37.D EX 38.N. and EX 45.E and PSA-ARCA-3 describe insignificant events and actions that neither individ-ually nor collectively reveal a basic flaw in the training program. See Attachment B. For example, PSA-ARCA-3 states LERO personnel used second floor telephones at the staging area, contrary to OPIP 4.7.1. While it is true that LERO personnel did not follow the letter of the procedure, the incident highlights a practical solution to the need for telephones to accomplish notification rather than demonstrating a flaw in the training program. FEMA recommended the procedure be revised to reflect the ac-tual practice of using second floor telephones, and the procedure has been revised accordingly. ) Contention EX 50.C

52. Q.

What does Contention EX 50.C allege? ) A. (Behr. Daverio, Weismantiel Contention EX 50.C alleges that the Exer-cise demonstrated that the LILCO training program has not successfully or j effectively trained LERO personnel to communicate necessary and suffi-cient data and information, to inquire and obtain such information, or to i recognize the need to do so. ) I l )

- ~ -. ) 44 53.- Q. Have you examined the Exercise actions and events that Intervenors cite as ) support for Contention EX 50.C? A. (Behr, Daverio, Weismantle} Yes. We have, and we strongly disagree with the allegation that the training program failed to train LERO personnel to ) communicate effectively. The events referenced by Intervenors must be put in context. The Exercise ran for a period of about 12 hours during which there were countless communications both oral and written between ) Exercise participants. The LERO message forms alone number about 650; there were also written press releases and EBS messages. We know that oral communications occurred when each of the 165 Traffic Guides radioed ) the Staging Area af ter reaching his location, that briefings were held in the EOC and Staging re (Shoreham Post-Exercise Assessment at x1, xiv, xv. xvil) and that status boards were maintained in' the EOC and Staging Areas ) (Shor'eham Post-Exercise Assesdinent at x1,; xv, xvil). Interveners focus .c only on the errors that occurred, leaving the impression that these few problems are indicative of a pervasive problem. Such is not the case. ) Even the instances cited by Intervenors do not, support their case. Many are clearly irrelevant to the issue of; whethee LERO effectively trained its personnel to communicate necessacy informatida. Others are ) factually baseless; they are unsubstantiated by Exercise e.vsnts and occur- ~ rences or they contain factual errors. The remainder describe Exercise events which, while they may be related to trEning, are minor bnd readily ) correctable by revisions in LERO procedures and training undertaken since the Exercise. These points are illustrated in the chart for Contention l EX 50.C in Attachment B. I )

g 54._Q. -What contentions or FEMA comments cited by Intevenors in support-of

O-Contention EX 50.C are clearly irrelevant to this training issue?

A. (Behr, Daverio, Weismantle] A quick look at Attachment B will show that Contentions EX 34, EX 36, and EX 42 are irrelevant to whether the Exer. O cise revealed a flaw in the training program rendering LERO personnel unable to commu'nicate necessary information. For example, Contention EX 34 alleges that LERO is incapable of providing prompt notification to - 10 the public in the event of a siren failure because, during the Exercise, Route Alert Drivers took too long to complete routes for three failed si-rens. The only issue raised is the timeliness of the response, not the ability O-to communicate information. In fact, in all three instances FEMA found that the Route Alert Drivers performed' as trained. See Shoreham Post-Exercise Assessment at 57, 64, and 74. In sum, the facts described in 0-Contention EX 34 do not support Contention EX 50.C's allegation that Ex-ercise actions and events demonstrated a flaw in LERO communications t' training. lO-

55. Q.

In Contention EX 45, consolidated with Contention EX 50, Intervenors allege a variety of communication failures. Does Contention EX 45 support the allegation that LERO failed to train its personnel to communicate nec-essary information? O A. [Behr, Daverio, Weismantle] No. Not one of the eight subparts of Con- - tention EX 45 supports the allegation that the training program failed to train LERO personnel to communicate information or to obtain necessary information. In Contention EX 45.A, Intervenors ascribe the delay in responding ( to the traffic impediments to communication failures. As discussed in t i O-LILCO's Testimony on Contention EX 41, the delays in LERO's response can be traced to primarily two causes. The first was the Evacuation Route O.

l l D Coordinator's failure to transmit all of the information contained on the original free play messages to staging area and field personnel, and to inform co-workers and superiors in the EOC of the impediments'. The sec-ond was the manner in which FEMA introduced the free play messages. B See LILCO's Testimony on Contention EX 41 at 19-20. These and other communications glitches referenced in Contention EX 45.A, and discussed in LILCO's Testimony on Contention EX 41, and scenario artifacts contrib-D uted to a delay in LERO's response, but did not prevent LERO from re-sponding appropriately to the traffic impediments. Therefore, they should not be used to cast a shadow on the entire communication training pro-3 gram. Indeed, as discussed above, other parts of the response to the traffic impediments demonstrate an ability to communicate necessary and suffi-cient information and to inquire and obtain such information. Thus, the D traffic impediment incidents do not support the allegation in Contention EX 50.C that the LERO training program failed to train personnel to obtain or communicate necessary information. [Behr, Daverio] Contention EX 45.B alleges that LERO's response to the Ridge Elementary School free play message demonstrated an inability to 3 communicate. The facts of that incident demonstrate that Intervenors are incorrect. Four minutes af ter the evacuation recommendation was made, 3 FEMA inserted the free play message at the EOC requesting a bus to evacu-ate 40 school children from Ridge Elementary School. This request was relayed to the Patchogue Staging Area where it was received by the Special O Populations Bus Dispatcher at 10:50. See Staging Coordinator, Bus Dis-patcher, Lead Traffic Guide Observer Form, Attachment G. The bus driver O

~ -... ~-. O _47_ was dispatched 'at 11:23, thirty three minutes later. See Special Popula - i .O -tions Evacuation Observer Form, A'ttachment G. This period was not inor-dinate considering that the Special Populations Bus Dispatcher was concur-rently handling the dispatch of approximately 44 other vehicles. See OPIP. !O : 3.6.5, Attachment 12. Once dispatched, the driver picked up a bus, at the yard at 11:43; he arrived at the school at 12:14. See Special Populations Evacuation Observer Form, Attachment G. The driver then traveled to the "O Nassau Coliseum Reception Center where he arrived at 13:51. I_d. In the meantime, the Public School Coordinator at the EOC called 1: the Longwood Central School District Superintendent (simulated) at 11:28

O'~

to tell him a bus was being dispatched to the Ridge School and requesting - that the Superintendent contact him when the bus arrived. See Public School Coordinator's Log, Attachment G. At 13:23, the Public School

O' Coordinator again called the simulated Superintendent who confirmed that the bus had already arrived and that it had left for the Reception Center.

When the Public School Coordinator called the Reception Center at 16:11 F 10 requesting confirmation, the bus had already arrived nearly three hours earlier. Thus it is not surprising that at 16:23, the Reception Center per-sonnel called the Public School Coordinator to tell him they could not con-firm the arrival of the Ridge School bus. The bus was already long gone. In our opinion the inability to confirm the bus's arrival is attributable to scenario artifacts. On the day of the Exercise, buses and cars simulating buses arrived at the Reception Center empty. Thus, when a bus simulating i i the evacuation of school children from Ridge School arrived, there was n thing to distinguish it from the other buses that would have been general O population evacuation buses. In a real emergency, a bus with 40 school O

l b children at the general population Reception Center would have been read-y..- ily recognizable. .Intervenors allege a failure of L'..dO to notify the Federal Aviation Administration ("FAA") and the Long Island Railroad ("LIRR") in Contention ) EX 45.C.. The Evacuation Coordinator did contact the FAA. See Attach-ment H. However, the FAA extension listed in the procedure was not the best number to call. With respect to the LIRR, the existing procedures did ) not call for notification. Since the Exercise, procedures for notifying the FAA have been modified and procedures for notifying LIRR have been included in the Plan. Thus, the Exercise did not demonstrate any failure by k LERO to communicate as required by the LILCO Plan or Procedures. In Contention EX 45.D Intervenors allege that LERO failed to distin-guish between DOE RAP and LILCO field monitoring data on the EOC dose assessment status board, that downwind dose measurement distances were erroneously reported as 7000 rather than 700 meters, and that extrapolated doses were erroneously reported as actual doses on the status board. Each of these was the subject of a FEMA comment which recommended changes in equipment, such as the size of the status board, or procedures to reduce the chance of error; those changes have been made. See Attachment B. These few instances of misrecorded data should not be viewed as a training failure. In Contention EX 45.E, Intervenors state that the secretary at the ) EOC who answered the telephone during the LERO Director's absence from the command room did not immediately deliver the message in writing to the Director. We do not see this as a significant problem. The secretary did not contravene any existing LERO procedures during the Exercise and )

L :/, h = 0 _49_ the Director did receive the information. Urgent messages for the Direc-O - tor could easily be designated as such by the caller thereby prompting immediate delivery by the secretary. Contention EX 45.F alleges communications failures of ENC, Public O Information, and Rumor Control personnel, citing as its only support Con-tentions EX 38 and EX 39. Contentions EX 38 and EX 39 describe Exercise events and actions that are generally irrelevant to training or do not indi-O cate a basic flaw in training. See Attachment B; LILCO's Testimony on Contentions EX 38 and 39. Contention EX 45.G contains a potpourri of alleged incidents: that Riverhead Staging Area personnel failed to record properly information on status boards; that radio reception at the Port Jefferson Staging Area was poor and " disrupted other essential communications"; that a Bus Dispatcher O at the Patchogue Staging Area made inaccurate announcements to bus driv-ers about dosimetry; and that a bus driver at the BNL transfer point was 0 misdirected. The failure to record properly information on status boards actually_ concerned the fact that the time of posting updated information on the status board at Riverhead was not always noted on the board. While Personnel were trained to include the time of posting, this minor omission O hardly demonstrated a programmatic flaw in the LERO training program. No similar comment was made with respect to the other Staging Areas and the problem noted at Riverhead was sporadic. 0: Intervenors' second allegation that communication with Traffic Guides from Port Jefferson was difficult due to poor radio reception and that communication with Traffic Guides disrupted other essential commu-g nications misstates the facts. The Shoreham Post-Exercise Assessment O

s nN ~ 50-specifically notes that the difficulties with radio reception were sporadic 0 and that the noisy transmissions interfered only occasionally with conver-sations of other personnel. Whether these communications were " essential" is not noted. More important for purposes of this testimony is the fact that this is a minor, isolated radio reception problem; it is not evidence of a - training problem. See Shoreham Post-Exercise Assessment at 56-57.- Third, as discussed in detail in our testimony on Contention EX 50.H. the Bus Dispatcher at Patchogue did not violate any procedure and made no faise statements. Fourth, the misdirection of a bus driver at the BNL transfer point was an isolated mistake which does not alone, or in conjunction with other minor, isolated mistakes, demonstrate a flaw in LERO's training program. During the Exercise,333 Bus Drivers were dispatched.. Each arrived at a g Staging Area where he was briefed on dosimetry and his route assignment, went to a bus yard where he was to pick up a bus (either actual or simulat-ed), drove to a transfer point to receive a route assignment from the Trans-O fer Point ' Coordinator who also dispatched him on a route, and ~ finally, drove to the Reception Center when directed to so by the Transfer Point Coordinator. The Bus Drivers received and followed countless directives- .O from Transfer Point Coordinators without error. A reference to one error on the part of a Transfer Point Coordinator hardly evinces a pervasive flaw o in the LERO training. Contention EX 45.H alleges that LERO was unable to transmit cor-rect information about Suffolk County Police Department ("SCPD") assis- .O_ tance. The confusion over SCPD assistance arose because FEMA personnel simulating Suffolk Count.y personnel gave inconsistent input to the LERO O

m _ EOC.. Inconsistencies about SCPD assistance are directly attributable to O. the inconsistent input from the FEMA simulators, not to any flaw in LERO training. The facts in Contention EX 45 provide no support for the allegation O ' n Contention EX 50.C that the events and occurrences during the Exercise i demonstrated a failure of the LERO training program to train personnel to obtain and communicate information. O-CONTENTION EX 50.D

56. Q.

What do Intervenors allege in Contention EX 50.D? ' A. (Behr, Daverio, Weismantle] In Contention EX 50.D, Intervenors allege that the Exercise demonstrated that LILCO's training program has not suc-essfully r effectively trained LERO personnel to follow directions given O by superiors during an emergency.

57. Q.

What factual support do Intervenors provide for this allegation? O A. (Behr, Daverio, Weismantle] Intervenors cite Contentions EX 41, EX 42 and EX 45 as well as FEMA comments cited in those contentions as pur-portedly describing Exercise actions and events which support their allega-tion. However, a careful analysis of the contentions and FEMA comments cited reveals they are generally unsupportive of Intervenors' allegation that I f the Exercise revealed a fundamental flaw in the LERO training program. iO ~ See Attachment B. It should be noted that an organization as large as LERO fielded in l the Exercise (about 1000 personnel) could not operate if its personnel did !O not follow the directions of their superiors. Intervenors attempt to focus attention on a few problems and ignore the thousands of directives issued IO l i

A by superiors that were swiftly and correctly carried out by LERO person-nel. For example, during the Exercise the deployment of 333 Bus Drivers, 165 Traffic Guides,38 Road Crew Personnel,19 Route Alert Drivers, and numerous other field personnel from the Staging Areas entailed briefings on dosimetry and field assignments, orders to dispatch, and direction of field personnel from the Staging Areas and EOC In evaluating these activities, FEMA noted excellent performance by supervisory personnel. For in-stance, the Staging Area Coordinator at Port Jefferson was described as clearly in charge and demonstrating leadership in the assignment of person-nel. The dispatch and direction of field workers from that Staging Area ) was considered by FEMA to be well organized. See Shoreham Post-Exercise Assessment at 56. Clearly, FEMA could never have reached these conclu-sions if personnel under the control of the Staging Area Coordinator ) repeatedly failed to follow his directions.

58. Q.

Intervenors cite Contention EX 41 as support for their claim that LERO failed to train its personnel to follow the directions of their superiors. Have you examined the facts presented in this contention for support for Contention EX 50.D7 A. (Behr, Daverio, Weismantle] Yes. The facts underlying Contention EX 41 ) concerning the traffic impediments have been described in detail in LILCO's Testimony on Contention EX 41. As that testimony demonstrates, nowhere in Contention EX 41 or the corresponding FEMA comments is ) there any evidence of LERO personnel failing to follow directions from a superior. See also Attachment B. -59. Q. Do Contentions EX 42 and EX 45 cited by Intervenors provide any factual ) support for Contention EX 50.D? A. [Behr, Daverio] No. Contention EX 42 generally alleges that LERO, as an

, organization, and individual members of LERO were presented with only a ) limited number of unanticipated situations and that they failed to respond adequately to those unanticipated events. The contention cites no instance during the Exercise when LERO personnel f ailed to follow directions. The ~ only event that might be characterized as indicating LERO personnel might not follow directions from superiors is the statement that some Traffic Guides indicated to FEMA evaluators that they might question the authori-ty of Lead Traffic Guides to authorize excess exposure. This reference must be put in context. A review of the FEMA Report shows that the two Traffic Guides questioned at Port Jefferson and the eight Traffic Guides questioned at Riverhead all understood who could authorize exposure in excess of the general public PAGs. See Shoreham Post-Exercise Assess-ment at 59,77. Only at Patchogue did two of the 14 Traffic Guides inter-viewed indicate they did not understand the chain of command for excess exposure authorization and that they might question the authority of the Lead Traffic Guide to issue the authorization. The fact that two out of the j' 24 Traffic Guides questioned indicated they might question the authority of the Lead Traffic Guide to authorize excess exposure does not demonstrate j a failure of the training program. Clearly,22 Traffic Guides absorbed the training, and understood and would follow procedures. Contention EX 45, which we have just discussed, does not support h Contention EX 50.D. The only instance of a failure to follow instructions l-from a superior is described in Contention EX 45.G. The Transfer Point Coordinator at the BNL Transfer Point neglected to relay the specific ) instructions from the Staging Area to one bus driver to proceed to the Reception Center rather than to the EWDF as is usual under the procedures. i

C The isolated, minor incidents described in Contentions EX 42 and O EX 45.G hardly demonstrate a pervasive failure to follow directions from superiors and, therefore, do not demonstrate a flaw in the LERO training program. xU

60. Q.

In general, did the Exercise results demonstrate a failure of the LERO training program to train personnel to follow directions? A. (Behr, Daverio, Weismantiel No. To the contrary, the vast majority of LERO workers functioned well; in large part, this may be attributed to a willingness and ability on the part of these individuals to follow the direc-tions of their superiors. CONTENTION EX 50.E

61. Q.

What do Intervenors allege in Contention EX 50.E7 g A. (Behr, Daverio, Weismantle] In Contention EX 50.E Intervenors allege that the Exercise demonstrated that LILCO's training program has not suc-cessfully or effectively trained LERO personnel to exercise independent O judgment or good judgment or to use common sense in dealing with situa-tions presented during an emergency or in implementing the LILCO Plan and Procedures. g

62. Q.

What is your understanding of the allegation in Contention EX 50.E7 A. (Behr, Daverio, Lindell, Mileti, Weismantle] It is difficult to grasp the O thrust of this contention. Intervenors seem to imply that the LERO training program is or should be aimed at teaching personnel to use com-mon sense. Responsible individuals are recruited as LERO personnel and O are provided comprehensive training to prepare them to accomplish a vari-ety of tasks in the case of an emergency at Shoreham. This training is O

1 ) aimed at ensuring that LERO can provide an effective response to an emer- ) gency and that personnel follow procedures, which have been designed to facilitate an effective response; it is not aimed at inculcating common sense in a trainee. The idea is not to train a group of free thinkers; LERO personnel, particularly in non-management roles in LERO, are to imple-ment the Plan, not develop ad hoc responses in the field. What Intervenors really mean by Contention EX 50.E is that their judgment differs from that of LERO personnel, and thus, in their view, LERO personnel did not exer-cise good judgment on the day of the Exercise. )

63. Q.

Do the contentions and FEMA comments cited by Intervenors support the allegation that LERO failed to train its personnel to exercise independent good judgment or common sense? A. (Behr, Daverio, Weismantle] No. Again, Intervenors cite a variety of 3 other contentions and FEMA comments that have nothing whatever to do with the exercise of independent judgment by LERO personnel. See Attachment B. In some cases, we think Intervenors criticize LERO person- ) nel merely for arriving at a conclusion that differs from theirs. For exam-ple, Contention EX 36 alleges that LERO personnel made an inappropriate protective action recommendation to the public to evacuate certain zones of the EPZ when a wind shif t was predicted. This is but Intervenors' con-flicting opinion. The Radiation Health Coordinator did exercise indepen-dent and good judgment when he decided not to countermand an order to evacuate when a wind shif t was predicted. See LILCO's Testimony on Con-tention EX 36 at 15-16; Shoreham Post-Exercise Assessment at 33. O W i 51

E - l

64. - Q.

Intervenors cite Contention EX 40 as presenting facts which support Con-tention EX 50.E. Does this contention support the allegation that LERO failed to train its personnel to exercise independent good judgment or com-mon sense? A. (Behr, Daverio, Weismantle] No. In Contention EX 40, Intervenors com-plain, among other things, that Traffic Guides were not at their posts when i the EBS message recommending evacuation was issued. The deployment of Traffic Guldes followed the LILCO Plan and Procedures, and the Traffic ) Guides were at their posts in sufficient time to effect a " controlled" evacu-- ation. See LILCO Testimony on Contention EX 40 at 3-4,6-10. Departure from these procedures by the " exercise of independent judgment" was not 1 called for and indeed, had it occurred, probably would have been cited by Intervenors in Contention EX 50.B as examples of LERO personnel's failure to follow procedures. )

65. Q.

Intervenors also cite Contentions EX 42 and EX 45 as supporting their alle-gations. Do you agree? A. (Behr, Daverio, Weismantle) No. In fact LERO's response to the traffic ) impediments, which is one of the subjects addressed in EX 42 and EX 45, generally shows that LERO personnel exercised good judgment in response to these unanticipated events. We will just note a few examples rather ) than repeat our prior testimony: the Traffic Guide who sought cones and the assistance of another guide to reroute traffic; the phone calls to Hess Oil Company and the Miller Place Fire Department; and the dispatch of a Route Alert Driver to monitor the radiation exposure of fire department personnel. l )

CONTENTION EX 50.F b

66. Q.

What do Intervenors allege in Contention EX 50.F7 l t i A. (Behr, Daverio] In Contention EX 50.F. Intervenors allege that the Exer-t ) cise 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 and nonconflicting information to the ) public through the media. l

67. Q.

Do the contentions and FEMA comments cited in Contention EX 50.F describe Exercise actions and events that support this allegation? ) A. (Behr, Daverio] No. Egg Attachment B. To support their allegation, Intervenors cite Contentions EX 37, EX 38, EX 39 and EX 40.C (which was l L consolidated with EX 38) and the FEMA comments referenced in those con- ) tentions. It is our belief that, in general, the Exercise demonstrated that LERO personnel were capable of providing the public with timely, accurate information about the emergency and that the facts alleged in Contentions ). EX 38 and 39 do not support EX 50.F. See LILCO's Testimony on Conten-tion EX 38 and 39. I To the extent that there was any delay in transmitting information to the media it is attributable to the breakdown of copying machines at the i ENC and had nothing to do with the training received by LERO personnel. LERO now has better copying capability. Five copying machines are avall-able to the ENC. As LILCO's Testimony on Contentions EX 38 and 39 shows, the essential role of the ENC Public Information group and the Rumor Control ) group was fulfilled. $_ee LILCO's Testimony on Contentions EX 38 and 39 at 8,13-50. First, the public was given accurate information directly and in a 1 i

I timely fashion. through the EBS messages. Second, media personnel ) received essential information in news conferences held periodically at the ENC by LERO and LILCO personnel. Intervenors' allegations in Contention l EX 50.F rest merely on the fact that, in their opinion, the media were not p timely provided with hard copies of the EBS messages or press releases. Hard copies of EBS messages and press releases are, at best, a tertiary ( means of providing information to the public. In any event, any problem at ) the ENC was related to an equipment failure, not training. Eg! Shoreham Post-Exercise Assessment at 53-54. Similarly, occasional delays in updating information at Rumor Con- ) trol do not evince a flaw in the LERO training program. First, Rumor Con-trol is a component of the onsite organization which is responsible for its training. Therefore, even if a training problem was identified, it would not be one related to the LERO training program. Second, Rumor Control did respond, as trained, to individual inquiries from the public in a timely man-ner and, for the most part, accurate information was provided. See ) LILCO's Testimony on Contentions EX 38 and EX 39 at 51-70. The alleged failures of LERO to communicate, as described in Con-tentions EX 38 and EX 39, were attributed by FEMA in its Post-Exercise y Assessment primarily to the malfunctioning of copying machines at the ENC. They are not training problems. )

68. Q.

Does Contention EX 37 cited by Intervenors support Contention EX 50.F7 A. (Behr, Daverio] No. First of all, Contention EX 37 was admitted only as a part of Contention EX 15 which alleges that the February 13 Exercise was not a full participation exercise. More importantly, Contention EX 37 has nothing whatever to do with the media. In Contention EX 37,Intervenors

1 p. e -SV ~ L allege LERO failed to determine, recommend or implement protective actions necessary to mitigate the consequences of the radiological release in the ingestion pathway. As support Intervenors state: (a) that documents generated at the EOC during the Exercise fail to indicate that LERO con- ) sidered further expansion beyond the EPZ of its prior recommendation to. shelter milk providing animals and place them on stored feed, (b) that LERO personne1' never considered the need for protective measures to )- cover animals in the food chain other than dairy animals, (c) that LERO personnel failed to make protective action recommendations concerning water and food, and (d) that LERO personnel apparently never completed )' the " Ground Deposition Calculation Workaheet for Particulate Radionuclide Releases" as required by LERO procedures. Not only is the Shoreham Post-Exercise Assessment devoid of any facts or conclusions in support of Intervenors' position that Contention EX 37 supports Contention EX S0.F. but FEMA noted that the Radiation Health Coordinator and the Nuclear Engineer demonstrated good judgment in making correct protective action determinations. 33g Shoreham Post-Exercise Assessment at 33. In his deposition, the Radiation Health Coordinator noted that the reason he did not complete the worksheet was ) that he had actual smear data that was more reliable. Egg Deposition of Richard Watts (Dec. 3,1986) at 87-88. This evinces the effectiveness of h the LERO training program. CONTENTION EX 50.0

69. Q.

What do Intervenors allege in Contention EX 50.07 A. (Behr, Daverio) In Contention EX 50.0, Intervenors allege that the l 3

L )- 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. ) 70 Q. Do Intervenors provide any f actual support for this allegation? A. [Behr, Daverio] Intervenors cite Contentions EX 27 and EX 28 as support for Contention EX 50.G. These allege generally that training in the use of f dosimetry, the use of KI, and the procedure for authorization of excess ra-- diation exposure has not been provided to school evacuation bus drivers and ambulette drivers. They do not allege that the content or effectiveness j LERO of training was flawed in any way. l

71. Q.

Has LILCO provided training to outside personnel on these radiological pro-tective procedures? ) A. (Behr, Daverio] Ambulance and ambulette drivers had received training l-prior to the Exercise, jgg, e1, Shoreham Post-Exercise Assessment at l 44-45. Ambulance and ambulette drivers were trained in radiological pro- ) cedures by completing LERO Training Program Module 9 " Personnel Dosimetry and Exposure Control." LILCO imestigated the problem noted the day of the Exercise and ) found that it was attributable to attrition among ambulance drivers who had been trained. To combat the attrition problem, training of ambulance and ambulette drivers has been conducted monthly since the Exercise so that new drivers from any ambulance company under contract to LILCO can receive training within one month. In its review of the LILCO response to EOC-ARCA-12 RAC noted favorably that LILCO had regularly scheduled ambulance and ambulette driver training sessions. 3 L

k t Training is also available for school bus drivers (gg Shoreham Plan 5 5.1.D) and before the Exerciae some drivers from the Seaman Bus Com-pony, which services the Shoreham-Wading River School District, had - received the training. However, because schools other than the Shoreham-Wading' River School District are not yet participating in emergency plan-ning for Shoreham, training of all school bus drivers had not been accomplished by the day of the Exercise. Of course, LILCO is willing and ) able to provide radiological training to the school bus drivers, and proco-dures are currently being developed to facilitate the participation of all school bus drivers in these radiological training sessions. ) CONTENTION EX 50.H

72. Q.

What do Intervonors allege in Contention EX 50.H7 ) A. (Behr, Daverio) In Contention EX 50.H. Intervenors allege that the Exer-cise demonstrated that LERO training is deficient in the area of dosimetry, exposure control, KI, and understanding of radiation technology and related areas.

73. Q.

What support for this allegation do Intervenors provide? ) A. (Behr, Daverio) As support for their allegation, Intervenors cite Conten-tions EX 27, EX 28, EX 42, and EX 45 and a number of FEMA comments dealing with radiological procedures that are generally duplicative of the ) contentions, jgg Attachment B.

74. Q.

Do the Exercise events and actions described in the FEMA comments cited l by Intervenors provide factual support for the allegation in Contention EX 50.H that LERO failed to train personnel effectively in dosimetry, ) exposure control, and K! use? J L_.

_ A. (Behr, Daverio] No. As the chart in Attachment B litustrates,Intervenors cite minor examples of individual failures with respect to personal radiological procedures. While not intending to minimize the importance of the safety of LERO emergency workers, it must be remembered that ) instances of field workers not reading their dosimetry or ingesting their KI would in no way impair protection of the public health and safety. More to the point, however, these instances of breaches in personal radiological ) procedures by LERO personnel do not individually or collectively demon-strate a flaw in the LERO training program. )

75. Q.

Nevertheless, hasn't LERO instituted changes in its radiological procedures and training? A. (Behr. Daverio] LERO is concerned about the safety of its personnel. As a consequence of FEMA comments based on the Exercise, LERO has made several modifications in its personnel dosimetry and exposure control training to emphasize to trainees the importance of reading dosimetry, knowing when to ingest KI, and knowing who and by what means excess ) radiation exposure is authorized. The specific changes are listed in the chart for Contention EX 50.H included in Attachment B. ) (Behr, Goodkind Lindell) Dosimetry and related areas are generally a problem at FEMA exercises (see Summary of Training Citations, Attach-ment D) because people find it hard to remember detailed information that they rarely use. The LERO post-exercise approach to correcting this prob-( lem involves the issuance of Identification Badges to all emergency workers. S_ee Attachment H. These badges, worn on the outer garments for easy access and identification, list personal radiological procedures on the back for quick reference in the field. Thus, LERO personnel need not

c: 3- )' attempt to memorize esoteric figures such as dose limits; they need only refer to the back of their badges. In our opinion, this, together with the inereened emphasis in training on personal radiological procedures, will be an effective solution. )

76. Q.

Do Contentions EX 42 and EX 45 cited by Intervonors provide support for the allegation in Contention EX 50.H that LERO failed to train personnel in radiological procedures? }- A. (Behr, Daverio] No. They are generally irrelevant. Only Subpart D of Contention EX 42 and the corresponding FEMA comment PSA-ARCA-16 deal with lasues at all related to Contention EX 50.H. They note that two ) Traffle Guides did not understand the procedures for excess exposure. These two isolated instances do not demonstrate a programmatic flaw in LERO training. As noted earlier in our testimony, FEMA questioned 24 ) Traffic Guides about dosimetry lasues; of those 24, only these two did not have a thorough understanding of what they had been taught. Egg Attach-ment B. Furthermore, the problem highlighted by these two incidents is 3 relatively minor in nature and readily correctable by modifications in LERO training to emphasize personal radiological procedures. jgg Attachment B. l Similarly, most of Contention EX 45 is irrelevant. Only Contention ) EX 45.0 deals at all with personal radiological procedures. It alleges, among other things, that the Bus Dispatcher at the Patchogue Staging Area made inaccurate announcements to bus drivers about dosimetry. The Dis-3 patcher, when giving last minute instructions to drivers before their deper-ture, failed to mention the dosage units associated with the 3.5 REM trigger point for calling in and did not mention the use of the 0-200 MREM 3 dosimeter and the 200 MREM trigger for calling in. The Dispatcher did not make inaccurate announcements as Intervenors allege in Contention i

_ _ _ _ _ _ - _ - _ _ - - _ _ _ _ - _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l l EX 45.G; rather, he failed to be complete and precise. jgg Shoreham Post-Exercise Assessment at 64-69. Again the incident has different import when placed in context.. The Dispatcher wac only quickly refreshing the drivers' memories just before their departure about comprehensive dosimetry instructions they had received during a briefing held only minutes earlier; hones his quick reference to 3.5 without the units. Even if i Intervenors' allegations were true, Contention EX 45.G would not by itself, f ); or in conjunction with any other sporadic instances, demonstrate a funda-mental flaw in LERO's training of personnel in dosimetry, K! use, or proce-dures for excess dose authorization. ) i i CONTENTION EX 50.!

77. Q.

What is alleged in Contention EX 50.17 A. (Behr, Deverio] In Contention EX 50.I. Intervonors allege that LILCO's proposals to modify training materials or procedures would not correct the l flaws revealed by the Exercise, i

78. Q.

What corrective measures has LERO undertaken as a result of the Exercise results? A. (Behr Deverio] Each of the FEMA comments has been or will be analyzed 3 and appropriate changes made to respond to training or procedural prob-i i lems underlying the comment. The charts in Attachment 8 present the l i training and procedure modifications instituted by LERO to correct prob-lems identified in the Shoreham Post-Exercise Assessment. Because the Exercise revealed that overall the LERO training program well prepared f emergency personnel to do their jobs, we felt major changes in the LERO ,) [ l lD i r I

) 65-training program were unwarranted and would actually be counterproduc- ) tive. Consequently, we have not restructured the basic LERO training reg-imen that had been approved by the Licensing Board in the emergency plan litigation. )

79. Q.

Can you describe any examples of alterations in the LERO procedures or training program to illustrate this approach? A. (Behr, Daverio] Yes. LERO has made several specific changes in its ) training program to meet problems revealed by its response to traffic impediments on the day of the Exercise. The position of Traffic Engineer has been added to minimize the adverse impact of any impediment to the ) evacuation by rerouting traffic. Information flow, timely response, equip-ment requirements, response priorities, and analysis of ovacuation impact are emphasized in revisions to portions of the LERO training program. These revisions are refincted in the LERO Traffic Control Tabletop Drill V (Rev. May,1986) conduct.d for the Traf fic Control Oroup and in the LERO Classroom Training materials for Session 8 " Traffic Control" (Rov. July, ) 1986) conducted for fleid workers.

80. Q.

Ilow do you evaluate the adequacy of such changes? ) A. (Behr, Daverio) In a number of ways. First, changes LERO instituted in response to the Shoreham Post-Exorcise Assessment have been reviewed by the FEMA Regional Assistanco Committee ("RAC"). Second, LERO contin- ) ually evaluates its training program internally. The officacy of the pro-gram is ovaluated through review of FEMA's Assessment, development of responses to prob! cms identified by FEMA. and review of LERO training drills and training materials. In the caso of drill reports,if positive worker performanco is not observed, the reasons for that performanco problem are b explored and modifications to the program may be made. Finally, although ) it is the intent of LERO to maintain the highest quality training program and to evaluate its efficacy continually, LERO, like every other offsite ra-diological response organization, will rely heavily on the FEMA post-exercise assessments of future exercises to point out training related prob-lems. )

81. Q.

What were the results of the RAC Review of LERO's responses to the FEMA comments? A. (Behr, Daverio] In general, as the charts in Attachment B lliustrate, the responses to FEMA comments woro reviewed favorably in the RAC Review ) of December 15, 1986. Ilowever, in some instances the RAC reserved judg-ment. For example, with regard to ENC-D-1, the RAC wanted LERO to complete its evaluation of copying equipment beforo determining if LERO had responded adequately to ensure timely hard copy distribution of mes-sages and releases to the press. LILCO continues to pursue resolution of those open items with FE 4 A. )

82. Q.

You mentioned periodic training drills conducted by LERO lias LERO con-ducted drills since the February 13,1986 Exercise? A. (Behr, Daverio] Yes. As part of its ongoing training program, LERO con- ) ducts a quarterly emergency preparedness training drill program. The pur-pose of the training drill program is three-fold. First, it gives new mom-bers of LERO the opportunity to practico, in as realistic an omorgency ) sotting as possible, the concepts they have boon taught in classroom training. They learn by doing their LERO jobs. Second, the training drills ) provido a forum for both now and old members of LERO to learn and prac-tico now procedures. The changes mado to proceduros as a result of tho

) Exercise have been practiced in recent training drills. Third, training dellts are integral to maintaining the specific emergency job skills learned by LERO members as well as the understanding they have of how LERO oper-ates as an organization and thele role in that organization. ) In order to accomplish these tasks, the drills and oxercises are con-ducted to simulate, as closely as possible, an emergency situation. Just as in a real emergency. EOC and Staging Area operations are carried out 10 ) Ehu, operations are carried out in response to information presented in the same form and manner it would be in an emergency, and field workers are briefed and dispatched. Ilabb gi gj. ff Tr.11,140 at 13,21,40-42.

83. Q.

What were the results of these training drills 7 l A. (llehr, Daverio] Keeping the purpose of the training drills in mind, the ) drills generally demonstrated that LERO workers were assimilating the changes that had been made in the LERO training program to rectify prob-loms revealed by the February 13 Exercise and that LERO workers wero ) maintaining their LERO job skills.

84. Q.

Wero the results of the training drills recorded? A. (llehr, Daverlo) Yes. Training drill reports woro draf ted for each of the drills conducted in the past year as part of the quarterly omorgency pro-paredness training drill program. In reading and interpreting these reports it is important to keep their remedial purposo in mind. The olmorvors and ) controllers who ovaluato the drills and produco the otmorvor forms from which the reports aro draf ted are instructed to discover and discloso prob-l loms. The purpose of drill reports themselves are to discloso to LILCO's ) management any problems in LERO so that thoso problems may bo

) 68-corrected. Thus, by design, they are critical of less than perfect perfor-mance.

85. Q.

What do the training drill reports say? ) A. (Hehr. Daverlo) It's probably best to look at the training drill reports on a shif t by shitt basis. The first training drill af ter the Exercise, held on June 6,1986, tr$volved LERO workers assigned to Shitt 2 at the EOC and ENC, ) Shilt 1 Riverhead Staging Area management personnel, and all Riverhead Traffic Guides. Many of these individuals had not participated in the Exer-cise. A modification of the Exercise scenario was used, and emphasis was ) placed on problems revealed in the February 13 Exercise, including traffic impediments, deployment of traffic guides, and testing the copying capabil-itles at the ENC. The drl!! also focused on testing new concepts proposed ) in Revision 7 to the LILCO Plant in particular,it examined the efficacy of the proposal to pre-assign Traffic Guides for the 0-2 milo zone and the new position of Traffic Engineer. ) A number of drill participants were new tralnces; all drill partict-pants woro presented for the first time with the now concepts of 0-2 mile pre-assignment of Traffic Guides, major road impediments and the now ) position of Traffic Engineer. No classroom sessions on these new concepts had occurred prior to the drill; only thoso LERO workers who participated in the Traffic Control Tabletop, hold on May 29 and June 3 and 4, had been introduced to the concepts of major traffic impediments and the new post-tion of Traffic Engineer. The report finds that the gravel truck impedimont was handled well ) but considers tho ono hour taken to respond to tho fuoi truck impedimont to be too long. Much of that hour dolay was attributable to misinformation about the fuel tructs location and the fact that players were dealing with ) assimilating a new player, the Traffic Engineer, into the organization and with the new concept of traffic rerouting. The Traffic Control Coordinator, who was practicing the 0-2 mile ) pre-assignment and dispatch of Traffic Guides for the first time, did not dispatch Traffic Guides immediately upon the order to evacuatet there was a 25 minute delay in getting word to the Staging Area, liowever, the D Staging Arca expeditiously dispatched the Traffic Guides in 13 minutes. Copler problems also occurred in the June drill but were remedied and have not recurred in any later drills. The same shif t drilled again on October 1 with better results. The participants, who had the benefit of enhanced classroom tralning on imped-iments and the experience of the June drill, dealt with the traffic impedt-ments well. The dispatch of Traffic Guides was also improved. The Riverhead Staging Area (the only staging area to have drilled in June) promptly dispatched Traffic Guides to the two mile zonet Port Jefferson and Patchogue were somewhat loss expeditious, in the caso of Patchogue, the report attributes the delay to the fact that the Lead Traffic Guides woro new to their positions. g Drills were held on September 10 and 17 for Shitt 3, which had not drilled as a team sinco late 1985. In thoso drills, Shilt 3 was introduced to the now procedures in Revision 7, the now concepts of 0 2 mito pre-q assignment of Traffic Guides and rorouting for major traffic impediments, and the now position of Traffic Engincor. Shilt 3 was drilled on two con-secutivo wocks to uso the first wook as an interactivo learning process with g Controllors providing assistance with the now material and personnot and D

_ _ _ _ to use the second as a hands-off training session. Drill objectives were to timely respond to road impediments, to [. reassign Traffic Guides to TCPs within the two mile EPZ and to roenforce dosimetry and K! training. The type and location of the traffic impediments were changed between the September 10 and September 17 drills. Shitt 3's response to the traffic impediments on September 10, 1986 was generally good. The Traffic Engineer was instrumental in developing ) rerouting schemes and there was good communication among all groups and the EOC relative to the traffic impediments, llowever, the report did note I a one-half hour delay at the Road Communicator's duk in transmitting ) Information to Road Crows; that delay was raised in the post-drill critique with the players and the importance of transmitting messages in a timely fashion was stressed. Although personnel at the Patchogue and Riverhead Staging Areas responded satisfactorily to the traffic impediments, the response from Port Jefferson was considered very slow and the Road Crow never did arrive. All in all, this is not surprising considering that this was the first timo personnel from Shilt 3 had practiced responding to traffic impediments. The September 17 drill results show that they learned from the mistakes made in the September 10 training drill. Overall the response ) to the traffic impediment was good. The Port Jefferson Staging Area, which had previously exportonced a delay in responding to traffic impedi-monts, responded excellently The information flow to Port Jefferson was ) timely and accurato, and the responso of the field workors was very good, The Hoad Crow arrived within 17 minutes of the request for help from tho scono of tho accidont, The responso of the Road Crow from tho Rivorhead ) Staging Area was also timolyt they arrived within 10 minutes of tho request.

)

r Both September drill reporta note the Traffie Guides for the 0-2 mile

) evacuation were preessigned and dispatched in an offielent and timely [ manner from all staging areas. The most recent drill report covers training drills held December 2 ) i and December 10 for Shilt 1. which was last drilled in the February 13, t 1984 Exercise. As with the September drills, Shif t 1 drilled on two consee-utive weekst the first week was a learning process to become familiar with ) the latest procedures and the accond week to reenforce the knowledge' gained during the first drill. Both the December 2 and December 10 drills showed good EOC and field responses to multiple traffle impediments. However, during the December 10 drill there was a delayed response by a e l Road Crew to a free play message of a duck treek impediment. The EOC f received nottee of the accident at 12:45 but did not dispatch a Road Crew boeause at that time no evacuation was recommended and the EOC assumed that, prior to such evaeustion recommendation. the Suffolk Coun-ty Po!!ee Department would handle traffle impediments as part of their normal duties. Once the evaeustion PAR was made at 12:44, LERO re-L sponded promptly to the acendent by dispatching Road Crew 2010 at 12:58. l The Road Crew arrived at the accident at 13:52 and reported to the EOC at ) (. 14:00 that the accident had been cleared. In evaluating the response to the duck truok, one must remember that the same traffle group was expedi-tlously handling three other traffle impediments that were introduced at l the ROC during a similar time frame. The EOC was informed of a brush j fire on the Long Island Expressway at 09:30, the duck truck impediment at j ) 12:48, a cement mixer impediment at 13:03, and a cesspool truck impedt-ment at 14:00. The response to all the Impediments other than the duck l )

~ 4: ) k -72. ~ p, truck was very good and shows an ability to deal with traffic impediments; f the delay in responding to the duck truck is primarily attributable to the decision not to dispatch a Road Crew when there was no evacuation recom-mandation. ). Expeditious deployment of traffic control personnel was also an objective of the December drills. The Traffic Guides assigned to TCPs i within the two mile evacuation zone for Port Jefferson manned their TCPs ) within about an hour (63 minutes on December 2 and 60 minutes on December 10). Similar11y, in Patchogue all the priority TCPs were manned within about one hour (63 minutes on December 2 and, with the exception of one Traffic Guide,60 minutes on December 10). Riverhead took approx-imately one hour and 15 minutes to man all the priority TCPs on both December 2 and December 10. LERO intends to continue to emphaalze expeditious deployment of Traffic Guides in training with the express pur-pose of having all three Staging Areas meet the approximately one hour deployment target.

84. Q.

Has LERO modified the Bus Driver training program in response to Exer-cise findings? f[,$[f,", / ' A. (Behr. Daverio] Yes. Atter the Exercise, LERO determined that the fall-e. ure of a few Bus Drivers to find bus yards and transfer points was attribut-u able to a practice in past drills of bus drivers volunteering to go to certain ,,s ).(( [,, locations. LERO instituted a two phase Bus Driver Driving Instruction Training Program designed to lamiliarize Bus Drivers with all potential assignments. In Phase I training, Bus Drivers were required to travel to all 17 bus company yards. In Phase !! training, Bus Drivers were dispatched ~, from a staging area and traveled to a bus yard and all of the transfer points

B-.in the staging area's responsibility. Each driver carried a Session Verifica-D'" tion Cover Sheet that was punched by a controller at the bus yard and/or the transfer points. Bus Drivers then traveled to-the Emergency Worker Decontamination Facility where the Verification Cover Sheets were turned Q-in. Large scale Phase II road rallies were conducted simultaneously with the drills -in September and October,1986. During the December 1986 C drills, makeup road rallies were conducted. The overall results of these-road rallies were very favorable. Although' there were a few isolated in-stances in which a driver missed a check point, in general the road rallies Q revealed significant improvement in Bus Driver performance. LERO will continue to evaluate Bus Driver performance during regularly scheduled drills now that the Phase II training has been completed. Q

87. Q., ; What have the drills'since the Exercise shown about dosimetry training?

A. [Behr, Daverio] Initially, the drills did not reveal substantial improvement O in the area of dosimetry, KI use, and exposure control procedures, but it must be noted that tDe vast majority of LERO personnel participating in the drills in June, September and October had not received the revised 1 training in which increased emphasis is placed on personal radiological pro-cedures. In addition, these earlier drills were conducted before the use of LERO Identification Badges (see Attachment H) which essentially obviate the need to memorize dose limits. The badges provide a handy, easy-to-read source of information on personal radiological procedures that a LERO yg field worker can quickly consult if he forgets does limits, who can autho-rize excess exposure, or when he should ingest KI. t =n c -n

! l l As revealed by the December drills, changes in training to reinforce radiological procedures and the use of Identification Badges resulted in a marked improvement in LERO workers' knowledge of radiological proce-dures. Field workers were briefed on the use of the LERO badges and urged to refer to them when necessary. Field Controllers observing various loca-tions reported that field workers read their dosimetry every 15 minutes and that they were aware of their dose limits. As the December drill report attests, LERO personnel knew the appropriate procedures and used their dosimetry and KI properly. J

88. Q.

Has the post-exercise training program succeeded in eliminating the possi-bility that individual members of LERO will make mistakes performing their assigned tasks? A. (Behr, Daverio] No amount of training could guarantee that LERO person-J nel would not make mistakes or commit errors. However, the LERO training program has been designed and subsequently modified to thor-oughly prepare emergency response personnel to perform essential tasks. ] The results of the February 13 Exercise and the drills conducted during the past year show that LERO personnel are well prepared to perform the es-sential tasks necessary to protect the health and safety of the public. 3 LILCO intends to keep LERO well prepared with its continuing training program, including training drills and critiques of those drills. We believe that an important element of any good training program is an hon- ) est self-critique process. Only by honestly evaluating past performance and striving to correct problems, can performance improve. LERO prides itself on its frank and thorough self-critiques. It is this continuing training program and self-critique process, as opposed to just an annual FEMA eval-uation, that helps us assure LERO is always ready to respond to an emergency. O

i .O 89. Q. Does this complete your direct testimony on Contention EX 50? A. [ Panel] Yes. O 'O

O l

O O

O 'O lO O ... ~.

B LIST OF ATTACHMENTS D A. Text of Contention EX 50 B. Charts Describing Other Contentions and FEMA Comments 3 Cited by Intervenors as Support for Contention EX 50 C. Summary of ARCAs and Deficiencies in Region II Exercises D. Summary of Training Citations for Shoreham and other Region II Exercises J E. Criteria for Critical Incidents / Events / Behaviors / Actions F. Summary of Cohesiveness Factors - All LERO Facilities G. Observer Forms: O_ Special Population Evacuation Observer, p. 3. Staging Area Coordinator, Bus Dispatcher, Lead Traffic Guide Observer, p. Sa. Public Schools Coordinators Log, pp.1-2. H. Evacuation Coordinator's Log, p. 2. I. LERO Identification Badges for Field Personnel J D D J O

1 ) J ? e ATTACHMENT A J J J D e O

I

o

Attachmsnt A ~ IO ' . Contention EX 50. [The alleged mistakes related to training raised in EX 42 will be dealt with under EX 50: and bases for EX 45 are consolidated with EX 50]. The ex-ercise demonstrated.that LILCO's Plan is fundamentally flawed in that members of

y

.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 and retraining of both LILCO and non-LILCO personnel in LERO. Training began in 1983 and, since that

O 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 training pro- - gram on an annual basis. Plan at 5.1-1,5.1-7 and 5.1-8; OPIP 5.1.1. At a minimum, this 401 requires each LILCO worker in LERO, each year, to attend classroom instruction ses-

sions on seven emergency response training modules and to participate in at least one tabletop session / drill / exercise; on average, however, LILCO personnel are required, each year, to attend classroom instruction sessions on nine modules and to participate in three tabletop session / drills / exercises. Plan, Figs. 5.1.1 and 5.2.1; OPIP 5.1.1. Thus, as of the time of the February 13 exercise, the bulk of LILCO's LERO personnel had al-

!O ready. undergone almost three years of training by LILCO involving, on average, class- ~ room instruction on a total of 27 training modules and participation in nine tabletop i sessions / drills / exercises. The large number of training deficiencies revealed during the exercise collec-tively demonstrate LILCO's lack of compliance with 10 CFR S 50.47(b)(14) and (15) and ,O NUREG 0654,5 II.N and O, and violations of LILCO's Plan and Procedures (chiefly OPIP i 5.1.1), as well as LILCO's overall inability to implement the LILCO Plan and Procedures as required by 10 CFR 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: IO made subject to confirmation by a finding, to be made by FEMA af ter a graded exercise, that the Plan can be satisfac-torily implemented with the training program submitted and that LILCO possesses an adequate number of trained LERO workers. !O- ' 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 exer-cise results thus disclose fundamental flaws in LILCO's training program which preclude a finding of reasonable assurance that adequate protective measures can and will be taken in the event of a Shoreham emergency. O Every instance of a LILCO training deficiency revealed during the exercise is

j not described at length in this contention because they are so numerous; virtually every

{ error made by a LILCO player during the exercise involved to some degree a failure of the LILCO training program to prepare personnel adequately to perform necessary !O

=- l ) actions. Thus, each " deficiency" and each "ARCA" identified by FEMA, plus each addi- ) tional error committed during the exercise and identified in other contentions, provides a basis for the Governments' allegation that the exercise results demonstrate a funda-i mental flaw in LILCO's training program. Because such errors are all identified else-where, 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.M ) EX 50.A. The exercise demonstrated that the LILCO program has not success-fully or effectively trained or prepared LERO personnel to respond properly, appropri-ately, 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. EX 50.B. The exercise demonstrated that LILCO's training program has been in-effective 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-A RCAs-3, 4, 7, 8, 9,12,13,14,15,16; R-ARC As 4, 5, 6; RC-ARCA 1. EX 50.C. [The alleged misstep described in EX 23 will be considered under this subpart]. The exercise demonstrated that the LILCO training program has not success-fully 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 ) Contention EX 34, 36, 38, 39, EX 41, EX 42, EX 45, and in the following FEMA conclu-sions:.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. EX 23. [Not separately admitted but will be considered under subpart C of EX 50]. EOC ARCA 5 refers to a 2.5 hour delay by LILCO personnelin correcting the ) error of reporting extrapolated dose data as actual measurements at other distances. FEMA Report at 41. This violates OPIP 3.5.2 and, depending upon the particular num-bers involved in the error, could result in substantially erroneous dose projections and wholly inappropriate protective action recommendations. Thus, this deficiency pre-cludes a finding that actual and potential offsite consequences of an accident are accu-rately 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 adequate protective measures can and will be taken in a Shoreham accident. 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 identi-fled 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 Re-ception Center as "RC." )

) EX 50.D.. The exercise demonstrated that LILCO's training program has not suc-p cessfully or effectively trained LERO personnel to follow directions given by superiors during an emergency. Exercise actions and events which support this allegation are de-scribed 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 suc- ) cessfully or effectively trained LERO 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. Exercise actions and events which support this allegation are described in Contentions EX 34, 36, 38-42, 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 program has not suc-cessfully or effectively 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. Exercise actions and events which support ) this allegation are described in Contentions EX 37, EX 38, and EX 40.C, and in the fol-lowing FEMA conclusions: ENC-D-1; ENC-ARCAs 2,3. EX 50.G. 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 1 are described in Contentions EX 27, EX 28 and in the following FEMA conclusions: EOC-ARCAs 11, 12, 13, 14, 15. EX 50.H. [The alleged errors described in EX 27 and 28 will be dealt with under this subpart]. 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 to 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 inca- ) pable 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-ARCAs 4, 5, 6. EX 27. [Not separately admitted but will be dealt with under subpart H of EX 50]. EOC FIELD ARCAS 1,3 and 5 refer to the fact that school bus drivers have had no training in dosimetry, 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 the protective actions of early dismissal and evacuation of ) school children in the EPZ. OPIP 3.6.5. Thus, these deficiencies preclude a finding that protective actions for school children can and will be implemented as required by 10 CFR S 50.47(b)(10), that means are in place for controlling radiological exposure of emergency workers as required by 10 CFR S 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 S 50.47(b)(15). They also preclude a finding of rea-sonable assurance that adequate protective measures can and will be taken in the event i of a Shoreham accident. EX 28. [Not seDarately admitted but will be dealt with under subpart H of EX 50]. EOC FIELD ARCA 4 refers to the fact that ambulette drivers are not all . trained in excessive exposure authorization and procedures. FEMA Report at 46. Ac-cording to the LILCO Plan, ambulette drivers are relied upon for implementation 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 fa-cilities and the homebound can and will be implemented as required by 10 CFR y 5 50.47(b)(10), that means are in place for controlling radiological exposure of emergen-cy workers as required by 10 CFR S 50.47(b)(11), or that radiological emergency re-sponse training has been provided to those called upon to assist in an emergency, as re-quired 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 (see 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 inabili-ty to remove the simulated impediments as provided in the Plan, and as would be neces- ) sary 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 simi-lar to those that would be required under the LILCO Plan in response to many other sit-uations which would occur in substantial numbers during a real emergency. Therefore, these failures are significant and preclude the reasonable assurance finding required by 10 CFR S 50.47(A)(1). Specifically: (1) 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 impedi-ment messages, contrary to OPIP 3.6.3 which requires such communication. The Evac-uation 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 in-formed of either one, however, until af ter 12:13, when he was informed by the FEMA controller. See 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 Coordi-nator, the Road Logistics Coordinator, the Transportation Support Coordinator, Lead ) Traffic Guides, Road Crews, Evacuation Route Spotters, and Evacuation Support Com-municators, as required by OPIP 3.6.3, led to the substantial delays and ultimate inabili-ty to respond adequately to the impediments. In fact, the delays caused by such failures would have been even greater in an actual 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 essential 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 ex- ) .pected to respond to the impediments, as required by OPIP 3.6.3 and OPIP 4.1.2. See 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 Com-municator for Route Spotters / Road Crews regarding the gravel truck impediment, including the fact that three passenger cars were involved in the accident. Similarly, essentialinformation 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. See FEMA Report at 30. Because of these failures, the equipment eventually sent to respond to the gravel truck impedi-ment was inappropriate and inadequate to remove the simulated obstruction, and the equipment eventually 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 af ter the free play message _had been injected. See 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 Sputter had been dis-patched as required under the Plan, and as apparently assumed by the LERO players. ' The spotter was not in fact dispatched until about 12:02. See 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 evacuation 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 j not been informed that there might be a need to send equipment to the site of the fuel truck impediment. See FEMA Report at 36. Thus, the initial errors, omissions, and failures to follow procedures and accurately transmit information were compounded by additional errors even af ter 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 y the overall emergency response. t

b (vi) As a result of the numerous failures and delays in internal LERO 7 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 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 essentialinformation 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 dis-patched to a bus yard to pick up a bus for 40 minutes. See FEMA Report at 38,66. Fur-thermore, there were no apparent efforts by LERO personnel to follow upon their dis-patch 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 LERO bus driver, when as of 4:23 he had still not arrived at the Reception Center, further demonstrates LILCO's inability to 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 personnel to perform these tasks evidences their inability to approporiately process, act upon, and communi-cate emergency information. Seen FEMA Report at 29. 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 person-nel failed to designate clearly on the EOC dose assessment status boards the distinc-tions between DOE RAP monitoring data and LILCO field monitoring data. See FEMA Report at 29-30. This failure demonstrates not only an inability to effectively commu-nicate important dose information and potentially significant distinctions between the ) Information from the two sources, but also an inability to recognize the significance of that distinction, contrary to the requirements of OPIP 3.6.1. Similarly, downwind dis-tances 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. See FEMA Report at 33. And, at the EOC, several extrapolated ) doses at various distances were reported as actual measurements rather than as proj-ected data on the dose assessment status board. It took two and one half hours to iden-tify and correct this error. See FEMA Report at 33. These failures indicate a signifi-cant inattention to detail and accuracy in recording, processing, and communication of data critical to the accident assessment and protective action recommendation pro-cesses which are at the core of an emergency response. Such failures could lead to ) dangerous errors in a real emergency. T

) _7 j EX 45.E. During the exercise, the LERO Director apparently lef t 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 signifi- -cant. 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. Finally, 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. See 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 ap-propriately act upon important emergency information and data demonstrated by the performance of LERO ENC, Public Information and Rumor Control personnel, in viola- ) tion of OPIP 3.8.1. These are detailed in Contentions EX 38 and EX 39. The fact that such personnel exhibited such communication inabilities 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 accu- ) rately, appropriately or in a timely manner obtain, record, transmit, or act upon emer- ~ gency data, in violation of OPIPs 4.1.2, 3.6.3, 3.6.4, 3.6.5, and OPIP 3.9.1. For example: (1) Personnel at the Riverhead Staging Area did not properly record or ap-propriately identify event status information on Emergency Event Status Forms or on status boards. See FEMA Report at 72. (11) Communications between the Port Jefferson Staging Area and Traffic Guides was difficult due to poor radio reception, and disrupted other essential commu-nications from that Staging Area. See FEMA Report at 56. Such difficulties would be much more serious in an actual emergency when many more traffic guides would be at-tempting 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 in-formation in fact led to confusion on the part of the bus drivers, and could be very dan-gerous in a real emergency. See FEMA Report at. 68. (iv) The Transfer Point Coordinator at the Brookhaven National Labora-tory Transfer Point was unable to follow instructions and transmit information and di-rections 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 Cen-ter. See FEMA Report at 65. )

} EX 45.H. LERO personnel at the EOC and staging areas were unable to transmit ) consistent or accurate information concerning assistance from the Suffolk County Po-lice Department ("SCPD") during the exercise. For example, at 9:19, the LERO Manag-er was told by simulators purportedly representing Suffolk County officials that no County resources would be availabe to assist LILCO during the exercise. This f act 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 Evacuation Coordinator ) recorded in his log that the SCPD had offered to provide LILCO whatever assistance was required, and the Traffic Control Coordinator was advised of this purported infor-mation at 9:35. At 10:02, the Evacuation Coordinator notified the staging areas that the SCPD had offered assistance in traffic control, route alerting, and route spotting, and that police officers would be dispatched to the staging areas for briefings. And, be-tween 10:02 and 10:15, the Traffic Control Coordinator informed (1) the Riverhead ) Staging Area to expect 39 SCPD officers to report for assignment to traffic control and route spotting functions; (11) the Port Jefferson Staging Area to expect 74 SCPD offi-cers and ; (iii) the Patchogue Staging Area to expect 37 SCPD officers. These mes-sages, 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 perscnnel. 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 prob-lems. ) ) ) b ) )

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4 CONTENTION EX 50,A LERO FAILED TO TRAIN PERSONNEL TO RESPOND EFFECTIVELY TO UNANTICIPATED AND UNREHEARSED SITUATIONS CONTENTION CITED AND STATUS AS SUPPORT FOR El 50.A MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS EX 39: Public Information A: ENC delayed in opening; Factua!!y baseless. ENC no information until first activation was timely. See nsws conference at 0840 FEMA Report at 52. LILCO is-sued press releases at 0625 and 0639. 6: First news release da-Factually baseless; irrelevant Essential emergency infor- . Reserved decision based on layed and inaccurate to training. Information was mation summarized and fact that LERO had not yet (ENC-D-1: Insufficient timely provided. Equipment transmitted via computer decided to upgrade copying copying capabilities re-problem. not training, caused from the EOC'to ENC and all capabilities. suited in delays in distri-delays in distributing updated rumor control locations st-bution of information) information. New procedures multaneously. Additional and better copying capability copying equipment (total of should obviate problem. 5 machines) ensures suffi-cient capability in event of unanticipated machine failure. C: Second news release de-Id. Id. Id. layed (ENC-D-l: Insufft-cient copying capabilities resulted in delays in dis-tribution of information) D: Insutticient copying Irrelevant to training. Id. Id. capa.b i l i t y at ENC delayed Equipment problem caused de-distribution of information' lays in distributing updated (ENC-D-1: Insufficient information. New procedures copying capabilities re-and better copying capability suited in delays in distri-should obviate problem, bution of information) E: Insufficient / inadequate Irrelevant to training. Facts The suggested displays and Adequately address the en-maps and displays based on equipment deficiency. status boards have been arcise issue. (ENC-ARCA-2: Insufficient provided to the ENC. maps and displays) rt' F: EDS message contained Minor and corrected by.revi-Press Release procedures The plan modifications ade-02 outreneous information sions in LERO procedures and have been modified. EBS quately address the O { (ENC-ARCA-3: EBS messages followup training, messages will no longer be -esercise issue. D rt Od

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Q~ (V 'Q TQ ,V '-~~ ~ ) M( g CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.A MODIFICATIONS IN LERO RAC REVIEW OF LERO' CORRESPONDING FEMA COuMENT PROCEDURES & TRAINING MODIFICATIONS contained'entraneous infor-released. The Coordinator. matten) of Public Information pre-pares press releases using an established format. The Director of Local Response approves it. The LERO Spokesperson directs dis-tribution to the media. LERO Public Information Group Personnel receive training in the new proce-dures in the LERO Public Information Tabletop Orill (Rev. Now. 1986). Gs Press releases Duplicative of Contention (see EX 38.8 above) (see EX 38.8) lata / inaccurate (ENC-D-1: Ex 38.C. Irrelevant to Insufficient copying capa-training. Information was bilit ies r esul ted in delays timely provided. Equipment in distribution of informa-problem caused delays in tion) distributing updated informa-tion. New procedures and bat-ter copying capability should obviate problem. Hs Evacuation decision Id. (see EX 38.8 above) (see EX 38.8) given to media too late (ENC-D-Is Insufficient copying capabilities re-sultad in delays in distri-bution of information) 1: Media requested not to Factually baseless. In accor-inform public of LERO dance with LERO procedures workers' ingestion of KI media were never briefed about LERO workers' K! ingestion. Js ENC personnel unable to Factually baseless. Facts do provide information to not demonstrated a failure to media; undble to contact provide the media information. Murketing Evaluations Ks Not admitted. L ENC log falsely indi-Esercise events do not impli-csted gravel truck impedt- 'cate deficiency in training. ment was being removed The inaccurate information was not released to the public or the media. T

11 CONTENTION CITED AND -STATUS AS SUPPORT FOR EX SO.A MOOIFICATIONS IN LERO RAC REVIEW OF LERO . COR*ESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS da ENC personnel'could not Factually baseless. LERO cnswar questions about im-spokesperson reported essen-pidtment tial details including loca-tion of road blockage and rerouting of traffic. N-ENC misstated facts Insignificant, isolated errors Ebout (1) when Emergency during a whole day's. worth of-was declared (0823, correct public information do not es-time was 0819), (2) EPZ tablish a training problem, winter vs. summer popula-tion 0: Delayed delivery of Onsite functions irrelevant to (see.EX 38.8 above) (see EX 38.8) press releases 4 and 5 to training. Media Monitoring Media Monitoring (ENC-D-1: receives information through Insufficient copying capa-EBS messages, does not have bilities resulted in delays immediate need.for news re-in distribution of informa-leases. Equipment problem tion) caused delays in distributing updated information. New pro-cedures and better copying ca-pability should obviate prob-lem. Pa Rumor Control operation DupItcative of Contention ineffective as described in EX 39. 1 Contsntion EX 39 Q: LERO modifications Irrelevant to training. would be inadequate to rem-Conclusory allegation not 4 ady " deficiencies" based on Enercise events, i EX 39: Rumor Control A; Call Boar d Operators Onsite function. Irrelevant (see EX 38.8 above) (see EX 38.8) had inaccurate / outdated to LERO trainings factually infurnation; answered in-baseless. The few instances quiries too slowly or in-of superseded information re-correctly (ENC-D-1; Insuf-sulted from an equipment prob-ficient copying capabill-lum. New procedures and bat-ties at ENC resulted in de-ter copying capability should Icys in distributing infor-obviate problem. mation to rumor control personnel) Os Late responses to Onsite function, irrelevant

7-g y-g y zy-CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.A MODIFI' CATIONS IN LERO RAC REVIEW OF LERO COR*ESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Simulated rumor messages, to trainings conclusory and factually baseless. Responses to messages were as expedt-tious as accuracy would allow. Personnel acted according to procedures. C: Rumor Control personnel Onsite function. Irrelevant (see EX 38.8 above) (see EX 38.8) provided inaccu-to training. Information pro-rato/ superseded information vided was generally timely and (ENC-D-13 Insufficient correct. Isolated instances copying capabilities at ENC of inaccurate information were resulted in delays in based primarily on an equip-distributing information to ment problem. New procedures rumor control personnel) and better copying capability should obviate problem. Ex 44: (1st sentence con-Irrelevant to training. Fac-Pnlidated with Ex 38 and tually baseless. Exercise EX 39): Failure tu provide events do not support allega-Eccurate, clear information tion of substantial evacuation would create a substantial shadow. evacuation " sliado w " EX 22F: False assumption Irrelevant to training, of no premature evacuation Conclusory allegation not based on Emercise events. Ex 41: Traffic Impediments As Slow mobilization of Irrelevant; not a training Rord Crews problem. Factually baseless. Sufficient Road Crews were mo-bilized in accordance with procedures. B Failusw to respond ade-Duplicative of Contentions Traffic Engineer added to Adequately address the is-quately to two road impedi-EX 42.B and 'X 45.A. Facts do EOC. LERO Traffic Control sues raised in the exer-msnts: (1) Communications not demonstrcte a pervasive Tabletop Drill V (Rev. May,

cise, failures at EOC (EOC-D-1:

training flaw. Isolated in-1986) and PAR / Accident Man-Dslays in responding to two stances of communciations agement Tabletop Drill III svacuation impediments) problems readily correctable (Rev. Aug. 1986) emphasize by revisions in LERO proce-responding to evacuation dures and training. impediments including com-nunication of information, equipment requirements, re-sponse priorttles, and al-tornate traffic routing.

CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.A MOOIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS LERO Classroom Training Program materials for Ses-ston 8 " Traffic Control" (Rev.. July, 1986) empha-sizes communication of in-formation and timely re-sponse to evacuation imped-1ments. (2) Delay in fleid Minor and readily corrected by 'LERO Traffic Control proce-Adequately address the en-verification of fuel truck revisions in LERO procedures dures have been revised.to arcise issue, impsdiment (LOC-ARCA-9: and training. expedite dispatch of per-D3tcy in field verification sonnel responding to inci-of fuel t r uc k impediment) . dents identified by the EOC. LERO field personnel now receive training with increased emphasis on re-sponses to evacuation im-pediments. Modifications have been made ins (1) LERO Evacuation Route Spotter Tabletop Drill III (Rev. May, 1986); (2) LERO Staging Area Management Tabletop Drill III (Rev. May, 1986): (3) LERO Tref-fic Control Tabletop Drill V (Rev. May, 1986): (4) LERO Classroom Trair:1ng Program materials for Session 8 " Traffic Con-trol" (Rev. July, 1986). (3) Appropriate Factually baseless. Personnel LERO Traffic Control Tab-Adequately address the en-p3rsonnel not dispatched to and equipment required to letop Drill V (Rev. May. ercise issue, rcmove multiple vehicle ac-clear blocked road were sent 1986) emphasizes commualca-cidsnt road impediment to accident. Facts do not tion directly between the (PSA-ARCA-82 Appropriate demonstrate a training flaw. EOC and Road Crews to on-personnel not dispatched Any problems were minor and sure appropriate response, to clear nualtiple vehicle readily correctable by revi-accident ru4d impediment) stons in LERO procedures and LERO Classroom Training training. Program materials for Session 8 " Traffic Control" trains traffic control per-sonnel, including Road Crews, to communicate by radio with the Road Logis- . tics Coordinator at the EOC.

n_ CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.A MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS C Not admitted. D: Not admitted. E: Addition of Traffic En-Irrelevant to training. Olnser to EOC would not Conclusory allegation not eliminate flaws in dealing based on Emercise events, alth road imped imen t s Ex 221: (dedit with under M. EX 45) Erroneous assump-tien that LERO needs to be Eble to deal with only two road impediments EX 42 (Hases incorporated in EX 38 & EK 39) A: Untimely / ineffective Dupilcative of Contentions (see EX 41.8 above) (see EX 41.8) response to road impedi-EX 41.8 and FX 45.A. ments (EOC-D-1: Delays in responding effectively to road impediments) 0: Untimely / inadequate re-Duplicative of Contention LERO procedure. modified to Adequately address the en-sponse to Ridge School EX 45.8. Factually baseless. ensure additional staff are arcise issue. evacuation message Dispatch of bus 33 minutes used to assist the Special (PSA-ARCA-11: Forty minute after receipt of request.at Populations Bus Dispatcher. dalay in dispatching Bus PSA was timely under circum-LERO. Classroom Training ma-Driver to evacuate school stances. terials for Session 9, children) " Transportation Coordinator" and " Pro-tactive Actions for Special Populations" emphasize need for assistance in expediting special popula-tion buses. Transportation Tabletop and Staging Area Management Tabletops also emphasize this. C: Inability to handle un-Duplicative of Contention espected r umor s EX 39. D Inability of Tratftc Readily correctable by revi-LERO Classroom Training Adequately address the en-Guidas to respond to stons in the LERO procedures Program materials for arcise issue. ovecuee questions and training. Session 8 " Traffic Control" (PSA-ARCA-7: Traffic (Rev. July, 1986) now l i

z -.. _ CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.A MODIFICATIONS IN LERO RAC REVIEW OF LERO' COR'ESPONDING FEMA COMMENT PROCEDURES & TRAINING , MODIFICATIONS Guid3s lacked complete in-trains Traffic Guides to formation on the appropri-instruct evacuees to Itsten oto destination for to the EBS radio station for svacuation information cvecuees including evacuation desti-nations. LERO Identifica-tion Badge for-Traffic Guides, listing job-related 1 duties on the back. in-structs them to advise evacuees to-listen to the EBS station. D. (cont.) Inability of Facts do not demonstrate a Traffic Guides now wear 4 Traffic Guides to know en-pervasive flaw in LERO LERO Identification Badges cess dcse authorization training program. Minor, iso-enumerating radiological procedtre (PSA-ARCA-16: lated incidents readily cor-procedures on the back for Traffic Guides did not un-rectable by revisions in LERO quick reference in the ? d3rstand oncess dose autho-equipment and training. field. The Badge clearly rization procedures) states that they will re-i ceive authorization for en-cess exposure from the Lead Traffic Guide. Excess dose authorization procedures 1 are now emphasized in re-2 vised LERO Classroom i Training materials for Session 3 " Personnel Dosimetry and Emposure Con-trol" (Rev. July. 1986). i E: Some uus drivers failed LERO procedures and training Bus Drivers are now as-Adequately address the is-4 i to carry out their assigned have been modified to ensure signed routes randomly in sues raised in the emer- ~ duties (PSA-D-6 Bus driv-that every Bus Driver is capa-order to familiarize them cise. crs delayed, went to wrong ble of driving any randomly with a variety of routes trcnsfer point, or missed assigned route. they might be called on to segment of assigned route) drive. t Transfer Point Coordinators f now check bus dispatch forms upon Driver's arrival to confirm that the Driver is at the correct transfer point. LERO Classroom Training Program materials for Session 9 " Transportation

r; v ' -- v - v y-y v-y- CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.A MODI 51 CATION 5 IN LERO RAC_ REVIEW OF LERO COR*ESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Coordination" (Rev. July, 1986), the Transportation Tabletop (Rev. Nay, 1986) and - the Staging Area Man-agement Tabletop (Rev. May, 1986) emphasize that Bus Drivers report to the Transfer Point Coordinator for vertftcation of the Bus Dispatch Form to ensure that the Driver is at cor-rect location. Sus Driver Driving Instruc-tion Training (Rev. May, 1986) emphastzes the new vertftcation procedures. The session includes a Road Rally in which each Driver runs a route to designated check locations. F Traffic Guides arrived Factually baseless. Traffic Traffic Guides are now Adequately address the is-late at control points Guides critical to a con-prestaged for immediate suas raised in the emer-(RSA-D-2: Traffic Guide trolled evacuation manned dispatch within the C-2 cise. d3 layed in arriving at con-their posts to a timely mile EPZ upon emergency trol points) fashion. Irrelevant to declaraticn. LERO Traffic training issue. Any problem Control Tabletop Detti V was procedural. Procedures (Rev. May, 1986) and have been modified. Staging Area Management Tablotop (Rev. May, 1986) emphastre prestaging and rapid deployment of Traffic Guides in 0-2 mile EPZ. LERO Classroom Training Program materials for Ses-ston 8 " Traffic Control" (Rev. July, 1986) empha-sizes pre-equipping and pre-assigning of Traffic Guides. F. (con.t) Hus drivers not Irrelevant to training issue. LERO Classroom Tretning Reserved decision pending dibpatched in timely Detvers were. dispatched ac-Program materials for completion of further modt-fashion (P5A-ARCA-1: Bus cording to procedures. Prob-Session 9 " Transportation fication of LERO procedures drivers not dispatch 9d lem related to quantity of-Coordination" (Rev. July, to assure timely briefings untti 2 hour s af ter trained personnel available to 1986) now emphasizes that and distributton of cmergency declaration) assist Dispatcher in distribu-Transfer Point Coordinator dostmetry to Bus Drivers.

CONTENTION CITED AND STATUS AS SUPPORT FOR Ex SO.A MODIFICATIONS IN LERO RAC REVIEW OF LERO COR*ESPONDING FEMA COMMENT. PROCEDURES & TRAINING' EODIFICATIONS -{ tion of dostmetry. FEMA rec-assist Bus Dispatchers with ] ommended additional. personnel. distributton of materials .j be provided to assist in bus and dostmetry-in orGer to ) dispatching. Sus dispatch expedite dispatch of Sus .1 procedures have been modified

Drivers, to provide additional help.

The Transportation Tabletop i and Staging Area Management i Tabletop Drills (Rev. May. l '1986) emphasize need for assistance in rapid dis-patch of buses. Dostmetry Tabletop Drill VI (Rev. Now. 1986) emphastaes need for rapid distributton of-dosimetry to large groups such as Sus Drivers. G: ENC personnel failed to Duplicative of Contention respond appropriately to EX 38. media questions OTHER FEMA COMMENT CITED STATUS AS SUPPORT FOR Ex 50.A MODIFICATIONS IN LERO RAC REVIEW OF LERO PROCEDURES & TRAINING MOOIFICATIONS EOC-ARCA-2: Confusion re-Irrelevant to training conten-LERO will implement the new. RAC made new recommenda-garding the method of nott-tion. Procedures were fol-recommendation that it con-tions which LERO is imple-fying the Federal Aviation lowed during the esercise. tact FAA directly. A let-menting. Administration ("FAA") FEMA subsequently recommended ter of agreement with FAA a new notification procedure will be obtained and EOC (RAC Review. Dec. 15, 1986), personnel designated and trained to communicate with FAA. EOC-ARCA-3s The Long Is-Irrelewsit La training conten- 'LERO procedures have been Planning provisions are ad-Ignd Railroad ("LIRR") was tion. Procedures were fol-modified. The Evacuation equate. LERO should obtain not nottfled lowed during the esercise. Coordinator notiftes LIRR a letter of understanding of. emergency status. LERO from LIRR. Accident Management Tab-letop Drill III (Rev. Aug. 1986) emphasizes new re-sponsibility of Evacuation Coordinator to notify LIRR. PSA-ARCA-b Unsecured door Irrelevant to training conten-PSA Guard Post 1 now as-Adequately address the en-at tire escape on east side tion. Facts do not implicate signed responsibility for ercise issue. of building a training flaw. LERO securing the entrance.

OTHER FEMA CGMMENT CITED STATUS AS SUPPORT FOR EX 50.A MODIFICATIONS IN LERO RAC REVIEW OF LERO PROCEDURES & TRAINING esOOIFICATIONS procedure modified. PSA-ARCA-9 Instructions Minor, isolated instance not LERO Staging Area Manage-Adequately address the en-to a Bus Driver to proceed-indicattwo of pervasive flaw ment Tabletop Drill III and orcise issue. to the Reception Center in training program. Training Transportation Tabletop were not properly trans-has been modified. Drill (Rev. May, 1986) en-mitted at BNL tranfers phastae training of Trans-paint for Point Coordinators to follos staging area direc-tions-in instructing Sus Drivers. LERO Classroom Training Program materials for i Session 9 "Transportat ion - Coordination" and " Pro-tective Actions for Special Populations" (Rev. July, 1966) nos emphastae the proper destinat tos.s f or Bus Drivers. PSA-ARCA-10s Residences of Irrelevant to training conten-LERO is evaluating maps for Adequately address the en-some persons were difficult tion. FEMA recommended Delv-clarity and if marranted orcise issue. for Drivers to find ers De provided more dotatted will include utility pole maps and descriptions of pick numbers for merking pick up up points, points. 1 1 l I 'W l i

4 CONTENTION EX 50.8 LERO FAILEO TO TRAIN PERSONNEL TO FOLLOW 4 AND IMPLEISENT ITS PLAN AND PROCEDURES 2 CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.8 MODIFICATIONS IN LERO RAC REVIEW OF LERO COR*ESPONDING FEMA COMMfMT PROCEPORES & TRAINING MODIFICATIONS Ex 33 Not admitted 1 EN 33 Not admitted Ex 3%: Insporopriate pro-Factually baseless. LERO fol-tective action recommenda-lowed applicable procedures. tions (wind shift) FEMA Report at 33. EX 37: Pr otect two Action i &* commendations (Not sepa-rotely admitted but incor-p9 rated into subpart I of EX 15) I As Failure to eatend PARS Irrelevant to training conten-beyond 10 mile EPZ tions. Factually baseless. LERO followed applicable pro-cedures. FEMA Report at 33. S: No PARS for other than Id. dairy aqtmals C No PANS concerning Id. eater and food 0: Fa t lur e to complete Inconsequential. Actual data ground deposition worksheet were avallaule so completion of an estimatiue. worksheet was l unnecessary. EM 34: Public Information A: ENC delayed in open'.13 Factually baseless. ENC no information until first acttwatten was timely. See noms conference at 0840 FEMA Report at 52. LILCO is-sued press releases at 0625 and 0639. 3: First news release de-Factually baseless: trrelevant Essential emerDency infor-Reserved decision based on j layed and inaccurate to training. Information was mation summarized and fact that LERO had not yet w.

{ { ~ ~ / ~ [ ~~~ ~ ~ ~~ ' ~ ) i I CONTENTION CITED AND -STATUS As SUPPORT FOR Ex 50.8 MODIFICATIONS IN LERO RAC REVIEM OF LERO-CORR E S PONDI NG F E MA COMMENT PROCEDURES & TRAINING MODIFICATIONS (ENC-D-l: Insufficient timely provided. Equipment transmitted wta computer decided to upgrade copying - copying capabilities re-problem not training, caused from the EOC to ENC and all capabiltties.. cultcd in delays in distri-delays in distributing updated rumor control locations si-t bution of information) Information. New procedures multaneously. Additional and better copying capability copying equipment (total of should obwlate problem. 5 machtnes) ensures sufft-l cient capability in event I of unenticipated machine failure. 1 l 'Cs Sscond news release de-Id. Id. Id. leyed (ENC-D-la Insufft-cient copying capabilities resulted in delays in dis-l tribution of information) "Da Insufflctent copying Irrelevant to training. Id. Id. capability at ENC delayed Equipment problem caused de-distribution of information lays in distributing updated (ENC-D-1: Insufficient information. New procedures copying capabilities re-and better copying capability sulted in delays in distri-should obwlate problem, butten of information) E Insufficient / inadequate Irrelevant to training. Facts The suggested displays and Adequately address the'en-maps and displays based.on equipment deficiency. status boards have been orcise issue. (ENC-ARCA-2: Inhufficient provided to the ENC. maps and displays) F: EBS message contained Minor and corrected by rewt-Press Release procedures The plan modifications ade-entraneous information stons in LERO procedures and have been modified. ESS quately address the emer-(ENC-ARCA-3: EBS messages follomup training, messages allt no longer be Cise issue. contained entraneous infor-released. The Coordinator mation) of Public Information pre-pares press releases using an established format. The Director of Local Response approves it. The LERO Spokesperson directs dis-tribution to the media. LERO Public Information Group Personnel recetwo ] training in the new proce-i dures in the LERO Public Information Tabletop Drill (Rev. Now. 1986). 1

i CONTENTION CITED ANO STATUS AS SUPPORT FOR Ex 50.9 MODIFICATIONS IN LERO. RAC REVIEd OF LERO l ' CORRESPONDING FEaBA COsmeENT PROCEOURES & TRAINileG MOOlFICATIOseS l Ga Press releases Duplicative of Contention (see Ex 38.8 above) (see Ex 34.5) l late / inaccurate (ENC-D-Is EX 34.C. Irrelevant to Insufficient copying capa-training. Information was l bilities resulted in delays timely provided. Equipment l in distribution of informa-problem caused delays in j tlan) distributing updated informa-tion. Nem procedures and bet-ter copying capability should I obviate problem. ( H; Evacuation decision re-Id. (see EX 38.8 above) (see EX 38.8) parted to media too late l (ENC-D-la Insuffletent l copying capabilities re-l suited in delays in distrl-button of information) l Is Media requested not to Factually baseless. In accor-l inform public of LERO dance with LERO procedures l workerm* ingestion of MI media were never briefed about LERO markers

• KI ingestion.

Ja ENC personnel unable to Factually baseless. Facts do provide information to not demonstrated a failure to l medte; unable to contact provide the media information. l Marketing Evaluations l K; Not admitted. La ENC log falsely indl-Esercise events do not impit-cated gravel trw-t impedt-cate deficiency in training. ment was being removed The inaccurate information was not rolessed to the public or the media, m: ENC pashonnel Could not Factually baseless. LERO cnswer quantions about in-spokesperson reported essen-pediment tial details including loca-tion of road blockage and rerouting of traffic. N; ENC mtbstated facts Insignificant. 1solated errors about (1) when Emergency during a whole day's worth of was declared (0823, correct public information do not es-time was 0819). (2) EPZ tabitsh a training problem, sinter vs. summer popula-tien li .h-6 ~ o ~ f . 9 E Y g q + 4 6, j. + ,,= s _s c ~.. + ~ W _, t

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4 - ' -; ) i 7 f . CONTENTION CITED AND STATUS AS SUPPORT FOR FX S0.8 * ' MOC1*ICATIONS-!N LERO RAC REVIEW Of LERO - ~4(d PROCEDURES & TR AINING .MOOTFIC4TIOs5 4 COE'ESPONDING FEMA COMMENT 3 g:(

• w*

> L. 4 t ' ; A ~. - .3-n 3,z ;, ":v Os Deidied delivery of ~, y. ), j Or.alta function; trrelevant to (see EX 38.8 above) (see EX 38.8) press releases 4 and 5 to 'ty e t.t i ng. Media Monitoring Medio Lonitoring (ENC-D-1: . receives information through Insufficient copying capa ,s E85 messages, does not have Ollitlos resulted in delay. Immediate need for news re- .as in distributton of Informa-leases. Equipment problem h tion) caused delays in distributing updated information. New pro-cedures and better copying ca-pability should obviate prob-lem. P Rumor Control operation Duplicative of Contention instfective as described in EX 39. Contention EX 39 Q: LERO modifications Irrelevant to training. msutd be inadequate to rem-Conclusory allegation not edy " deficiencies" based on Emercise events. EX 30: Rumor Control As Call Board Operators Onstte function. Irrelevant (see EX 38.8 above) (see EX 38.8) hid inaccurate / outdated to LERO training; factually informatton; answered in-baseless. The few instances quiries too slowly or in-of superseded information re-ccrrcctly (ENC-D-Is Insuf-suited from an equipment prob-ficient copying capabill-lem. New procedures and bet-ties at ENC resulted in de-ter copying Capabtitty should Icys in distributing infor-obviate problem. mation to Rumor Control personnel) On Late responses to simu-Onsite function. Irrelevant lated rumus messages to training; conclusory and factually baseless. Responses to messages were as expedt-tlous as accuracy would allow. Personnel acted according to procedures. C; Rumor Contrul personnel Onsite function. Irrelevant (see EX 38.8 above) (see EX 38.8) provided inaccu-to training. Information pro-rate / superseded information vided was generally timely and (ENC-D-1; Insufficient correct. Isolated instances ccpying capabilities at ENC of inaccurate information were resulted in delays in based primarily on an

Q g7 h h y-g '~-g~'~''- [ 4 e CONTENTION CITED'AND -STATUS AS SUPPORT FOR EX 50.8 MODIFICATIONS IN LERO RAC REVIEW OF LERO. -CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS' distributing information to equipment problem. New proca-rumur control pe monnel) dures and better copying capa-0111ty should obviate problem. EX 44: (1st sentence con-Irrelevant to training. Fac-polidated with EX 38 and tually baseless. Emercise EX 39): Failure to provide events do not support allega-cccurate, clear information tion of substantial evacuation would create a substantial shadow. evecuation " shadow" EX 22F False assumption Irrelevant to training. of no premature evacuation Conclusory allegation not based on Exercise events. EX 41: Traffic Impediments . As Slow mobilization of Irrelevants not a training Road Crews problem. Factually baseless. Sufficient Roaci Crews were mo-bilized in accordance with procedures. 8: Failure to respond ade-Duplicative of Contentions Traffic Engineer added to Adequately address the is ' quotely to two road impedt-EX 42.8 and EX 45.A. Facts do .EOC. LERO Traffic Control sues raised in the exer-mants: (1) Communications not demonstrate a pervasive Tabletop Drtil V (Rev. May,

cise, failures at EOC (EOC-D-1:

training flaw. Isolated in-1986) and PAR / Accident Man-Dalays in' responding to two stances of-communciations agement Tabletop Drill III evacuation impediments) problems readily correctable (Rev. Aug. 1986) emphasize by revisions in LERO proco-responding to evacuation dures and training. impediments including com-munication of information, equipment requirements, re-sponse priorities, and al-tornate traffic routing. 'LERO Classroom Training Program materials for Ses-ston 8 " Traffic Control" (Rev. July, 1986) empha-sizes communication of.in-formation and timely're-sponse to evacuation tmped-1ments. (2) Delay in field Minor and readily. corrected by LERO Traffic Control proce-Adequately address'the en-verification of fuel truck revisions in LERO procedures dures have been revised to -ercise issue. i mp'ad imen t (EOC-ARCA-9: and training. empedite dispatch of

y-. y7 y y. .Q y y v. y ly. v-; -]- CONTENTION CITiD AND STATUS AS SUPPORT'FOR EX 50.8 MODIFICATIONS IN LERO. RAC REVIEW OF LERO C07 RESPONDING FEMA COMMENT PROCEDURES & TRAINING MOO!FICATIONS' Dalay in f i e l <1 vertftcation personnel responding to in-of fuel truck impediment) cidents' identified by the EOC. LERO field personnel now receive training with increased emphasis on re-sponses to evacuation in-pediments. Modifications have been made ins (1) LERO Evacuation Route Spotter Tabletop Drill III (Rev. May, 1986): (2) LERO Staging Area Management Tabletop Drill III (Rev. May, 1986); (3) LERO Traf-fic Control Tabletop Drill V (Rev, May, 1986); (4) LERO Classroom Training Program materials for Session 8 " Traffic Con-trol" (Rev. July, 1986). (3) Appropriate Factually baseless. Personnel LERO Traffic Control Tab-Adequately address the en-personnel not dispatched to and equipment required to letop Drill V (Rev. May, orcise issue. remove multiple vehicle ac-clear blocked road were sent 1986) emphasizes communica-closnt road impediment to accident. Facts do not tion directly between the (PSA-ARCA-82 Appropriate demonstrate a training flaw. EOC and Road Crews to en-personnel not dispatched Any problems were minor and 'sure appropriate response, to clear multiple vehicle 'readily correctable by revi-accident road impediment) stons in LERO procedures and LERO Classroom Training training. Program materials for Session 8 " Traffic Control" trains traffic control per-sonnel, including Road Crews, to communicate by radio with the Road Logis-tics Coordinator at the EOC. C Not admitted. Da Not admitted. En Addition of Traffic En-Irrelevant to training. ginser to EUC would not Conclusory allegation not allminate flaws in dealing based on Exercise events. with road impediments i

(j h

h h (j d U D-M . Q-CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.8 MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS l EM 22Is (dealt with under Id. I EX 41) Erroneous assump-tion that LERO needs to be ,e able to deal with only two 1 road impediments l EX 42 (Bases incorporated in EX 38 & Ex 39) Ar Untimely / ineffective Duplicative of Contentions (see EX 41.B above) '(see EX 41.B) response to road impedt-EX 41.0 and EX 45.A. ments (EOC-D-1 Delays in responding effectively to road impediments) 8: Untiaely/ inadequate re-Duplicative of Contention LERO procedures modified to Adequately address the ex-sponse to Ridge School EX 45.B. Factually baseless. ensure additional staff are arcise issue. ovecustion message Dispatch of bus 33 minutes used to assist the Special (PSA-ARCA-11: Forty minute after receipt of request at Populations Bus Dispatcher. dalay in dispatching Bus PSA was timely under circum-LERO Classroom Training ma-j i l Driver to evacuate school stances. terials for Session 9, " Transportation children) Coordinator" and " Pro-tactive Actions for Special Populations" emphasize need i for assistance in 1 expediting special popula-i tion buses. Transportation l Tabletop and Staging Area Management Tabletops also emphasize this. C Inability to handle un-Duplicative of Contention empscted rumors EX 39. D: Inability of Trattic Readily correctable by revi-LERO Classroom Training Adequately address the ex-Guidas to respond to sions in the LERO procedures Program materials for orcise issue. evacuse questions and training. Session 8 " Traffic Control" (Rev. July. 1986) now (PSA-ARCA-7: Traffic trains Traffic Guides to Guides lacked cumplete in-instruct evacuees t o '. l i s t en f or eha t ion un the appropri-to the EBS radio station ate dastinattun for for evacuation information evacuses including evacuation desti-nations. LERO Identifica-tion Badge for Traffic Guides, listing job-related duties on the back,

T-- ~ -~ .,l ~ 'y ~ - '~ Q ~ ~~ CONTENTION CITED AND STATUS AS SUDPORT FOR EX 50.8 MODIFICATIONS IN LERO ~ RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MOO!FICATIONS instructs them to advise evacuees to listen to the EBS station. D. (cont.) Inabtlity of Facts do not demonstrate a Traffic Guides now wear Traffic Guides to know en-pervasive flaw in LERO LERO Identification Badges cess dose authorization training program. Minor.-iso-enumerating radiological procedure (PSA-ARCA-16: lated incidents readily cor- . procedures on the back for Traffic Guides did not un-rectable by revisions in LERO quick reference in the carstand oncess dose autho-equipment and training. fleid. The Badge clearly rization procedures) states that they will re-ceive authorization for en-cess esposure from the Lead Traffic Guide. Excess dose authorization procedures are now emphasized in re-vised LERO Classroom Training materials for Session 3 " Personnel Dosimetry and Exposure Con-trol" (Rev. July, 1986). E: Sume bus drivers felled LERO procedures and training Bus Drivers are now as-Adequately address the ts-to carry out their assigned have been modified to ensure signed routes randomly in sues raised in the exer-duties (PSA-D-6: Bus driv-that every Bus Driver is capa-order to familiartze them cise. ers delayed, went to wrong ble of driving any randomly with a variety of routes trainsfer point, or missed asstoned route. they might be called on to ssomInt of assigned route) drive. Transfer Point Coordinators now check bus dispatch -forms upon Driver's arrival: to confirm that the Driver. is at the correct transfer point. LERO Classroom Training Program materials for Session 9 " Transportation Coordination" (Rev. July, 1986),<the Transportation Tabletop (Rev. May, 1986) and the Otaging Area Man-agement' Tabletop (Rev. May, 1986) emphasize that Bus Drivers report to the Transfer Point Coordinator for verification of the Bus

-~ .a, t k CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.5 MODIFICATIONS IN LERG. RAC REVIEW OF LERO' CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Dispatch Form to ensure that the Driver is at'cor-rect location. Bus Driver Driving Instruc-tion Training (Rev. May, 1986) emphasizes the new verification procedures. 'The session includes a Road Rally in.which each Driver runs a route to designated i check locations. F: Trafttc Guides arrived Factually baseless. Traffic Traffic Guides are now Adequately address the i s- - late at control points Guides critical to a con-prestaged for immediate sues raised in the emer-(RSA-D-2: Traffic Guide trolled evacuation manned dispatch within the 0-2 cise. d31cyed in arriving at con-their posts in a timely mile EPZ upon emergency trol points) fashion. Irrelevant to declaration. LERO Traffic training issue. Any problem Control Tabletop Drill V was procedural.. Procedures (Rev. May, 1986) and ^ have been modified. ' Staging Area Management Tabletop (Rev. May, 1986) emphasize prestaging and rapid deployment of Traffic i Guides in 0-2 mile EPZ. l LERO Classroom Training . Program materials for Ses-ston 8 " Traffic Control" (Rev. July, 1986) empha-sizes pre-equipping and pre-assigning of Traffic Guides. l F. (con.t) Bus drivers not Irrelevant to training. issue. LERO Classroom Training Reserved decision pending dispatched in timely Drivers were dispatched ac-Program materials for completion of further modt-fashion (PSA-ARCA-1: Bus cording to procedures. Prob-Session 9'" Transportation fication of LERO procedures drivers not dispatched lem related to quantity of Coordination" (Rev.. July, to assure timely briefings until 2 hour s after emer-trained personnel available to 1986) now emphasizes that and distribution of gancy dec lar at ion) assist Dispatcher in distribu-Transfer Point Coordinator dosimetry to Bus Drivers. tion of dosimetry. _ FEMA rec-assist Bus. Dispatchers with ommended additional personnel distribution of materials be provided to assist in bus .and dosimetry: in order to dispatching. Bus dispatch expedite dispatch of Bus procedures have been modified Drivers. to provide additional help. 1 The Transportation Tabletop and Staging Area Management

U M 'U V. N L /, y v v, y... v 8 CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.8 MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Tabletop Drills (Rev. May, 1986) emphasize need for assistance in rapid dis-patch of buses. Dosimetry Tabletop Drill VI (Rev. Nov. 1986) emphasizes need. .for rapid distribution of dosimetry-to large groups 'such as Bus Drivers. Ga ENC personnel failed to Dupitcative of Contention respond appropriately to EX 38. media questions EX 43: (consolidated with EX 50) l As Communications failures Duplicative of Contentions (see EX 41.8 above) (see EX 41.5) l in response to traffic im-EX 41.8.and EX 42.A. l psdiment messages (EOC-D-1: Daleys in responding to two evacuation impediments; i. EOC-ARCA-9t Delay in field verification of fuel truck inpsdiment) 8: Connunications failures Dupitcative of Contention (see EX 42.8 above) (see EX 42.8) in response to school evac-EX 42.8. Factually baseless. untion message Dispatch of bus 33 minutes (PSA-ARCA-nla Forty minute after receipt of request.at dalay in dispatcle of Bus PSA was timely under.ctrcum-1 Driver to evacuate school stances. children) C: Failure to notify FAA & Irrelevant to training conten-LERO will implement.the new Reserved decision. R A C.. LIRR (EOC-ARCA-2: Confu-tion. Procedures were fol-recommend 9 tion that it con-made new recommendations-ston regarding the method lowed during the exercise, tact FAA directly. A let-which LERO is implementing. of notifying FAA FEMA subsequently recommended ter of agreement with FAA a new notification procedure will be obtained and EOC (RAC Review. Dec. 15, 1986). personnel designated and trained to communicate with FAA. (C: cont.1 LOL-ARCA-3: Irrelevant to training conten, LERO procedures have been . Planning provisions are ad-LIRR was not notified) tion. Procedures were fol-modified. The Evacuation equate. LERO should obtain-lowed during the exercise. Coordinator notifies LIRR a letter of understanding of emergency status. LERO from LIRR. Accident Management

I CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.8 MODIFICATIONS IN LERO-RAC REVIEW OF LERO - CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Tabletop Drill emphasizes new responsibility of Evac-untion Coordinator to nott-fy LIRR. D Failure to distin-Irrelevant to training conten-Dose Assessment status Adequately address the en-guish between DOE RAP and tion. Facts involve equip-board has been revised to .orcise issue. LILCC field monitoring on

ment, separate data from DOE RAP dosa assessment status and LILCO field monitoring board (EOC-ARCA-4:

Not teams. A meeting was held enough columns on dose as-with DOE representatives on sessment status board to Jan. 6, 1987 to review the kosp DOE RAP and LILCO data use of new status board. sepnrated) Downwind distance of Isolated instance of human All downwind distances now Adequately address the en-dose measurement errone-error caused by a decimal reported directly in miles ercise issue. ously reported as 7000 me-point misplaced during.conver-without need to convert to ters instead of 700 meters. ston of distance units. Po-meters. This was reviewed (EOC-ARCA-5s Downwind dis-tential for error reduced by during the LILCO/ DOE meet-tance of a thyroid dose change in procedures. ing on Jan. 6,

1987, semple incorrectly reported as 7000 meters instead of 700 meters)

Entropolated doses Minor and readily correctable Procedure now calls for Adequately address the en-erroneously reported as ac-by revisions in LERO proce-identification of data upon orcise issue. tual doses on status board. dures and training, receipt at EOC as actual or (EOC-ARCA-b Entrapolated entrapolated. DOE RAP per-doss data were reported as sonnel were notified of sctual measurements on sta-change in reporting proco-tus board) dure at the LILCO/ DOE meat-ing on Jan. 6, 1987. Es Secretary did not de-Insignificant. Noted but not liver telephone message cited in FEMA Assessment as promptly to LERO Director deftctancy or ARCA. Secre-tary's actions did not contra-i vene any LERO procedure. Mes-l sages designated by the caller as urgent would be immediately conveyed to the Director. F: Communications tailures Duplicative of Contentions of ENC, Public Information. EX 38 and EX 39. end Runer Cont rol personnel G: Failur e of RSA Failure to post time of update LERO Staging Area Adequately address the per sonne l to properly was minor and readily cor-Management Tabletop Drill exercise issue.

CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.8 MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS rccord event information on rectable by modifications in III (Rev. May, 1986) now stctus board (RSA-ARCA-1:

training, emphasizes posting time of Time was not always includ-updated information on sta-ed when new information was tus board postad on status board)

Radio reception at Factually baseless. Irrele-Port Jefferson Staging Area vant to training contention. eas poor and disrupted "es-Based ois sporadic radio recep-ssntial" communications tion problem. Noted but not cited in FEMA Assessment as deficiency or ARCA. Bus Dispatcher at Dispatcher's last minute re-LERO Staging Area Manage-Adequately address the ex-PSA made inaccurate an-minders to Bus Drivers were ment Tabletop Drill III ercise issue, nouncements to bus drivers not complete but contained no (Rev. May, 1986) now empha-about dosimetry inaccuracles of important in-sizes need for complete. (PSA-ARCA-12: Bus Dis-formation. Minor, isolated precise instructions at all pstcher did not give instance not indicative of times. dosimetry units nor mention pervasive training flaw. 0-200 MREM DRD Bus Driver misdi-Minor, isolated instance not LERO Classroom Training Adequately address the en-' rected at the BNL transfer indicative of pervasive Program materials for arcise issue, point. (PSA-ARCA-9: In-training flaw. Session 9." Transportation structions to proceed to Coordination" and " Pro-Recaption Center were not tactive Actions for Special proparly transmitted at BHL Populations" (Rev. July, transfer point 1986) now emphasize the proper destinations for Bus Drivers. LERO Requalification Training Session 9 (Rev. July, 1986) trains Drivers to proceed with evacuees to Reception Centers. i LERO Staging Area Manage-ment Tabletop Drtil III and Transportation Tabletop Drill (Rev. May, 1986) em-phastze training of Trans-for Point Coordinators to follow staging area direc-tions in instructing Bus i Drivers. 3 h+'

4 A CONTENTION CITED AND STATUS AS SUPPORT FOR EX 5 0 '. B MODIFICATIONS IN LERO RAC REVIEW OF LERO' CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS a Hs Inability to transmit Factually baseless. Problem corrsct information about originated with conflicting Suffolk County Police De-FEMA input-into Exercise sco-pcrtment assistance

narlo, i

EX 49: Indbility to roots-ter end monitor evacuees A: Radiological monitoring Factually baseless monitoring LERO Classroom Training ma- . Adequately address the en-frequently took too long, only occasionally took longer terials.for Session 7 " Mon-ercise issue. (RC-ARCA-1: Radiological than 90 seconds. LERO person-itoring and monitoring occasionally nel demonstrated ability to Decontamination" have been j .took longer than 90 seconds monitor evacuees in 90 sec-revised to emphasize taking specified in LERO proca-onds. no longer than 90 seconds dures) to monitor evacuees at Re-ception Center. EX 34 (dealt with under Irrelevant to training. Con-EX 49.A) Insufficient tention alleges deficiency in staff at Reception Center quantity of personnel, not their training. 6: Ability to obtain addi-Irrelevant to training. Con-tional monitoring personnel tention is not based on Emer-end other features of pur-cise events. Factually base-i ported alternate monitoring less. Ability to secure addt-plan not demonstrated tional monitoring personnel from INPO and elsewhere was demonstrated. Ca More persons than ad-Factually baseless. vised would seek ra-Conclusory allegation not i i diological monitoring based on Emercise events or occurrences. OTHER FEMA COMMENTS CITED STATUS AS SUPPORT FOR EX 50.8 MODIFICATIONS IN LERO RAC REVIEW OF LERO PROCEDURES & TRAINING MODIFICATIONS i h i EOC-ARCA-7: Health Ser-Minor, isolated instance of Health Services Coordinator Adequately address the en-vices Coordinator misstated human error. Health Services has been provided with re-ercise issue. an EPA Protective Action Coordinator later stated the view material on use and Guldsline PAG correctly. meaning of EPA PAGs. 9 PJSA-ARCA-1: One Bus Driv-Minor, isolated instance. Emphasis on personal Adequately address the en-er neglected to read readily corrected by increased dosimetry procedures in- 'ercise issue. q dosimetry at anytime while emphasis in revised LERO creased. Importance of working in EPZ

training, reading dostmetry every 15-i i

i ,a

OT H5 R FEMA COMMENTS CITED STATUS AS SUPPORT FOR EX 50.8 WODIFICATIONS IN LERO RAC REVIEW OF LERO PROCEDURES & TRAINING' MODIFICATIONS minutes stressed in (1) LERO Classroom Training ma-terials for Session 3 "Per-sonnel Dosimetry and Expo-sure Control" (Rev. July, 1986).-(2) Session 9 " Transportation" and (3) Requalification Training Session 3 (Rev. Sept. 1986). All. Bus Drivers now wear LERO Identification Badges with dosimetry in-formation on the back in-structing them to read dostmeter every 15 minutes. PSA-ARCA-3: Personnel en-Minor and inconsequential. Procedures revised to allow Adequately address tho en-terad the second floor to FEMA recommended a change in access to second floor ercise issue. i use telepnones contrary to procedures to reflect actual telephones. procedures practice of using second floor telephones. PSA-ARCA-4: The south door Minor and readily corrected by New procedure calling for Adequately address the en-j was not locked as specified modifications in LERO proco-PSA Guard Post 3 to ensure arcise issue. f in procedures dures and training. security of south door is stressed at LERO Staging I Area Management Tabletop Dr11I III (Rev. May, 1986). 4 PSA-ARCA-13: Two Bus Driv-Facts do not demonstrate per. All Bus Drivers now wear Adequately address the ex-era did not read dosimetry vasive flaw in LERO training LERO Identification Badges ercise issue, on time program. Minor and isolated with dosimetry information instances readily correctable on the back instructing by modifications in LERO them to read dostmeters 3 training. .every 15 minutes. Emphasis on reading dosimetry every 15 minutes has been in-creased in LERO training. The importance of checking DRDs on schedule ~is stressed particularly in (1) LERO Classroom Training materials for Session 3 " Personnel Dosimetry and Exposure Control" (Rev. July. 1986). (2) Session 9 " Transportation" (3) ]

.i OTHER FEMA COMMENTS CITED STATUS AS SUPPORT FOR EX 50.8 MODIFICATIONS IN LERO RAC REVIEW OF LERO' PROCEDURES & TRAINING MODIFICATIONS Requalification Training Session 3 (Rev. Sept. 1986). PSA-ARCA-14: Two. Traffic Facts do not demonstrate a All LERO field personnel Adequately address the on-Guides did not know dose pervasive flaw in training. now wear LERO Identifica-ercise.lssue. suthorization limits Minor and isolated instances tion Badges enumerating readily correctable by modift-personal radiological pro-cations in LERO equipment.and cedures on the back for training. quick reference in the field. Procedures gov-erning dose limits and ex-cess authorization are now stressed particularly in (1) LERO Classroom Training materials for Session 3 " Personnel Dostmetry and Esposure Control" (Rev. July, 1986), and (2) Session 8 " Traffic Control" (Rev. July, 1986). PSA-ARCA-15 A Route Minor and isolated instance All LERO field personnel Adequately address the on-Alerting Ortver does not demonstrate a perva-now wear LERO Identifica-ercise issue, misunderstood KI authoriza-sive flaw in LERO training tion Sadges enumerating tion procedure program. personal radiological' pro-cedures on the back for quick reference in the field. Increased emphasis on ingesting KI when Gener-al Emergency is announced over ESS Station has been included in modifications to the LERO Route Alert ' Driver Tabletop Drill (Rev. May, 1986). RSA-ARCA-4; dne RSA Bus Minor, isolated instance read-All Bus Drivers now wear _ Adequately address the ex-Driver did not read his fly correctable by increased LERO Identification Badges orcise issue, dosimetry every 15 minutes en@hasis in revised LERO with dosimetry.information training. on the back instructing them to read dosimeters every 15 minutes. Emphasis on personnel dosimetry pro-cedures increased. Impor- 'tance of reading dostmetry every 15 minutes stressed

1 OTHER FEMA CDuMENTS CITED STATUS AS SUPPORT FOR Ex 50.8 - ' MODIFICATIONS IN LERO RAC REVIEW OF LERO PROCEDURES & TRAINING MOOIFICATIONS 4 in.(1) LERO Training Pro-gram Modulo 9 " Personnel 1 Dostmetry and Exposure Con-trol (Rev. July, 1986), and (2) Requalification Training Session 3 (Rev. Sept. 1986). RSA-ARCA-5 Two of 8 Traf-Minor and readily correctable Traf fic Guides now wear ' Adequately address tho'en- 'fic Guides did nnt fully by modifications in LERO LERO Identification Badges .ercise issue. undsratand difference be-equipment and training. enumerating personal re-twssn low and mid-range diological procedures on DRDs the back for quick refer-ence in the field. The badges provide brief in-structions on the use of the two dostmeters. Dosimetry now receives in-creased emphasis in (1) LERO Classroom Training ma-- terials for. Session 3 "Per-sonnel Dostmetry and Expo-sure Control" (Rev. July, 1986), and (2) Session 8 " Traffic Control" (Rev. Uuly, 1986). RSA-ARCA-6: One Bus Driver Minor, isolated instance read-All LERO field personnel Adequately address the en - simulated is westion of KI ily correctable by modifica-now wear LERO Identifica-ercise issue, prematurely tions in LERO. tion Badges enumerating-personal radiological pro-cedures on the back for quick reference in the field. LERO Classroom Training materials for Session 3 " Personnel Dostmetry and Emposure Con-trol" (Rev. July, 1986)'now stresses internal dose con-~ trol by KI ingestion at ap-propriate time.

.y ~n 'd l. CONTENTION EX 50.C i 'LERO FAILED TO TRAIN PERSONNEL TO l COMMUNICATE NECESSARY DATA ANO INFORMATION i I l CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.C MODIFICATIONS IN LERO- .RAC REVIEW OF LERO COR*ESPONDING FEMA COMMENT , PROCEDURES & TRAINING MODIFICATIONS Ex 34: Route Alert Orivers Irrelevant to training conten-LERO has undertaken a're - teok too long to notify tion. Route Alert Orivers view of notification proco-public complied with procedures. dures and personnel will be FEMA did not cite the length trained as newer procedures of time as a deficiency or era developed. ARCA. FEMA recommended that the procedure for backup route alerting be revised to reduce the time needed for route alerting, perhaps by using multiple drivers, Ex 36: Inappropriate pro-Factually baseless. LERO tactive action recommenda-followed applicable proce-tionw (wind shift) dures. FEMA Report at 33. Ex 33: Public Information A: ENC delayed in opening; Factually baseless. ENC no information until first activation was timely. See nswa conference at 0840 FEMA Report at 52. LILCO issued press releases at 0625 and 0639. Os First news release de-Factually baseless: 'trrele-Essential emergency infor- . Reserved decision based on leyed and inaccurate vant to training. Informa-mation summarized and fact that LERO had not-yet (ENC-D-la Insufficient tion was timely provided. transmitted via computer decided to upgrade Copying copying capabilities re-Equipment problem, not from the EOC to ENC and all capabilities, suited in delays in distri-training. caused delays in rumor control locations si-bution of information) distributing updated infor-multaneously. Additional mation. New procedures and copying equipment (total of better copying capability 5 machines) ensures sufft-should obviate problem. cient capability in event of unanticipated machine failure. C: Second news release de-Id. Id. Id. layed (ENC-D-la Insufft-cicnt copying capabilities resulted in delays in dis-tribution of information) 1

' ' V ~M %),_ y - %y. _y y y 9 s-s CONTENTION CITED AND -STATUS AS SUPPORT FOR Ex50.C MODIFICATIONS IN LERO RAC REVIEW OF LERO. COR'ESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS j 0 Insufficient copying Irrelevant to training, ld. Id. capability at ENC delayed Equipment problem Caused de-distribution of information lays in distributing updated (ENC-D-1: Insufficient information. New procedures copying capabilities re-and better copying capability suited in celays in distri-should obviate problem. button of information) E Insufttclent/ inadequate Irrelevant to training. Facts The suggested displays and Adequately address the en-- maps end displays based on equipment deficiency. status boards have been arcise issue. (ENC-ARCA-2: Insufficient provided to the ENC. maps end displays) F: EDS message contained Minor and corrected by revi-Press Release procedures The plan modifications ade-entraneous information stons in LERO procedures and have been modified. EBS quately address the emer-(ENC-ARCA-Je EDS messages followup training, messages will no longer be cise issue, contained entraneous infor-released. The Coordinator of Public Information pre-mation) pares press releases using an established format. The Director of Local Response approves it. The LERO Spokesperson directs dis-tribution to the media. LERO Public Information Group Personnel receive training in the new proca-dures in the LERO Public .{ Information Tabletop Drill (Rev. Nov. 1986). G Press releases Duplicative of Contention (see EX 38.8 above) (see EX 38.8) late / inaccurate (ENC-D-1: EX 38.C. Irrelevant to 4 J Insufficient copying capa-training. Information was .) l bilities resulted in delays timely provided. Equipment in distribution of informa-problem caused delays in tion) distributing updated informa-i tion. New procedures and bet-ter copying capability should obviate problem. H: Evacuation decision id. (see EX 38.8 above) (see EX 38.8) 1 given to media too late (ENC-D-1: Insufficient cc:py ing capabilities re-zuited in delays in i l l

I Q y. d IQ Q V IV; M -VI [ -M: CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.C MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MOOIFICATIONS distribution of informa-tien) In Media requested not to Factually baseless. In accor-inform pubitc of LERO dance with LERO procedures workers' ingestion of KI media were never briefed about LERO workers

• KI ingestion.

J: ENC personnel unable to Factual 6y baseless. Facts do prcvide information to not demonstrated a failure to medla; unable to contact provide the media information. Marketing Evaluations K: Not admitted. La ENC log falsely indi-Esercise events do not impit-cated gravel truck impedi-cate deficiency in training, ment was being removed The inaccurate information was not released to the public or the media. 5; ENC personnel could not Factually beseless. LERO enswer questions about im-spokesperson reported essen-pediment tial details including loca-tion of road blockage and rerouting of traffic. N ENC misstated facts Insignificant. Isolated errors cbout (1) when Emergency during a whole day's worth of ses d2clared (8:23 correct public information do not es-time was 8:19). (2) EPZ tablish a training problem. winter vs. summer popula-tion 0: Delayed delivery of Onsite function; irrelevant to (see EX 36.B above) (see EX 38.8) press releases 4 and 5 to training. Media Monitoring Media Monitoring (ENC-O-1 receives information through Insufficient copying capa-EBS messages, does not have bilities eusulted in delays immediate need for news re-in distribution ut informa-leases. Equipment problem tion) caused delays in distributing updated information. New pro-cedures and better copying ca-pability should obviate prob-lem. P: Rumor Control operation Duplicative of Contention insffecttwe as described in EX 39.

f (,.) \\_) R_f .l 0 'Q

Q l.

c -Q{ -} ^ 4 CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.C -MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Contention Ex 39 Q: LERO modifications Irrelevant to training. msutd be inadequate to rem-Conclusory allegation not cdy "deftctancies" based on Exercise events. EX 39: Rumor Control A: Call Board Operators Onsite function. Irrelevant (see EX 38.8 above) (see EX 38.8) had inaccurate / outdated in-to LERO training; factually formatton; answered inqut-baseless. The few instances rios too slowly or incor-of superseded information ra-rectly (ENC-D-1: Insufft-sulted from an equipment. prob-cient copying capabilities lem. New procedures and bet-81 ENC resulted in delays ter copying capability should in distributing information obviate problem. to rumor control personnel) 8: Late responses to simu-Onsite function. Irrelevant lated rumor messages to trainings conclusory and factually baseless. Responses to messages were as expedi-tious as accuracy would allow. Personnel acted ar. cording to procedures. C: Rumor Control personnel Onsite function. Irrelevant (see EX 38.8 above) (see EX 38.8) provided inaccu-to training. Information pro-rate / superseded information vided was generally timely and (ENC-O-1: Insufficient correct. Isolated instances copying capabilities at ENC of inaccurate information were resulted in delays in based primarily on an equip-distributing information to ment problem. New procedures rumor control personnel) and better copying capablitty should obviate problem. Ex 44: (1st sentence con-Irrelevant to training. Fac-polidated with EX 38 and tually baseless. Emercise Ex 34): Failure to provide events do not support allega-cccurate, clear information tion of substantial evacuation would create a substantial shadow. evacuation " shadow" Ex 22F: Falso assumption Irrelevant to training, of no premature evacuation Conclusory allegation not-- based on Esercise events.

i l CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50 C MODIFICATIONS IN LERO RAC REVIEW OF LERO l COR~ESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS l' Ex 41: Traffic Impediments i As Slow mobilization of Irrelevants not a training Roed Crews problem. Factually baseless. Sufficient Road Crens were mo-bilized in accordance with procedures. Os Failure to respond ade-Duplicative of Contentions Traffic Engineer added to Adequately address the is-quately to two road impedt-EX 42.8 and EX 45.A. Facts do EOC. LERO Traffic Control sues raised in the ener-ments: (1) Communications not demonstrate a pervastve Tabletop Drill V (Rev. May, cise. failures at LOC (EOC-D-1: training flaw. Isolated in-1986) and PAR / Accident Man-Delcys in responding to two stances of communciations agement Tabletop Oriti III ovscuation impediments) problems readily correctable (Rev. Aug. 1986) emphasize by revisions in LERO proce-responding to evacuation dures and training. impediments including com-munication of information, equipment requirements, re-sponse priorttles, and al-tornate traffic routing. LERO Classroom Trainina Program materials for Ses-ston 8 " Traffic Control" (Rev. July, 1986) empha-sizes communication of in-formation and timely re-sponse to evacuation imped-tments. (2) Delay in field Minor and readily corrected by LERO Traffic Control proce-Adequately address the en-verification of fuel truck revisions in LERO procedures dures have been revised to arcise issue, impediment (EOC-ARCA-9: and training. expedite dispatch of per-Daley in field verification sonnel responding to inci-of fust truck impediment) dents identified by the EOC. LERO field personnel now receive training with increaswd emphasis on re-sponses tu evacuation im-pediments. Modifications have been made ins (1) LERO Evacuation Route Spotter Tabletop Driti III (Rev. May, 1986): (2) LERO Staging Area Management Tabletop Drill III (Rev. May, 1986); (3) LERO Traf-fic Control Tabletop

U ' ~ U-U U U U M V V M" CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.C MOO!FICATIONS IN LERO RAC REVIEW OF LERO COR~ESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Drtil V (Rev. May, 1986)t (4) LERO Classroom Training Program materials for Session 8 " Traffic Con-trol" (Rev. July, 1986), (3) Appropriate Factually baseless. Personsel .LERO Traffic Control Tab-Adequately address the en-personnel nut dispatched to and equipment required to letop Drill V (Rev. Nay, arcise.lssue, remove multiple venicle ac-clear blocked road were sent 1986) emphastaes communica-closnt road impediment to accident. Facts do not tion directly between the (PSA-ARCA-8: Appropriate demonstrate a training flaw. EOC and Road Crews to on-personnel not dispatched Any problems were minor and sure appropriate response, to clear multiple vehicle readily correctable by revi-accident road impediment) sions in LERO procedures and LERO Classroom Training training. ~ Program materials for Session 8 " Traffic Control" trains traffic control per-sonnel, including Road Crews, to communicate by radio with the Road Logis-tics Coordinator at the EOC. C: Not admitted. D: Not admitted. En Addittun ut Traffic En-Irrelevant to training. gineer to EOC would not Conclusory allegation not allminate flaws in dealing based on Esercise events. with road lehped imen t s EX 221: (dealt with under Id. EX 41) Erroneous assump-tion that LERO needs to be Eble to deal with only two rond impediments EX 42 (Bases 6ncorporated in Ex 38 & Ex 39) A: Untimely /inwffective Duplicative of Contentions (see EX 41.8 above) (see EX 41.8) response to road impect-EX 41.B and EX 45.A. ments (EOC-D-1: Delays in re ponding effectively to roid impediments) 5: Untimely / inadequate Duplicative of Contention LERO procedures modified to Adequately address the response to Ridge School EX 45.8. Factually baseless. ensure additional staff are exercise issue.

c-CONTENTION CITED AkD STATUS AS SUPPORT FOR EX 50.C MODIFICATIONS IN LERO RAC RF. VIEW OF LERO COR*ESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS cvscuation message Dispatch of bus 33 minutes used to assist the Special ( PSA-ARC A-I I : Forty minute after receipt of request at Populations Bus Dispatcher, deley in dispatching Bus PSA was timely under circum-LERO Classroom Training ma-Drivsr to evacuate school stances. terials for Session 9, children) " Transportation Coordinator" and " Pro-tactive Actions for Special' Populations" emphasize need for assistance in expediting special popula-tion buses. Transportation Tabletop and Staging Area Management Tabletops also emphastze this. C Inability to handle un-Duplicative of Contention ospected rumors EX 39. Os Inability of Traffic Readily correctable by revt-LERO Classroom Training Adequately address the en-Gutdas to respond to stons in the LERO procedures Program materials for orcise issue, ovacuee questions and training. Session 8 " Traffic Control" (PSA-ARCA-7: Traffic (Rev. July, 1986) now Gulous Iached complete in-trains Traffic Guides to formation on the approprt-instruct evacuees to listen ato destination for to the EBS radio station avecuees for evacuation information including evacuation desti-nations. LERO Identifica-tion Badge for Traffic Guides, listing job-related duties on the back, in-structs them to advise evacuees to listen to the ESS station. D. (cont.) Inability of Facts do not demonstrate a Traffic Guides now wear Traffic Guides to know en-pervasive flaw in LERO LERO Identification Badges Cens dohe authorization training program. Minor, iso-enumerating radiologtCal procedure (PSA-ARCA-16: lated incidents readily cor-procedures on the back for Trsffic Guides did not un-rectable by revisions in LERO quick reference in the derstand eacess dose autho-equipment and training. field. The Badge clearly rization procedures) states that they will re-cetve authorization for en-cess esposure from the Lead Traffic Guide. Encess dose authorization procedures are now emphasized in re-vised LERO Classroom

A/ ~V . v. ~ %./ v v v-g CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.C MODIFICATIONS IN LERO' ' RAC REVIEW 'OF LERO CORRESPOt4 DING F EMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Training materials for . Session 3 " Personnel Dostmetry and Exposure Con-trol" (Rev. July. 1986). E Some bus drivers failed LERO procedures and training Bus Drivers sre now as-Adequately address the is-to carry out their assigned have been modified to ensure signed routes randomly in suas raised in the emer-duttet (PSA-D-6: Bus driv-that every Bus Driver is capa-order to familiarize them cise. ers delayed, went to wrong Die of driving any randomly with a variety of routes trensfer point. or missed assigned route, they might be called on to ssement of ansigned route) drive. Transfer Point Coordinators now check bus'dtspatch forms upon Driver's arrival to confirm that the Driver is at the correct transfer point. LERO Classroom Training Program materials for Session 9 " Transportation Coordination" (Rev. July, 1986), the Transportation Tabletop (Rev. Nay, 1986) and the Stagtng Area Man-agement Tabletop (Rev. May, 1986) emphasize that Bus Drivers report to the Transfer Point Coordinator for verification of the Bus Dispatch Form to ensure that the Ortver is at cor-rect location. Bus Driver Driving Instruc-tion Training (Rev. May, 1986) emphasizes.the new verification procedures. The session includes a Road Rally in which each Driver runs a route to designated check locations. F: Traffic Guides arrived Factually baseless. Traffic Traffic Guides are now Adequately address the ts-late at control points Guides critical to a con-prestaged for immediate sues raised in the ener-(RSA-D-2: Teatric Guide trolled evacuation manned dispatch within the 0-2

cise, dslayed in arriving at their posts in a timely mile EPZ'upon emergency control points) fashion. Irrelevant to declaration. LERO Traffic

CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.C MODIFICATIONS IN LERO RAC REVIEW OF LERO 1 COR?ESPONDING FEMA COMMENT PROCEDURES & TRAINING. ' MODIFICATIONS training issue. Any problem Control Tabletop Drill V was procedural. Procedures (Rev. May, 1986) and have been modified. -Staging Area Management Tabletop (Rev. May. 1986) emphasize prestaging and ) rapid deployment of Traffic j Guides in 0-2 mile EPZ. LERO Classroom Training .i Program materials for Ses-sion 8 " Traffic Control" (Rev. July, 1986) empha-i sizes pre-equipping and pre-assigning of Traffic Guides. F. (con.t) Bus drivers not Irrelevant tc training issue. LERO Classroom Training Reserved decision pending utspatched in timely Drivers were dispatched ac-Program materials for completion of further modl-fashion (PSA-ARCA-la Bus cording to procedures. Prob-Session 9 " Transportation fication of LERO procedures drivers not dispatched les related to quantity of Coordination" (Rev. July, to assure timely briefings until 2 hours after emer-trained personnel available to 1986) now emphasizes that and distributton of guncy declaration) assist Dispatcher in distribu-Transfer Point Coordinator dosimetry to Bus Drivers, tion of dosimetry. FEMA rec-assist Bus Dispatchers with ommended additional personnel distribution of materials be provided to assist in bus and dosimetry in order to dispatching. Sus dispatch expedite dispatch of Bus procedures have been modified Drivers. to provide additional help. The Transportation Tabletop 4 and Staging Area Management Tabletop Drills (Rev. May. 1986) emphastze need for I assistance in rapid dis-l patch of buses. Dosimetry Tabletop Drtil VI (Rev. Nov. 1986) emphasizes need for rapid distribution of dostmetry to large groups i such as Bus Drivers. G ENC personnel telled to Duplicative of Contention respond appropriately to Ex 38. media questions 1 i i m

O .O' .O' O 0: O .O Q u Q v I OTM9R FEMA COMMENT CITED ST ATUS AS SUPPORT FOR EX 50.C MODIFICATIONS IN LERO RAC REVIEW OF LERO PROCEDURES & TRAINTNG MODIFICATIONS i Ex 45: (consolidated with Ex 50) e A: Communications failures Duplicative of Contentions (see EX 41.6 above) (see EX 41.5) 2 in response to traffic in-Ex 41.8 and Ex 42.A. .I pediment messages (EOC-D-Is Delays in responding to two evacuation impediments; EOC-ARCA-9: Delay in field verification of fuel truck impediment) 9: Communicettons failures Duplicative of Contention Ex (see EX 42.8 above) (see EX 42.5) in response to school 42.8. Factually baseless, evaucation message Dispatch of bus 33 minutes (PSA-ARCA-II: Forty minute after receipt of request at delay in dispatch of Bus PSA was timely under Circum-Driver to evacuate school stances. cn11dren) C Failure to notify FAA & Irrelevant to training conten-LERO will implement the new. Reserved decision. RAC LIRR (EOC-ARCA-2: Confu-tion. Procedures were fol-recommendation that it con-made new recommendations ston regarding the method lowed during the esercise. tact FAA directly, A let-which LERO is implementing. of notifying FAA FEMA subsequently recommended ter of agreement with FAA a new nottftcation procedure will be obtained and EOC (RAC Review, Dec. 15, 1986). personnel designated and trained to communicate with FAA. ) (C cont.) EOC-ARCA-3: Irrelevant to training conten-LERO procedures have been Planning provisions are ad-l LIRR was not nottfled) tion. Procedures were fol-modified. The Evacuation equate. LERO should obtain towed during the esercise. Coordinator notifies LIRR a letter of understanding of emergency status. LERO from LIRR. Accident Management Tab-letop Drill emphasizes new l responsibility of Evacua- ] tion Coordinator to notify j LIRR. 2 D: Failure to distinguish Irrelevant to training conten-Dose Assessment status Adequately address the en-betwsen DOE RAP and LILCO tion. Facts involve equip-board has been revised to ercise issue. field monitoring on dose ment. separate data from DOE RAP assessment status board and LILCO field monitoring (EOC-ARCA-4: Not enough teams. A meeting was held columns on dose essessment with DOE representatives on status board to keep DOE Jan. 6, 1987 to review the RAP and LILCO data sepa-use of new status board, rated) 4

, v -- v - -- y- .y y OTHER FEMA rOMMENT CITED STATUS AS SUPPORT FOR Ex 50.C MODIFICATIONS IN LERO. RAC REVIEW OF LERO. P90CEDURES & TRAINING. MODIFICATIONS' Downwind distance of Isolated instance of human All downwind distances now Adequately address the en-dose measurement errone-error caused by a decimal reported directly in miles arcise issue. sualy reported as 7000 me-point misplaced during conver-without need to convert to l tors instead of 700 meters. ston of distance units. Po-meters. This was reviewed (EOC-ARCA-5 .Domn-tod dis-tential for error reduced by during the LILCO/ DOE meet-tance of a thyroid dose change in procedures. ing on Jan. 6 1987. sample incorrectly reported as 7000 meters instead of 700 meters) Estrapolated doses Minor and readily correctable Procedure'now calls for Adequately address the on-l urroneously reported as ac-by revisions in LERO proce-toontification of data upon arcise issue. I tual doses un status board. dures and training. receipt at EOC as actual or l (EOC-ARCA-6: Entrapolated entrapolated. DOE RAP per-i dose date were reported as sonnel were nottfled of cctual measurements on sta-change in reporting proco-tus board) dure at the LILCO/ DOE meet-l ing on Jan. 6 1987. E: Secretary did not de-Insignificant. Noted but not l Ilver telephone message cited in FEMA. Assessment as promptly to LERO Director deftetency or ARCA. Secre-l tary's actions did not contra-vene any LERO procedure. Mes-sages designated by the caller as urgent would be immediately conveyed to the Director. F: Communtcations failures Duplicative of Contentions of ENC. Public Information. Ex 38 and EX 39. and Rumur Control personnel G: Failure of RSA person-Failure to post time of update LERO Staging Area Manage-Adequately address the.es-nel to properly record was etnor and readily cor-ment Tabletop Drill III ercise issue, event information on status rectable by modifications in (Rev. May, 1986) now empha-board. (RSA-ARCA-t: Time training. sizes posting time of up-mas not always included dated information on status when nem informattun was

board, posted on status board)

Radio reception at Factually baseless. Irrele-Port Jefferson Staging Area vant to training contention, was poor and disrupted "es-Based on alleged equipment sential" cummunications problem. Noted but not cited in FEMA Assessment as deft-cles.sy or ARCA. Bus Olspatcher at Dispatcher's last minute .LERO Staging Area Adequately address the PSA made inaccurate an-reminders,to Bus Drivers were Management Tabletop Drtal esercise issue. i

i OTHER FEMA CGMMENT CITED STATUS AS SUPPORT FOR Ex 50.C MODIFICATIONS IN LERO RAC REVIEM OF LERO PROCEDURES & TR AINING MOOIFICATIONS nouncements to bus drivers not complete but contained no III (Rev. Nay, 1986) now about dosimetry inaccuracles of important in-emphastaes need for com-(PSA-ARCA-12: Bus Dis-formation. Minor. isolated plate, precise instructions patcher did not give instance not indicative of at all times, dostmetry units nor mention pervastwo training flaw. O-200 MREM DRO Bus Drtwer misat-Minor, isolated instance not LERO Classroom Training Adequately madress the~en - rected at the BNL transfer indicattwo of pervasive. Program materials for orcise issue. potot. (PSA-ARCA-9: In-training flaw. Session 9 " Transportation structions to proceed to Coordination" and " Pro-Deception Center were not tecttwo Actions for Special property transmitted at BNL Populations" (Rev. July, transfer point 1986) now emphasize the proper destinations for Bus Drtwers. LERO Requalification Training Session 9 (Rev. July, 1986) trains Drivers to proceed with evacuees to Reception Centers. LERO Staging Area Manage-ment Tabletop Drill III and Transportation Tabletop Drill (Rev. Nay, 1986) en-phastae training of Trans-- for Point Coordinators to follow staging area direc-tions in instructing Bus Ortwers. H: Indbility to transmit Factually baseless. Problem correct information about originated with conflicting Suffolk County Police De-FEMA input into Esercise sco-partment assistance narlo. Ex 23: (t,4 sis considered Duplicattwo of Contention (see EX 45.D above) (see EX 45.D) under subpart Ex SOC) En-EX 45.D. Minor and readily trapolated doses reported correctable by revisions in rs ectual doses LERO procedures and training. (EOC-ARCA-6: Entrapolated dose date =wre reported as actual meas..e=ments on sta-tus bo rd)

OTHER FEMA CoasasENT CITED STATUS AS SUPPORT FOR Ex 50.C .ReODIFICATIONS IN LERO RAC REVIEW OF LERO PROCEDUAES & TRAINING 000DIFICATIONS EOC-ARCA-7: Health Ser-tainor, isolated instance of Health Services Coordinator Adequately address the en- - vicos Coordinator misstated human error. Health Services has been provided with re-ercise tasue. an EPA Protecttwo Action Coordinator later stated the view material on use and C@comumenda t ion PAG correctly. meaning of EPA PAGs.

r ___ CONTENTION Ex 50.0 LERO FAILED TO TRAIN PERSONNEL TO FOLLOW DIRECTIONS OF SUPERIORS CONTENTIONS CITED AND STATUS AS SUPPORT FOR Ex 50.D MOOIFICATIONS IN LERO RAC REVIEW OF LERO CQa ESPONDING FEMA COMMENTS PROCEDURES & TRAINING MODIFICATIONS En 41: Trafttc Impediments As Slos mobilization of Irrelevant; not a training Eoad Cre.s problem. Factually baseless. Sufficient Road Crews were so-bilized in accordance with procedures. Os Failure to respond ade-Duplicative of Contentions Traffic Engineer added to Adequately address the 16-quately to two road impedt-Ex 42.8 and EX 45.A. Facts do EOC. LERO Traffic Control suas raised in the emer-ments: (1) Communications not demonstrate a pervasive Tabletop Drtti V (Rev. May, ctse. tellures at EOC (EOC-D-1: training flaw. Isolated in-1986) and PAR / Accident Man-Delays in responding to two stances of communciations asement Tabletop Drtil III ovacuation impediments) problems readily correctable (Rev. Aug. 1986) emphasize by revisions in LERO proco-responding to evacuation dures and training, impediments including com-munication of information. equipment requirements, re-sponse priorttles, and al-tornate traffic routing. LERO Classroom Training Program materials for Ses-slon 8 " Traffic Control" (Rev. July, 1986) empha-sizes communication of in-foroetton and timely re-sponse to evacuation imped-iments. (2) Deley in field Minor and readily corrected by LERO Traffic Control proce-Adequately address the en-verification of fuel truck revisions in LERO procedures dures have been revised to arcise issue, impediment (EOC-ARCA-9: and training. expedite dispatch of per-Delay in f6 eld vertftcation sonnel responding to inct-of fuel truck impediment) dents identified by the EOC. LERO field personnel non receive training with increased emphasis on re-sponses to evacuation im-pedirants. Modifications have been made ins (1) LERO Evacuation Route Spotter

U V U U U v v v v v e f CONTENTION CITED AkD STATUS AS SUPPORT FOR Ex 50.D MODIFICATIONS IN LERO RAC REVIEW OF LERO C3RRESPONDING FEMA COMMENTS PROCEDURES & TRAINING MODIFICATIONS Tabletop Drill I!! (Rev. May, 1986); (2) LERO Staging Area Management Tabletop Drtil III (Rev. May, 1986); (3) LERO Traf-fic Control Tabletop Drill V (Rev. May. 1986); (4) LERO Classroom Training Program materials for Session 8 " Traffic Con-trol" (Rev. July, 1986). (3) Appropriate Factually baseless. Personnel LERO Traffic Control Tab-Adequately address the en-personnel not dispatched to and equipment required to tetop Drtil V (Rev. May, arcise issue. removs multiple wehicle ac-clear blocked road were sent 1986) emphasizes communica-cident road impediment to accident. Facts do not tion directly between the (PSA-ARCA-8: Appropriate demonstrate a training flaw. EOC and Road Crems to en-personnel sio t dispatched Any problems mere minor and sure appropriate response, to clear multiple wohicle readily correctable by revi-accident road impediment) sions in LERO procedures and LERO Classroom Training training. Program materials for Session 8 " Traffic Control" trains traffic control per-sonnel. including Road Cre=s, to communicate by radio with the Road Logts-tics Coordinator at the EOC. C; Not admitted. D: Not admitted. E: Additioe. of Traffic En-Irrelevant to training. O n=er to EOC = auld not Conclusory allegation not l ollminate flaws in dealing based on Esercise events, eith road impediments EE 22I: (demit alth under ~~Id. EM 4Il Erroneous assump-tion that LERO needs to be sole to deal etth only two road impediments EK 42 (Bases incorporated in EK 38 & Ex 39) A: untimely /Instfective Duplicative of Contentions (see EX 41.8 above) (see EX 41.0) 6 6 %, 1 e n 3 ) s -a h e_ x N-m4 s 'J. w

] Y] ~ Q lN~ \\['~ l [ 7, =: " D ~N 2 N '9 - '- n r p p _ /,. p) r+ , pd,f 5g }dy.,l' N '\\ .., 3 ' ** 4. . % I _. 21*$,Q l3 s.,:g ' t D, *f - ( . $ ' ~,. s _w. .s f. .f _, ,e 4 p$ ~ }g , _ + 3 ,3 -

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.A ~- b% y t Q. q ( CONTU*. TION CITED NO STATUS AS SUPPORT FOR Ex C.o .Is0DIFICATIOsts Ist LERO RAC REVIEW OF LERO + l< ComeESPOceolmG FEMA CotspES ( g-PROCEDURES & TRAItalteG - as0DIFICATIQe05 .. : r.g g;; (. l 6 .r 1 ; 1 Y. 4 respo.,se to roa %)apedP1, -EX 41.8 and Ex 45.A. G + .;t : monts (EOC-D-la us16vs in. <g '] res;.onding ef f ectively ter N y 3

, _ read,lmpediments)

's t i _1 x 21 _r! i. .I** 3 tint ime l y / inadequa t e re-s Dupl icat'.$e on ', _entot t o s ' g LERO prar:odures modiffaq to* - N acequately address the es-e r On j spar.so to Pidae School x Ex 45.8 Factualty r ssless.1 ensure avaltional star * 'are 3rcise issa. t. U 1 l ovocuation message Dispatch of bui M3 mirmtes x-used to assist the Special a' V s i (PSA-ARCA-lls Forty minute after reCetht o6 f* guest at ' E*opulations Sus Dispatcher. 3 3 i delay in dispatching Sus PSA wee tteely uncar*the ctr-LERO Classroom Trainire ma " ,x W

\\

q s .s 9 terials for Session 9, i - Driver 7 to swacuate school > cuar.teceQ ,.y ' 4_ l q*l icres.)

g.

" Transportation "" 9.%~ s Coordinator" and " Pro-N tactive Actions for Special j* ! Populations

• emphesise need 4

for assistance in l , ^ espediting special popula - tion buses. Transportation Tabletop and Staging Area asanagement Tabletops also i emphasize this. j C: Inautatty to handle un-Duplicative of Contention I espe;ted rumors EX 39. Os Inability of Traffic Readily correctable by revi-LERO Classroom Training Adequately address the en-1 Guides to respond to stons in the LERO procedures Program materials for orcise issue. ovacuee questions and training. Session 8 " Traffic Control" (PSA-ARCA-7: Traffic (Rev. July, 1986) nom Guides lacked complete in-trains Traffic. Guides to formation on the approprl-Instruct evacuees to Itsten i ato destination for to the ESS radio station for evacuation information I> evacuses including evacuation desti-f not1ons. -LERO Identiftca-tion Sedge for Traffic i Guides, listing job-related duties on the back, in-1 structs them to advise i evacuees to listen to the ESS station. D. (cont.) Inability of Facts do not demonstrate a Traffic Guides now wear Traffic Guides to know en-pervasive flae in LERO LERO Identification Sedges I cess dose author 42ation training program. IAlnor, iso-enumerating radiological f procedus e (PSA-ARCA-16: lated incidents readily Cor-procedures on the bach for Traffic Guides did not un-rectable by revisions in LERO quick reference in the derstand ancess dosen equipment and training, field. The Sedge clearly i e I i 4 g e r a v v y <vv

j _j i ' CONTENTION CITED ANDl STATUS AS SUPPORT FOR EX'50.D MODIFICATIONS IN LERO HAC REVIEW OF LERO j PROCEDURES & TRAINihG : MOOlFICATIONS -COR?ESPONDING FEMA COMMENTS. cuthertzation procedures) states'that they will re-ceive authorization for en-cess esposure from the Lead Traffic Guide. Excess dose authorization procedures are now emphasized in re- ] vised LERO Classroom - i Training materials for Session 3 " Personnel Dostmetry and Emposure Con-l trol"-(Rev. July, 1986), Et Some bus delvers failed LERO procedures and training Sus Drivers are now as-Adequately address the ts-to carry out their assigned have been modified to ensure signed routes randomly in sues raised in the eser-dut ics* (PSA-D-6: Bus driv-thac every Sus Driver is capa-order to famillerize them ctse. era delayed, went to wreng ble of driving any randomly with a variety of routes transfer point. or missed assigned route. they might be called on.to i segment of assigned route) drive. l Transfer Point Coordinators j now check bus dispatch forms upon Driver's arrival to confirm that_the Driver is.at the correct transfer q 1 pctnt. LERO Classroom Training Program materials for Session 9 " Transportation Coordination" (Rev. July, 1986). the Transportation Tabletop (Rev. May. 1986) and the Staging Area Man-agement Tabletop (Rev. May, 1986) emphasize that Sus Drivers report to the Transfer Point Coordinator for verification of the Bus Dispatch Form to ensure that the Driver is at cor-rect location. Bus Driver Driving Instruc-tion Training (Rev._May. 1986) emphastzes the new vertftcation procedures. The session ~ includes a Road Rally in which each Driver j i l i

-( l CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50,0 MODIFICATIONS IN LERO, RAC REVIEW OF LERO CORRESPONDING FEMA COMMENTS PROCEDURES & TRAINING MODIFICATIONS runs a route to designated check locations. F: Traffic Guides arrived Factually baseless. Traffic Traffic Guides are now Adequately address the 1s-leto at control points Guides critical to a con-prestaged for immediate suas raised in the emer-(RSA-D-2: Traffic Guide trolled evacuation manned -dispatch within the 0-2 cise. d31cyed in arriving at con-their posts in a timely mile EPZ upon emergency trol points) fashion. Irrelevant to declaration. LERO Traffic training issue. Any problem' Control Tabletop Drtil V i was procedural. Procedures (Rev. May, 1986) and have been modified. Staging Area Management Tabletop (Rev. May, 1986) emphastze prestaging and rapid deployment of Traffic Guides in 0-2 mile EPZ. LERO Classroom Training Program materials for Ses-ston 8 " Traffic Control" (Rev. July, 1986) empha-sizes pre-equipping and pre-assigning of Traffic Guides. F. (con t) Bus drivers not Irrelevant to training issue. LERO Classroom Training Reserved decision pending dispatched in timely Drivers were dispatched ac-Program materials for completion of further modt-fashion (PSA-ARCA-1: Bus cording to procedures. Pron-Session 9 " Transportation fication of LERO procedures drivers not dispatched lem related to quantity of Coordination" (Rev. July, to assure timely briefings until 2 hours after emer-trained personnel available to 1986) now emphasizes that and distributton of gzncy declaration) assist Dispatcher in distribu-Transfer Point Coordinator dostmetry to Bus Drivers. tion of dostmetry. FEMA rec-assist Bus Dispatchers with ommended additional personnel distributton of materials be provided to assist in bus and dosimetry in order to dispatching. Sus dispatch expedite dispatch of Bus procedures have been modified

Drivers, to provide additional help.

The Transportation Tabletop and Staging Area Management Tabletop Drills (Rev. May, 1986) emphasize need f or assistance in rapid dis-patch of buses. Dosimetry Tabletop Drtin VI (Rev. Nov. 1986) emphasizes need for rapid distributton of dostmetry to large groups such as Bus Drivers. G: ENC personnel failed to Duplicative of Contention respond appropriately to EX 38. media questions i

CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.D MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENTS PROCEDURES & TRAINING MODIFICATIONS EX #S: (consolidated with Ex 50) A: Communications failures Duplicative of Contentions (see EX 41.8 above) (see EX 41.5) in response to traffic im-EX 41.8 and EX 42.A. psdiment messages (EOC-D-1: D31cys in responding to two cvecuation impediments: EOC-ARCA-9: Delay in field verification of fuel truck impsdiment) B: Cosimunications failures Duplicative of Contention (see EX 42.8 above) (see EX 42.5) in response to school evac-EX 42.B. Factually baseless, untion musbege Dispatch of bus 33 minutes (PSA-ARCA-II: Forty minute after receipt of request at dalay in dispatch of Bus PSA was timely under circum-Drivar tu evacuate school

stances, children)

C: Failure to notify FAA & Irrelevant to training conten-LERO will implement the new Reserved decision. RAC LIRR (EOC-ARCA-2: Confu-tion. Procedures were fol-recommendation that it con-made new recommendations ston regarding the method lowed during the esercise, tact FAA directly. A let-which LERO is implementing. of notifying FAA FEMA subsequently recommended ter of agreement with FAA a new notification procedure will be obtained and EOC (RAC Review, Dec. 15 1986). personnel designated and trained to communicate with FAA. (C: cont.) EOC-ARCA-3: Irrelevant to training conten-LERO procedures have been Planning prowlsions are ad-LIRR was not notified) tion. Procedures were fol-modified. The Evacuation equate. LERO should obtain lowed during the exercise. Coordinator notifies LIRR a letter of understanding of emergency status. LERO from LIRR. Accident Management Tab-1stop Drill emphasizes new responsibility of Evacus - tion Coordinator to notify. LIRR. D Failure to distin-Irrelevant to training conten-Dose Assessment status Adequately address the en-Cutsh between DOE RAP and tion. Facts involve equip-board has been revised to arcise issue. LILCO field monitoring on ment. separate data from DOE RAP doa0 assessment status and LILCO field monitoring board (EOC-ARCA-4: Not teams. A meeting was held enough columns on dose as-with DOE representatives on sessment status board to Jan. 6 1987 to review the kesp DOE HAP and LILCO data use of-new status board. sipsrated)

O 6 D .O -d. 'O 03 Lo O. 0 u' CONICNTION CITED AND STATUS AS SUPPORT FOR'Ex 50.D MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENTS PROCEDURES & TRAINING MODIFICATIONS Downwind distance of Isolated' instance.of human. All downwind distances now Adequately address the en-dose measurement errone-error caused by a decimal reported directly in miles arcise; issue, cualy reported as 7000 me-point misplaced during conver-without need to convert to ters instead of 700 meters, slon of distance units. Po-meters. This was reviewed (EOC-ARCA-5: Downwind dis-tantial for error reduced by during the LILCO/ DOE meet-tance of a thyroid dose change in procedures. ing on Jan. 6 1987. simple incorrectly reported as 7000 meters instead of 700 meters) Entrapolated doses Minor and readily correctable-Procedure now calls for Adequately address the en - erroneously reported as ac-by revisions in LERO proco-identification of data upon arcise lasue. tual doses on status board. dures and training, receipt at EOC as actual or (EOC-ARCA-bs Entrapolated outrapolated. DOE RAP per-dose data were reported-as sonnel were nottfled of actual measurements on sta-change in reporting proce-tus board) dure at the LILCO/ DOE meet-ing on Jan. 6, 1987. E Secretary did not de-Insignificant. Noted but not liver telephone message cited in FEMA Assessment as promptly to LERO Director deficiency or ARCA. Secre-tary's actions did not contra-vene any LERO procedure. Mes-sages designated by the caller as urgent would be immediately conveyed to the Director. F Communications fattures Duplicative of Contentions of ENC, Public Information. EX 38 and EX 39. cnd Rumor Control personnel G: Failure of RSA person-Failure to post time of update LERO Staging Area Manage- -Adequately address the en-nst to properly record was minor and readily cor- . ment Tabletop Detti III ercise issue, event information on status rectable by modifications in (Rev..May, 1986) now empha-board. (RSA-ARCA-1: Time training. sizes posting time of up-was not always included dated information on status when new information was

board, posted on status board)

Radio reception at Factually baseless. Irrele-Port Jefferson Staging Area. vant to training contention. was poor and disrupted "es-Based on sporadic radio recep-ssntial" communications tion problem. Noted but not cited in FEMA Assessment as deficiency or ARCA. Dub Dispatcher at Dispatcher's last minute LERO Staging Area Adequately address the PSA made inaccurate an-reminders to Bus Drivers were-Management Tabletop Drill exercise issue.

~ ' ' }'"~ .{ .( i CONTENTION CITED AND. STATUS AS SUPPORT FOR EX SD.D MODIFICATIONS.IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENTS' PROCEDURES & TRAINING MODIFICATIONS nouncements to Bus Drivers not complete but contained no III (Rev. May, 1986) now

t. bout dosimetry inaccuracles of important in-emphastzes.need for com--

(PSA-ARCA-12: Bus Dis-formation. Minor, isolated plate, precise instructions pStcher did not give instance not indicative of at all times, dostmetry units nor mention pervasive training flaw. 0-200 MREM DRD Bus Driver misdt-Minor, isolated instance not LERO Classroom Training Adequately address the en-rected at the BNL transfer indicative of pervasive Program materials for arcise issue, point. (PSA-ARCA-9: In-training flaw. Session 9 " Transportation structions to proceed to Coordination" and " Pro-Racsption Center were not tective Actions for Special propsrly transmitted at BNL Populations" (Rev. July, transfer point 1986) now emphasize the proper destinations for Bus Drivers. LERO Requaltftcation Training Session 9 (Rev. July, 1986) trains Drivers to proceed with evacuees to Reception Centers. LERO Staging Area Manage-ment. Tabletop Drill III and Transportation Tabletop Drtil (Rev. May, 1986) em-phastze training of Trans-for Point Coordinators to follow staging area direc-tions in instructing Bus Drivers. H: Inability to transmit Factually baseless. Problem correct information about originated with conflicting Suffolk County Police De-FEMA input into Exercise sco-partment abststence nario. -r

.U y V. U ~V 'v~ v- . y y u-CONTENTION EX 50.E LERO FAILED TO TRAIN PERSONNEL TO EXERCISE INDEPENDENT JUDGMENT OR COMMON SENSE CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.E MODIFICATIONS TO LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Ex 34: Route Alert Drivers Irrelevant to training conten- .LERO has undertaken a re-tnok too long to notify tion. Route Alert Drivers view of notification proce-

public, complied with procedures.

dures and personnel will be FEMA did not cite the length trained as newer procedures of time as a deficiency or are developed. ARCA. FEMA recommended that j the procedure for backup route l alerting be revised to reduce i the time needed for route alerting, perhaps by using multiple drivers. l EX 36: Inappropriate pro-Factually baseless. LERO tactive action recommenda-followed applicable proco-tion * (wind shift) dures. FEMA Report at 33. EX 38: Public Information As ENC delayud in opening; Factually baseless. ENC no information until first activation was timely. See nsus conference at 0840 FEMA Report at 52. LILCO issued press releases at 0625 and 0639. 8: First news release de-Factually baseless trrele-Essential emergency infor-Reserved decision based on layed and inaccurate vant to training. Informa-mation summarized and fact.that LERO had not yet (ENC-D-12 Insufficient tion was timely provided. transmitted-via computer decided to upgrade copying copying capablittles re-Equipment problem, not from the EOC to ENC and all capabilities. sultad in delays in distri-training, caused delays in rumor control locations st-bution of information) distributing updated infor-multaneously. Additional mation. New procedures and' copying equipment (total of better copying capability 5 machines) ensures sufft-should obvlate problem. cient capability in event of unanticipated machine failure. C: Second news release de- ~~Id. -Id. ~Id. layed (ENC-D-1: Insufft-cient copying capablittles resulted in delays in

CONTENTION CITED AND. STATUS AS SUPPORT FOR EX 50.E MODIFICATIONS IN LERO RAC REVIEW OF.LERO CORRESPONDING FEMA COMMENT PROCEDURES E TRAINING MODIFICATIONS distribution of informa-tion) Da Insufficient copying Irrelevant to training. Id. Id. cep:btlity at ENC delayed Equipment problem caused de-distribution of information lays in distributing updated (ENC-D-1: Insufficient information. New procedures copying capabilities re-and better copylog capability sultsd in delays in distrl-should obviate problem, bution of information) E Insufficient / inadequate Irrelevant to training. Facts The suggested displays and Adequately address the en-maps and displays based on equipment deficiency. status boards have been orcise issue. (ENC-ARCA-2: Insufflctent provided to the ENC. mtps and displays) F EBS message contained Minor and corrected by revi-Press Release procedures The plan modifications ade-entreneous information sions in LERO procedures and-have been modified. ESS .quately address the ener. (ENC-ARCA-3: EBS messages followup training, messages will no longer be cise issue, contained entraneous infor-released. The Coordinator mation) of Pubite Information pre-pares press releases.using an established format. The J Director of Local Response i approves it. The LERO Spokesperson directs dis-tributton to the media. LERO Public Information Group Personnel receive training in the new proco-dures in the LERO Public Information Tabletop Drill I (Rev. Nov. 1986). G: Press releases Duplicative of Contention (see EX 38.B above) (see EX 38.8) late / inaccurate (ENC-D-la EX 38.C. Irrelevant to Insufficient copying capa-training. Information was bilities resulted in delays timely provided. Equipment in distribution of informa-problem caused delays in tion) distributing updated informa-tion. New procedures and bat-ter copying capability should I obviate problem. H: Evacuation decision Id. (see EX 38.8 above) (see EX 38.8) given to media too late 4 (ENC-D-1: Insufficient I 3

y y .y y-u- y v y- ,y CC:iTENTION CITED AND STATUS AS SUPPORT FOR EX 50.E . MODIFICATIONS IN LERO RAC REVIEW OF LERO. COR".ESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS copying capabilities re-tutted in delays in distri-button of information) is radia requested not to Factually baseless. In accor-inform public of LERO dance with LERO procedures workers' ingestion of KI media were never briefed about LERO workers' KI ingestion. 'J ENC personnel unable to Factually baseless. Facts-do provide information to not demonstrated a failure to medias unable to contact provide the media information. Marketing Evaluations Ks Not admitted. L ENC log falsely indi-Exercise events do not impit-cated gravel truck impedt-cate deficiency in training. ment was being removed The inaccurate information was not released to the public or the media. 2: ENC personnel could not Factually baseless. LERO cnswsr questions about im-spokesperson reported essen-psdiment tlal deta11s including loca-tion of road blockage and rerouting.of traffic. N ENC misstated facts Insignificant. 1solated errors about (1) when Emergency during a whole day's worth of was declared (0:23 correct public information do not es-t i m;3 was 8:19). (2) EPZ tablish a training problem. winter vs. summer popula-tion Os Delayed delivery of Onsite functions irrelevant to (see EX 38.8 above) (see EX 38.8) press releases 4 and 5 to training. Media Monitoring Midia Monitoring (ENC-D-1: receives information through Intufficient copying capa-EBS messages, does not have bilities resulted in delays immediate need for news re-in distribution ot informa-leases. Equipment problem tion) caused delays in distributing updated information. New pro-cedures and better copying ca-pability should obviate prob-lem. P: Humor Control operation Duplicative of Contention instfective as described in EX 39.

CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.E MODIFICATIONS IN LERO . RAC REVIEW OF LERO-CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Contsntion EX 39 Q: LERO modifications Irrelevant'to training. wculd be inadequate to rem-Conclusory allegation not cdy " deficiencies" based on Exercise events. EX 39: Rumor Control As Call Board Operators Onsite function. Irrelevant (see EX 38.8 above) (see EX 38.8) hid inaccurate / outdated to LERO trainings factually information; answered in-baseless. The few instances ] quiries too slowly or in-of superseded information re-correctly (ENC-D-1: Insuf-sulted from an equipment prob-ficient copying capabili-lem. New procedures and bat-ties at ENC resulted in de-ter copying capability should lays in distributing infor-obviate problem, enstion to rumor control psrsonnel) 8: Late responses to simu-Onsite function. Irrelevant lated rumor messages to trainings conclusory and factually baseless. Responses to messages were as expedt-tious as accuracy would allow. Personnel acted according to procedures. C: Rumor Control personnel Onsite function.. Irrelevant (see EX 38.8 above) (see EX 38.8) provided inaccu-to training. Information pro-rate / superseded information vided was generally timely and (ENC-D-l: Insufficient correct. ' Isolated instances copying capabilities at ENC of inaccurate information were resulted in delays in based primarily on an equip-distributing information to ment problem. New procedures rumor control personnel) and better copying capability. should obviate problem. EX 44: (1st sentence con-Irrelevant to training. Fac-solidated with EX 38 and tually baseless. Exercise EX 39): Failure to provide events do not support allega-i occurate. clear information tion of a substantial evacua-l would create a substantial tion shadow. evscuation " shadow" EX 22F: False assumption Irrelevant to training. of no prumature evacuation Conclusory allegation not based on Exercise events. J

J J CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.E MODIFICATIONS-IN LERO-RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS EX 40: Plan falls to Irrelevant to training issue, provide for timely evacuee Contention EX 40 concerns ade-r*mietance quacy of Plan and Procedures and presents no factual sup-port on issue of esercise of + independent judgment by LERO personnel. As Pursuant to Plan and Id. Procedures Traffic Guides were not mobilized until after declaration of Site Area Emergency 8: Pursuant to Procedures id. Traffic Guides were not de-played until after evacua-tion recommendation C: EDS message issued pur-Id. e,usnt to the Plan falsely told public Trafttc Guides would be in place D: Not admitted. ) E: LERO "fix* would not Irrelevant to training, issue. 7 correct problems with Traf-Conclusory allegation not j fic Guide mobilization and based on Exercise events. drployment. EX 41: Traffic Impediments As Slow moutitzation of Irrelevant not a training Road Crews problem. Factually. baseless. Sufficient Road Crews were mo-bilized in accordance,with. procedures. t Failure to respond ade-Duplicative of Contentions Traffic Engineer added to Adequately address the'is-B: quetely to two road impedi-EX 42.B and EX 45.A. Facts do EOC. LERO Traffic Control sues raised in the emer-ments: (1) Communications not demonstrate a pervaalve. Tabletop Drtil V (Rev. May. cise. fattures at EOC (EOC-D-1: training flaw. Isolated in- .1986) and PAR / Accident Man-I Dalays in responding to two stances of communciations agement Tabletop Drtil III evacuation impediments) problems readily correctable (Rev. Aug. 1986) emphasize a by revisions in LERO proce-responding.to evacuation-dures and training. impediments including com-munication of information. t I

7 CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.E MODIFICATIONS IN LERO RAC REVIEW OF LERO' CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS equipment requirements,'re-sponse priorities, and al-tornate traffic routing. LERO Classroom Training Program materials for Ses-ston 8 " Traffic Control" (Rev. July, 1986) empha-sizes communication of in-formation and timely re-sponse to evacuation imped-1ments. (2) Delay in field Minor and readily corrected by LERO Traffic Control proce-Adequately address the en-varification of fuel truck revisions in LERO procedures dures have been revised to arcise issue. Impsdiment (EOC-ARCA-9: and training. expedite dispatch of per-Daley in field verification sonnel responding to.inci-of fuel truck impediment) dents identified by the EOC. LERO field personnel now receive training with increased emphasis on re-sponses to evacuation im-pediments. Modifications have been made ins (1) LERO Evacuation Route Spotter Tabletop Drill III (Rev. May, 1986)l (2) LERO Staging Area Management Tabletop Drill III (Rev. May, 1986): (3) LERO Traf-fic Control Tauletop Ortil.V (Rev. May, 1986): (4) LERO Classroom Trair*ng Program materials for Session 8 " Traffic Con-trol" (Rev. July, 1986). (3) Appropriate Factually baseless. Personnel LERO Traffic Control Tab-Adequately address the en-psrsonnel not dispatched to and equipment required to letop Drill V (Rev. May, arcise issue. remove multiple vehicle ac-clear blocked road were sent 1986) emphasizes communica-cidant road impediment to accident. Facts do not tion directly between the (PSA-ARCA-8: Appropriate demonstrate a training flaw. EOC and Road Crews to en-psrsonnel not dispatched Any problems were minor and sure appropriate response. to clear multiple vehicle readily correctable by revi-cccident road impediment) sions in LERO procedures and LERO Classroom Training training. Program materials for Session 8 " Traffic Control" trains traffic control

I CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50 E MODIFICATIONS IN LERO. RAC REVIEW OF LERO: CONRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS personnel, including Road Crows, to communicate by radio with the Road Logis-tics Coordinator at the EOC. C: Not admitted. D Not admitted. E: Addition of Traffic En-Irrelevant to training, ginear to EOC would not Conclusory allegation not eliminate flaws in dealing based on Exercise events, with road impediments EX 221: (dealt with under Id. EX 41) Erroneous assump-tion that LERO needs to be able to deal with only two road impediments EX 42 (Bases incorporated in EX 38 & EX 39) At Untimely / ineffective Duplicative of Contentions (see EX 48.8 above) (see EX 41.B) response to road impedi-EX 41.B and EX 45.A. m' ants (EOC-D-ts Delays in responding effectively to road impediments) B: Untimely / inadequate re-Duplicative of Contention LERO procedures modified ~ to Adequately address the en-sponse to Ridge School EX 45.B. Factually baseless. ensure additional staff are arcise issue. evacuation message Dispatch of bus 33 minutes used to assist the Special (PSA-ARCA-Ils Forty min. after receipt of request at Populations Bus Dispatcher. delay in dispatching Bus PSA was timely under circum-LERO Classroom Training ma-uriver to evacuate school

stances, terials for Session 9, children)

" Transportation Coordinator" and

• Pro-tactive Actions for Special Populations" emphasize need for assistance in expediting special popula-tion buses.

Transportation Tabletop and Staging' Area Management Tabletops also emphasize this. C; Inability to handle Duplicative of Contention unempected rumors EX 39.

y y~ .Q Q .y. U y-y. -. g. - y r . CONTENTION CITED AND STATUS AS' SUPPORT FOR Ex 50.E-MODIFICATIONS IN LERO RAC' REVIEW OF LERO CORRESPONDING FEMA COMMENT' - PROCEDURES & TRAINTNG MODIFICATIONS-D: Inability of Traffic Readily correctable by revi. LERO Classroom Training Adequately address the en-Guid3s to respond to 'alons in the LERO procedures. Program materials for orcise issue. evccues questions and training. Session 8 " Traffic Control" (PSA-ARCA-7: Traffic (Rev. July, 1986) now Guidas lacked complete in-trains Traffic Guides to formation on the appropri- . instruct evacuees to listen ato destination for to the EBS radio statten. ovecuees for evacuation information including evacuation desti-nations. 'LERO Identifica-tion Sadge for' Traffic. Guides, listing job-related duties on the back, in-structs them to advise. evacuees to. listen to the EBS station. D. (cont.) Inability of Facts do not demonstrate a Traffic. Guides now' wear Traffic Guides to know en-pervasive flaw in LERO LERO Identification Badges cess dose authorization training program. Minor, iso-enumerating radiological' procedure (PSA-ARCA-16: lated incidents readily cor-procedures on the back for Traffic Guides did not un-rectable by revisions in LERO quick reference in the darstand excess dose autho-equipment and training, field. The Badge clearly rization procedures) states that they will re-ceive authorization for en-cess exposure from the Lead Traffic Guide. Excess dose - authorization procedures, are now emphasized in re- . vised LERO Classroom Training materials for Session 3 " Personnel Dosimetry and Exposure Con-trol" -(Rev. July, 1986). Es Some Bus Drivers failed LERO procedures and training Bus Drivers are now as-Adequately address the is-to carry out their assigned have been modified to ensure . signed routes randomly in sues raised in the euer-duties (PSA-D-6: Bus Driv-that every Bus Driver is capa- . order to familiarize them cise. ers delayed, went to wrong ble of driving any randomly with a. variety of routes transfer point, or missed assigned route. they might be called on to ssgmsnt of assigned route) drive. Transfer Point Coordinators now. check bus dispatch forms upon Driver's arrival' to confirm that the Driver is at the correct transfer point.

4 f t I CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.E .MODIFICATI'ONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS LERO Classroom Training Program materials for Session 9 " Transportation Coordination" (Rev. July, e 3 1986), the Transportation Tabletop (Rev. May. 1986) and the Staging Area Man-agement Tabletop (Rev. May, 1986). emphasize that Bus Drivers report to the Transfer Point Coordinator. for vertftcation of the Bus Dispatch Form to ensure that the Driver is at cor-rect location. Sus Driver Driving Instruc-tion Training (Rev. May, 1986) emphastzes the new verification procedures. The session includes a Field Practical in which each Driver runs a route to designated check locations. F: Traffic Guides arrived Factually baseless. Traffic Traffic Guides are now Adequately address the is-late at control points Guides critical to a con-prestaged for immediate suas raised in the ener-a (RSA-D-2: Traffic Guide trolled evacuation manned dispatch within the 0-2 cise. d3 layed in arriving at cen-their posts in a timely mile EPZ upon emergency trol points) fashion. Irrelevant to declaration. LERO Traffic training issue. Any problem Control Tabletop Drill V was procedural. Procedures (Rev. May, 1986) and have been modified. Staging Area Management Tabletcp (Rev. May, 1986) . emphasize prestaging and rapid deployment of Traffic Guides in 0-2 mile EPZ. LERO Classroom Training Program materials for Ses-ston 8 " Traffic Control" (Rev. July, 1986) empha- ] sizes pre-equipping and pre-assigning of Traffic Guides. F. (con.t) Bus Drivers not Irrelevant to training issue. LERO Classroom Training . Reserved decision pending dispatched in timely Drivers were dispatched Program materials for completion of further 1

n CONTENTION CITED AND ' STATUS AS SUPPORT FOR EX 50.E MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS-fashion (PSA-ARCA-1: Bus according to procedures. Session.9 " Transportation modification of LERO proco-4 1 drivers not dispatched . Problem related to quantity of-Coordination" (Rev. July, dures to assure timely untti 2 hours after emer-trained personnel available to 1986) now emphasizes that. briefings and distribution Osncy declaration) assist Dispatcher in distribu-Transfer Point Coordinator of dosimetry to Bus Driv-tion of dostmetry. FEMA rec-assist Sus Dispatchers with era. ommended additional personnel distribution of materialss be provided to assist.in bus and dosimetry in order to + dispatching. Bus dispatch expedite dispatch of Sus procedures have been modified Drivers. to provide additional help. The Transportation Tabletop and Staging Area Management ' Tabletop Drills (Rev. Nay. 1986) emphasize need for assistance in rapid dis-patch of buses.. Dosimetry Tabletop Drill VI (Rev. Nov. 1986) emphasizes need for rapid distribution of dostmetry to large groups such as Bus Drivers. G: ENC personnel fatted to Duplicative of Contention respond appropriately to EX 38. media questions 1 EX 45: (cnnsolidated with l EX 50) 7 As Communications failures Duplicative of Contentions (see EX 41.B above) (see EX 41.8)~ l in response to traffic im-EX 41.B and EX 42.A. j pediment messages (EOC-D-1: 031ays in responding to two evacuation impediments; EOC-ARCA-92 Delay in field verification of fuel truck impediment) j 0: Communications failures Duplicative of Contention (see EX 42.8 above) (see EX 42.8) in response to school evac-EX 42.B. Factually baseless, untion message Dispatch of bus 33 minutes (PSA-ARCA-11: Forty minute after receipt of request at dalsy in dispatch of Bus PSA was timely under ctrcum-Driver to evacuate school stances. children) C: Fai lur e to notify FAA & Irrelevant to training con't'en-LERO will" implement the new Reserved decision.' RAC' LIRR (EOC-ARCA-2: tion. Procedures were recommendation that it .made new recommendations Confusion rewarding the followed during.the exercise, contact FAA directly. A which LERO is-implementing, i J

CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.E MODIFICATIONS IN LERO RAC REVIEW OF LERO PROCEDURES & TRAINING MODIFICATIONS CORRESPONDING FEMA COMMENT method of notifying FAA FEMA subsequently recommended letter of agreement with a new nottftcation procedure FAA will be obtained and (RAC Review. Dec. 15, 1986). EOC personnel designated and trained to communicate with FAA. (C cont.) EOC-ARCA-3: Irrelevant to training conten-LERO procedures have been Planning provisions are ad-LIRR was not notifted) tion. Procedures were fol-modified. ine Evacuation equate. LERO should obtain lowed during the exercise. Coordinator notiftes LIRR a letter of understanding of emergency status. LERO from LIRR. Accident Management Tab-letop Drill emphasizes new responsiblitty of Evacua-tion Coordinator to notify 4 LIRR. Os Failure to distinguish Irrelevant to training conten-Dose Assessment status Adequately address the en-betwsen DOE RAP and LILCO tion. Facts involve equip-board has been reviseo to arcise.tssue. fletd monitorinu on dose ment. separate data from OOE RAP essessment status board and LILCO field monitoring (EOC-ARCA-4: Not enough teams. A meeting was held columns on dose assessment with DOE representatives on status board to keep DOE Jan. 6, 1987 to review the use of new status board. RAP and LILCO data sepa-rated) Downwind distance of Isolated instance of human All downwind distances now Adequately address the ex-dose measurement errone-error caused by a decimal reported directly in miles orcise issue, ously reported as 7000 me-point misplaced during conver-without need to convert to ters instead of 700 meters. sion of distance units. Po-meters. This was reviewed (EOC-ARCA-5s Downwind dis-tential for error reduced by during the LILCO/ DOE meet-tence of a thyroid dose change in procedures. ing on Jan. 6, 1987. simple incorrectly reported as 7000 meters instead of 700 meters) Entrapolated doses Minor and readily correctable Procedure now calls for Adequately address the en-erroneously reported as ac-by revisions in LERO proce-identification of data upon arcise issue. ~ tual doses on status board, dures and training. receipt at EOC as actua1 or (EOC-ARCA-6: Entrapolated extrapolated. DOE RAP per-dose data were reported as sonnel were nottfled of i actual measurements on sta-change in reporting proce-tus board) dure at the LILCO/ DOE meet-ing on Jan. 6, 1987. E Secretary did not de-Insignificant. Noted but not liver telephone message cited in FEMA Assessment as promptly to LERO Director deficiency or ARCA.

- - = s CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.E MODIFICATIONS IN LERO RAC REVIEW OF LERO N CORTESPONDING FEMA COMMENT . PROCEDURES & TRAINING MODIFICATIONS Secretary's actions'did not contravene any LERO procedure. Messages designated by:the' caller as urgent would be im-mediately conveyed to the Di-rector. F Communications failures Duplicative of Contentions of ENC, Pubite Information. EX 38 and EX 39. and Rumor Control personnel Gs Failure of RSA~ Failure to post time of. update LERO Staging Area Manage-Adequately address the ex-" person-nel to properly record was minor and readily cor- .mont Tabletop Drill III ercise issue. event information on status rectable by modifications in (Rev. May, 1986) now empha-board. (RSA-ARCA-1: Time training. sizes posting time of up-was not always included dated information on status when new information was board. posted on status board) Radio reception at Factually baseless. Irrele-Port Jefferson Staging Area vant.to training contention, was poor and disrupted "es-Based on sporadic. radio recep-sent ia l" conununicat ions tion problem. Noted but not-cited in FEMA Assessment as deficiency or ARCA. Bus Dispatcher at Dispatcher's last minute re-LERO Staging Area Manage-Adequately address'the'ex-PSA made inaccurate an-minders to Bus Drivers were ment Tabletop Drtil III ercise issue, nouncements to Bus Drivers not complete but contained no -(Rev. May,'1986) now empha-about dostmetry inaccuracies of important in-sizes need for complete. (pSA-ARCA-12: Bus Dis-formation. Minor, isolated precise instructions'at all patcher did not give instance-not indicative of.

times, dosimetry units nor mention pervasive training flism.

O-200 MREM DRO Bus Driver misdi- ' Minor, isolated instance not. LERO Classroom Training Adequately address the ex- ' rected at the BNL transfer . indicative of pervasive Program materials for orcise. issue, point. (PSA-ARCA-92 In-training flaw. Session 9 " Transportation structions to proceed to Coordination" and " Pro-2 Reception Center were not tactive Actions for Special property transmitted at BNL Populations" (Rev. July, transfer point 1986) now. emphasize the. . proper destinations.for Bus Drivers. LERO Requalification. -Training Session 9 (Rev. July. 1986): trains DriversL

CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.E MODIFICATIONS IN LERO. RAC REVIEW OF'LERO COR*ESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS to prcceed with evacuees to Reception Centers. LERO Staging Area Manage-ment. Tabletop Drill III and Transportation Tabletop Drill (Rev. May, 1986) em-phasize training of Trans-for Point Coordinators to-follow staging area direc-tions in instructing Bus Drivers. Hs Inability to transmit Factually baseless. Problem correct information about originated with conflicting Euffolk County Police De-FEMA input into Exercise sco-psrtment assistance nario. EX 49: Inability to regis-tar and monitor evacuees A: Radiological monitoring Factually baseless; monitoring. LERO Classroom Training ma-Adequately address the en-frequently took too long, only occasionally took longer terials for Session 7 " Mon-ercise issue. (RC-ARCA-la Radiological than 90 seconds. LERO person-itoring and Decontamina-monitoring occasionally nel demonstrated ability to tion" have been revised to took longer than 90 seconds monitor evacuees in 90 sec-emphasize taking no longer spicified in LERO proce-

onds, than 90 seconds to monitor dures) evacuees at Reception Cen-ter.

EX 31 (dealt with under Irrelevant to training. Con-EX 49.A): Insufficient tention alleges deficiency in staff at Reception Center quantity of personnel, not their training. Os Ability to obtain addi-Irrelevant to training. Con-tional monitoring personnel tantion is not based on Exer-cod other features of pur-cise events. Factually base-ported alternate monitoring less. Ability to secure addt-plan not demonstrated tional monitoring personnel from INPO and elsewhere was demonstrated. C More persons than ad-Factually baseless. vissd would seek ra-Conclusory allegation not diological monitoring based on Exercise events or occurrences.

U- .U' g'-- .g'. .y y- ,y OTHER FEMA COMMENTS CITED STATUS AS SUPPORT FOR EX 50,E MODIFICATIONS IN LERO RAC REVIEW OF LERO PROCEDURES & TRAINING MOO!FICATIONS PSA-ARCA-5: Unsecured door Irrelevant to training conton-LERO procedure modified. Adequately address the en-at fire escope on east side tion. Facts do not implicate New procedure calling for arcise issue. of building a training flaw. ~ PSA Guard Post I to ensure security for fire escape door is stressed at LERO Staging Area Management . Tabletop Drill III (Rev. May. 1986) PSA-ARCA-lOs Rubidences of Irrelevant to training conten-LERO is evaluating maps for Adequately address the ex-some persons were difficult' tion. FEMA. recommended Driv-clarity and if warranted arcise issue. for Drivers to find ers be provided more detailed-will include utility pole maps and descriptions of pick numbers for markers of pick-up points. up points. l l 4 1 I l

zi CONTENTION EX 50 F LERO FAILED TO TRAIN PERSONNEL TO EFFECTIVELY INFORM THE PU6LIC THROUGH THE MEDIA CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.F MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENTS PROCEDURES & TRAINING MODIFICATIONS EX 37: Psntective Action Rncommendations (Not sepa-retely admitted but incor-porated into subpart I of EX 15) A: Failure to estend PARS Irrelevant to training conton-beyond 10 mile EPZ tions. Factually baseless. LERO followed applicable pro-cedures. FEMA Roport at 33. Os No PARS for other than Id. dairy animals C No PARS concerning Id. j water and fuod Da Failure to complete Inconsequential. Actual data 1 ground deposition worksheet were available so completion of an estimation worksheet was { unnecessary. EX 38: Public Information A: ENC delayed in openings Factually baseless. ENC no information until first activation was timely. See nsws conference at 0840 FEMA Report at S2. LILCO is-sued press releases at 0625 and 0639. B: First news release de-Factually baseless: trrelevant Essential emergency infor-Reserved decision based on layed and inaccurate to training. Information was mation summarized and fact.that LERO had not yet (ENC-D-1: Insufficient timely provided. Equipment transmitted via computer decided to upgrade copying copying capabilities re-problem, not training, caused from the EOC to ENC and all capabilities, sulted in delays in distri-delays in distributing updated rumor control locations st-button of inf or ma t i on ) information. New procedures multaneously. Additional and better copying capability copying equipment (total of should obviate problem. 5 machines) ensures sufft-cient capability.in event of unanticipated machine failure.

U V U_ U V- .y y y y y y CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.F MODIFICATIONS IN LERO RAC REVIEW OF LERO COR*ESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Cs Sicond news release de- ~~Id. Id. .Id. Icysd (ENC-D-la Insufft-cient copying capabilities resulted in delays in dis-tribution of informatton) D Insufficient copying Irrelevant to training. Id. Id. ccpfbility at ENC delayed Equipment problem caused de-distribution of information lays in distributing updated (ENC-D-1: Insufficient information. New procedures copying capabilities re-and better copying capability eulted in delays in distri-should obviate problem. bution of infor -t ion) En Insufttcient/ inadequate Irrelevant to training. Facts The suggested displays and Adequately address the en ' maps cod displays based on equipment deficiency. status boards have been orcise issue. (ENC-ARCA-2: InsufflCtent provided to the ENC. maps cnd displays) F: ETS message contained Minor and corrected by revi-Press Release procedures The plan modifications ade-cat eneous information sions in LERO procedures and have been modified. EBS- .quately address the emer-(ENL-ARCA-3: EBS messages followup training. messages will no longer be cise issue. contained entraneous infor-released. The Coordinator of Pubite Information pre-mation) pares press releases using an established format. The Director of Local Response-approves it. The LERO Spokesperson directs dis-l tribution to the media. 1 LERO Public Information I l Group Personnel receive training in the new proco-dures in the LERO Public .I i Information Tabletop Drtil l (Rev. Nov. 1986). G: Press releases Duplicative of Contention (see EX 38.8 above) (see EX 38.8) late / inaccurate (ENC-D-1: EX 38.C. Irrelevant to Insufficient copying capa-training. Information was bilities resulted in delays timely provided. Equipment in distribution of informa-problem caused delays in i tion) distributing updated informa-tion. New procedures and bet-ter copying capability.should obvtate problem. H: Evacuation decision Id. (see EX 38.8 above) (see.EX 38.8) I l f

A/' .v- %/ %.r. .v x.e ..v. ,v-w . y.. i; >S CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50,F' MODIFI' CATIONS IN LERO 'RAC REVIEW OF'LERO '1 ~ COR'ESPONDING FEMA COMMENT PROCEDURES &-TRAINING MODIFICATIONS Diven to media too late '(ENC-D-1: Insufficient ccpying capabilities re-sulted in delays in distri-bution of information) J .) Is Media requested not to Factually baseless. In accor-inform public of LERO dance with LERO procedures workers' ingestion of KI media were never briefed about LERO workers' KI ingestion. Ja ENC perbonnel unable to _ Factually. baseless. Facts do provide information to not demonstrated a failure to I media; unable to contact provide the media information. Marketing Evaluations Es Not admitted. La ENC tog falsely indi-Exercise events do not impli-cated gravel truck impedi-cate deficiency in training. ment was being removed The inaccurate information was not released to the public or the media. ,j Q: ENC personnel could not Factually baseless. LERO cnsusr questions about im-spokesperson reported essen-pIdtment tial details including loca-tion of road blockage and rerouting of traffic. 1 N: ENC mlbstated facts Insignificant. 1solated errors about (I) when Emergency during a whole day's worth of eas declared (0823 correct public information do not es-time was 0819). (2) EPZ tablish a' training problem, winter vs. summer popula-tion 0: Delayed delivery of Onsite functions irrelevant to (see EX 38.8 above) (see EX 38.8) press releases 4 and 5 to training. Media Monitoring Media Monitoring (ENC-D-13 receives information through Insufficient copying capa-EBS messages, does.not have bilities resulted in delays immediate need for news re-l in distribution of informa-leases. Equipment problem tion) caused delays in distributing l updated Information. New pro-j cedures and better copying ca r pability should obviate prob-l

lem, w.

i l

P CONTENTION CITED AND ' STATUS AS SUPPORT FOR Ex 50.F' MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS P Eumor Control operation Dupilcative of Contention inetfective as described in Ex 39. Contention EX 39 Q: LERO modifications Irrelevant to training, usuld be inadequate to rem-Conclusory allegation not Gdy "deftetencies" based on Exercise events. Ex 40.C: EBS message Irrelevant to training issue. falsely tolo public Traffic Contention Ex 40.C presents no Guldts would be in place factual support on issue of esercise of independent judg-ment by LERO personnel.

a CONTENTION Ex 50.H LERO HAS FAILED TO TRAIN PERSONNEL IN DOSIMETRY. EXPOSURE CONTROL, AND KI USE LONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.H MODIFICATIONS IN LERO RAC REVIEW OF LERO CORRESPONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS Ex 27: School Bus Drivers le ch training in. (1) dosimetry Facts do not implicate deft-No changes in LERO training Reserved decision ~pending' (EOC-ARCA-II: Dostmetry ciency in the training of-program required. LERO is . development of mechanism t o End training have not been fered. Currently developing a facilitate' training of mechanism to facilitate non-LERO personnel, provided to school evacua-tion Cus Drivers) participation of non-LERO school Bus Crivers in LERO t raining pr ogram. (2) KI procedures Id. Id. Id. (EOC-ARCA-13: School evac-ustion Bus Drivers have not b;sn trained in use of KI) (3) excess exposure autho-Id. Id. Id. rization (EOC-ARCA-15: School evacuation Bus Driv-ers have not been trained reg rding escess dose au-thorization) Ex 23: Ambulette Drivers Facts do not implicate a deft - LERO training for Ambu-Adequately address the en-eere not all trained in en-ciency in the training of-lance /Ambulette Drivers is arcise issue, cessive esposure authoriza-fered. Problem noted was conducted monthly now to tion and procedures caused by high attrition among ensure that new drivers are (EOC-ARCA-14: Amuulette Ambulance /Ambulette Drivers trained quickly. LERO Drivers were not all who had been trained. Re- -Classroom Training Program trained regarding excess placements had not yet re-materials have been revised dose authorization) ceived training at time of the to emphasize radiological Eser'ise. Procedures have procedures including excess been revised to rectify prob-esposure authorization pro-lem. cedures. Ex 42 (Bases incorporated in Ex 38 & Ex 39) As untimely / ineffective Irrelevant to training of per-response to road impedi-sonnel in radiological proca-ments (EOC-D-1: Delays in

dures, responding effectively to road impediments)

r----. CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 50.H MODIFICATONS IN LERO. RAC REVIEW OF LERO COR"EFOONDING FEMA COMMENT PROCEDURES & TRAINING MODIFICATIONS S: Untimely / inadequate re-id, eponse to Ridge School ovecuttlon nessage (PSA-ARCA-II; Forty minute dolcy in dispatching Bus Driver to evacuate school children) C Inability to handle un-Id. esp 3cted rumors D: Indbility or Traffic Id. Guldss to respond to swscuse questioning or know oncess dose authorization procedure (PSA-ARCA-7 Treffic Guides lacked com-plate inf or mat ion) (PSA-ARCA-16; Trattic Facts do not demonstrate a Traffic Guides wear LERO Adequately address the en-Guldss did not understand pervasive flaw in LERO Identification Badges arcise issue, escess dose authorization training program. Minor, iso-enumerating radiological procedures) lated incidents readily cor-procedures on the back for rectable by revisions in LERO quick reference.in the equipment and training, field. The Badge clearly states that.they will re-cetve authorization for en-cess esposure from the Lead Traffic Guide. Excess dose authorization procedures are now emphasized in re-vised LERO Classroom Training materials for Session 3 " Personnel Dostmetry and Exposure Con-trol" (Rev. July, 1986). Es Some Bus Drivers fatted Irrelevant to training of per-to carry out their assigned sonnel in radiological proca-dutics (PSA-D-6 Bus Driv-

dures, ers delayed, went to wrong trtnsfer point, or missed segment of assigned route)

F: Traffic Guides arrived ~~Id. late at control points (RSA-D-2: Traffic Guide e

.1 A

CONTENTION CITED AND STATUS AS SUPPORT FOR EX 50.H MODIFICATONS IN LERO- .RAC REVIEW OF LERO COR'ESPONDING FEMA COMMENT -PROCEDURES & TRAINING MODIFICATIONS' delayed in errivir.g at Con-trol points) Cus Drivers not dispatched Id. In timely fashion (PSA-K.RCA-Is Bus Drivers not dispatched until 2 hours after emergency dec-Isration) G: ENC personnel failed to id, respond appropriately to media questions Ex 45: (appended to end of EM 50) As Communications failures Irrelevant to training of per-in response to traffic im-sonnel in radiological proco-psdtment messmues (EOC-D-1: dures. D30ays in responding to two evccuation impediments EOC-ARCA-9: Delay in field-vselfication of fuel truck tapediment) 5: Communications fattures id. In response to school oveucation message (PSA-ARCA-II: Forty minute dalay in dispatch of Bus Driver tu evacuate school children) C Fmilure to notify FAA & Id. LIRR (EOC-ARCA-2: Confu-slon regerding the method of nutifying FAA EOC-ARCA-3: LIRH was not Id. nottfled) D Failure to distinguish Irrelevant to training conten-Dose Assessment status Adequately address'the en-between DOE RAP and LILCO tion. Facts involve equipment board has been revised to orcise issue. field monitoring on dose defletency. separate data from DOE RAP casessment status board and LILCO field monitoring. (EOC-ARCA-4: Not enough teams. A meeting was held

CDNTENTION CITED AND STATUS AS SUPPORT FOR EX 50.H MODIFICATONS IN LERO RAC REVIEW OF LERO COR'ESPONDING FEMA COMMENT PROCEDURES-& TRAINING MODIFICATIDNS' columns on dose assessment with DOE resprentatives on status board to keep DOE

Jan, 6,

1987 to review use RAP cnd LILCO data sepa-of new status board, rated) Downwind distance of Isolated instar.ca of human All downwind distances now Adequately address the en-dose measurement errone-error caused by a decimal reported directly in miles orcise issue, cualy reported as 7000 me-point misplaced during conver-without need to convert to ters instead of 700 meters. sion of distance units. Po-meters. Reviewed during (EOC-ARCA-5: Downwind dis-tential for error obviated by LILCO/ DOE meeting on tence of a thyrold dose change in procedures. Jan. 6,

1987, sample locurrectly reported as 7000 meters instead of 700 meters)

En t r apolated doses Minor and correctable by revi-Procedure now calls for Adequately address the en - otroneously reported as ac-slons in LERO procedures and identification of data upon arcise issue. tual doses on status board, training. receipt at EOC as actual or (EOC-ARCA-6: Entrapolated extrapolated. DOE RAP per-dnso data were reported as sonnel notified of change &ctual measurements on sta-in reporting procedure at tus board) LILCO/ DOE meeting on Jan. 6, 1987. Es Secretary did not de-Irrelevant to training of per-liver telephone message sonnel in radiological proce-promptly to LERO Director dures. F: Communications failures I d,. of ENC, Public Information, cnd Rumor Control personnel G: Failure of RSA person-Id. nel to properly record evsnt inf or mat ion on status board. (RSA-ARCA-Is Time was not always included whsn new information was posted on status board) Poor radio reception Id. at Port Jetterson Staging Area. Bus Dispatcher at Dispatcher's last minute re-LERO Staging Area Manage-Adequately addresssthe ex-PSA made inaccurate an-minders to Bus Drivers were ment Tabletop Drill III-ercise issue. nouncemerets to Bus Drivers not complete, but contained no -(Rev. May, 1986) now S A

'g) [ g {'; j e e -s ~ L

i, (f~

• 4 Y

[$

, k,

, 9e ~ ~ .y z. ~ .) N? ~ x CONTENTION CITED AND STATUS AS SUPPORT FOR Ex 53.t1.. s 'COR*ESPONDING FEMA COMMENT ~ MODIFICATONS IN LERO Y

• TAC.' REVIEW >OF LERO<

PROCEDURES & TRAINING g IFICATIONS-

• ^

- ;q N

)

.( " ~, l\\ 4 .rl. ' , h 's I ~ about dostmetry inaccuracies of important in-emphasizes nsidlfor com-N 'g. " q' (PSA-ARCA-12: Bus Dis-formation. Minor. 1solated plete, precise lastructions. . 7- , ' q! ' .pctcher did not give . instance not indicative of a at all times. e / dosiostry units nor mention pervasive training flaw. O-200 MREM DRD. Bus Driver misdi-Irrelevant to training of per-rected at the BNL transfer sonnel in radiological proce-paint. (PSA-ARCA-93 In-dures. structtons to proceed to . g. '.; a i Csceptton Center were not properly transmitted at SNL tecnsfer point H: Inability to transmit M. correct information about Suttolk County Police De-p2rtment assistance OTHER FEMA COMMENTS CITED STATUS AS SUPPORT OF "X50.H MODIFICATIONS IN LERO RAC REVIEW'OF LERO PROCEDURES & TRAINING MODIFICATIONS EOC-ARCA-12: Some Facts do not implicate a deft-LERO training for Ambu-Adequately address exercise Ambulette Drivers were not ciency in the training of-lance /Ambulette Drivers is issue. cuare of when to take their fared. Problem noted was conducted monthly now to KI caused by high attrition among ensure that new drivers are Ambulance /Ambulette Drivers trained quickly. LERO who had been trained. Re-Classroom Training Program placements had not yet re-materials have been revised ceived training at the time of to emphasize radiological the Esercise. procedures including use of KI.

-s b -_s J ATTACHMENT C i^) O 4 O e O

O ()' U O V U U - O Summary of ARCAs and Deficiencies in Region II Exercises NUMBER NUMBER OF OF NUCLEAR POWER FACILITY EXERCISE DATE ACRAs DEFICIENCIES COMMENTS Indian Point March 3,1982 Total ARCAS and Deficiencies Only " minor" deficiencies at state = 72. level. Deficiencies and significant deficiencies in 3 counties. See Note 1. March 9,1983 Total ARCAs and Deficiencies See Note 1. = S2. August 24,1983 Total ARCAs and Deficiencies See Note 1 =24 November 28,1984 61 2 See Note 2. June 4,1986 68 6 Based on FEMA Summary Table. Oyster Creek March 16,1982 28 8 " Minor" deficiencies tabulated as ARCAs. "Significant" deficiencies tabulated as deficiencies. See also Table 4.1 in 1985 Exercise Report. June 5,1985 48 0 See Note 2. See also Table 4.1 in 1985 Exercise Report. Ginna January 21,1982 Total ARCAs and Deficiencies FEMA made 65 recommendations = 65. See Comment. for improvements without N distinguishing significance. g June 22,1983 35 0 See Note 2. O September 26,1985 24 0 rt a

v 0 t.) D D U J O O ' ~ NUCl.EA R POWER FACil.lTY EXERCISE DATE ACR As DEFICIENCIES COMMENTS J.A. Fitzpatrick August 11,1982 16 3 FEM A listed "significant" deficiencies and " minor" deficiencies. These are assumed to correspond to deficiencies and ARCAs as currently defined. Salem October 23,1983 Total ARCAs and Deficiencies Based on FEMA Table 3.1 in 1984 =28 Post-Exercise Assessment. October 23,1984 59 4 See Note 2. Nine Mile Point September 15,1981 Total ARCAs and Deficiencies FEMA made 32 recommendations and = 32. Three areas identified identified three areas as weak. as weak. September 28,1983 41 0 See Note 2 November 13,1985 17 0 _========================================================================= NOTES TO TAllLE: 1. For the Indian Point Post-Exercise Assessments in 1982 and 1983, FEMA terminology does not allow distinction between - - - -

s. i deficiencies and ARCAs as currently defined. -FEMA's deficiencies are considered analogous to the combined categories of ARCAs and deficiencies as currently defined. 2. FEMA defined its criteria as " deficiencies that would cause a negative finding" and "other deficiencies". This terminology was ~ i assumed to correspond to currently - defined deficiencies and ARCAS. I i j I i l i 4 ) I 1 i I 4 l l ? 1

A) ,3 ' _A ). ATTACHMENT D O ,,.). ) e 0

e o o-o o-o o- .o o. o-o. ~ - o -- i ( i Summary.of Training Citations Shoreham Inden Point O) ster Creek Ginna Fitzpatrick Salem Nine MRe Point I l i i i i i i i i i i /////Hf/////H// l !"Itfs"*" X X X X X X X X X X X X-X X X X X 3 i l coc/cor op-ouon. X X X X X X X X X X X.X X l X X X X X X X X e=6* Ai-tas o-A - ant X X X X X X X X Firu/ Police Procedur X X X X X X X ri.id T om operosion X X X X X X X X X X X X l o centominouen ston X X X X-X X X X X. X X X l X X X X X X X X i,u. og<auon. 24-hour Stoffing X X-X X X X X X n c pu= c at-X X X X-X X X g l xmuuionce oriver/wdicoi X X X X } l

• • a*u==

X X X X i

• Excluding desirnetry training C

T )- ) )- ATTACHMENT E ) r ) ? )

Attachment E ' CRITERIA EQB CRITICAL INCIDENTS / EVENTS / BEHAVIORS / ACTIONS Definition: . Knowledge and/or -action by LERO and other emergency personnel as specified in the FEMA Report - excluding the medical drill, pgs. 84-85. . Observable by FEMA observers. . Knowledge of the objectives of the actions was .. known and apparent to the FEMA observers. . FEMA observers knew the~ consequences (positive or negative) of the outcomes /results. 1. Objective statements are neutral. (e.g., pg. 27 "The objective of demonstrating the ability to receive initial and follow-up emergency notification was met (EOC1).") 2. Recommendation statements are neutral. ( e.g., pg. 30 - LERO should consider whether operations could be improved by additional training stressing the mandatory use of standard message forms and the importance ) of legibility.") 3. Factual statements are neutral. ( e.g., pg. 35 "An evacuation of the entire 10-mile EPZ would require that about eight hundred eight (808) h individuals with special needs be picked up.") 4 Statements regarding OPIPs are neutral. (e.g., pg. 34 "0 PI P 3.3.4, Se c ti on 2.1, requires that sirens be activated in coordination with the EBS system ) subsequent to the declaration of a Site Area Emergency ECL, the declaration of General Emergency ECL, and the decision by the Director of Local Response to initiate or change protective action recommendations.") 5. Procedural statements are neutral. ( e.g., pg. 43 " Field activities dispatched from the LERO l. EOC were evacuation of special facilities by ambulance and ambulette, and school evacuation.") 6. " Compound" sentences with separate actions should be treated ) as multiple (i.e., 2 or more) incidents. ( e.g., pg. 58 - "Each driver was dssued route-specific maps and directionsjat the transfer point, / drove the route l l correctly, andvarrived promptly at the Reception Center.") ) . - ~ _.

B ( e.g. pg. 31 - "The ability to determine the need for State y assistance was demonptrated when requepts were made for v/s i m ul a t e d police,Vroad c l e a r a n c e, Va n d radiological monitoring support perso nn el.") (e.g., pg. 30 "However, when the two

2) free play g

impediment messages were introduced at the LERO EOC, all pertinent information was not transferred from the free play impediment message forms introduced by the exercise controller to the LERO message forms.") (e.g, pg. 31 - "At these times, a secretary ok the calls andfindicatedtothecallerthattheDirectorwouldcall I back.") 7. A single incident evidenced by multiple groups should be counted as multiple incidents. g je.g., p g. 30 and ys)pecial "A 1 the coordinators in the ' t ic, / transportation, facilities areas kept g and generally used LERO message forms.") "Th e VTr a f fi

Control, Traffic Control

( e. g., 35

Point, vacuation Route, and oad Logistics Coordinators 7

each proceeded to determine the procedures required in their respective areas of responsibility.") 8. All duplications (positive or negative) should be counted as they appear in the report. 3 ( e.g., pg. 3 "In addition, the downwind distance of the sample was incorrectly reported as 7000 meters instead of 700 meters for one of the thyroid doses reported by a DOE RAP field monitoring team. This errorXwas caused by a decimal point misplaced during the conversion of the distance units andgmeant that the initial calculation of 3 thyroid dose based on this measurement was 9000 mrem /hr at 4.3 miles downwind instead of 9000 mrem /hr at about 0.5 miles downwind.") 9. Timeliness is credited (positive or negative) only when there is a specific reference or some indication that it was ^) positive or negative. General references to times are considered neutral statements. ( e.g.,

g. 3 5 -

"By 1023, telephone cal.Ls (simulated) were being ade to homebound individuals.") "T h i s)(d e l a y of about forty-f e (45) e (e.g., pg. 37 minutes, although apparently caused by the need to rief the with the timely verification of the fuel truck im)(pediment.") Route Spotter at the Port Jefferson Staging Area, interfered D

D D 10. Ambulance and ambulette

drivers, bus / van

drivers, state / county personnel, and displays and maps are considered to be the same group unless specific separate actions or incidents are noted.

( e.g., pg. 36 - "The dmbulance had been dispatched by about 9 1100 and thevfImbulette by about 1114.")' ( e.g., p g. 33 Moth State and county representatives (simulators) were briefed in the issuance of EBS messages ") B ( e.g., pg. 44 - mbulance and ambulette personnel were issued dosimetry equipment consisting of 0-200 mrem and 0-5 Rem direct-reading dosimeters (DRDs), a thermoluminescent dosimeter (TLD), dose record forms, and simulated potassium iodide tablets (KI).") 3 11. The incidents should be classified on the basis of the FEMA report -- not on the interpretation of what "might" have been meant, or what occurred or may have occurred in addition to what was stated. D D D e e e

6 ) ) ). ATTACHMENT F ) ) 3 3 ') J

Attachment F Summary of Cohesiveness Factors ) - All Facilities C G H Intra-organizational Relationships Role Definition 79 0 1 Authority 17 3 1 Territory 12 0 0 Priority Setting 15 5 4 Normativeness 1 0 0 Legitimacy 2 1 0 1) Communications 27 6 1 -Knowledge 69 15 3 j Intra-and Inter-organizational Flexibility Formalization 1 0 1 Adaptability 5 1 3 D Contre! 0 0 0 Inter-organizational Network Domain 24 0 0 0 Dispute Resolution 0 0 0 Legitimacy of Roles 2 0 0 Resource Adequacy 67 13 4 Autonomy 0 0 0 Communications 25 1 2 Authority 6 0 0 Interaction Clarity 19 3 i Knowledge 28 1 0 ?

R

i j i~I

~ C1 O2 C ~ C -C C E' C 0' O2 C C C C C C C C E - C9 O1 C C C C C C C E C8 O1 E C C7 O1 C U U p U U E C6 O1 C C C C C C C C C C C C C E C5 O1 C C C C E C4 O1 C C C C C E C3 O1 C C C C C C E C C2 C O1 C p U C C p C E C1 O1 C C C C C E C0 O1 C C C C C C E CO9 C C C C C C E C C O8 C C C C C D E C C C C O7 C O C D p C E C C C O6 C E C CO5 U C p C E y C C p O4 E CO3 C C C C C C E CO2 C C C C C C C C y E CO1 C C C C C C C C C E s y L L n lo c r e t A A o y t N g N t O n n O t R a a I o i s RL I u u s l TSi t s n EA n T I f q n C apt t s o TN o y A o o e o NOYt t Z s d i n ZIi e e i I Hn S n y t IITt i I e y A t o N R c ay y i e NSi y y e c ay e TI a l i A a e y ct t t g C ANf t r y w a ct g DALz O~ GK e m c m ii i c d e it d NZIt b l 7 GOe i o t i nt e AIBl a o RRn t i r o nl r a e E RID r t i t t N! a t r OOi u t u n ui o r l OT o i r a t ui t nb l. - Axm p t - wa p i o o nb h e w Ae h r o m u ALl t r i r g mA o AGEr a n RTm s g s t mA t t o u REo u e r o e o n RRLo d o EEo i e e u o u n n g TRR A T P N L C m TOFF A C TND D L R A C A I u N N N I I I l1! (l! i lIlllI' il j l

l lli< > A j ~ ~ .,'-n ,s ,2 CN7 ( C C E CN6 U E i CN5 C C U U E C N4 C C C C E C C C N3 U D D E ~ CN2 E CN1 C C C E s y L L n e t A A o l y 4 N e N t o c r O n n O t R a a I o i s RL I u u s l l f q n C TSi t s n EA n T apt t s o TN o y A o o e o NOY1 t Z s d i n ZIi e e i IHn S n y t IITt i I e y A t o e N R c ay y i NSi y y e c ay e TIa I ANf t r y v a ct e DALr 1 A a e y ct t t e it t c d GK e m c m ii d NZIt b m GOe t o t i l nl e AISl a o RRn t i r o ni r a e C RID r t i t t NI a t r OO1 u t u n ut o r l N OT o i r a t ui I i mb w AXm p t Wa p i o o mb h e w E Ae h r o m ALl t r i r e mA o AGEr a n RTm s g s t mA t t o REo u e r o e o n RRLo d o EEo i e e u o u n n TRR A T p N L C u TOFF A C TND D L R A C A I K N N N I I I ,,lt!\\ !:lIfl lll jl' l1t

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) Attechment G ) RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE 08SERVATIONS AND EVALUATIONS FIELD ACTIVITY MODULE BUS TRANSPORTATION ) OBSERVER DATA Facility: EA7c.t4 M Date: TC6

9. M IL 5pecific Assignment:-

I ffCI M. o Pum7/o.e bVAC,u A71W i Team Leader: 4 /b Name: Organization: 1M Pt L

Title:

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~ FIELD ACTIVITY MODULE BU5 TRANSPORTATION 1 I. Transportation Operations Sat Unsat N/A N/0 ) 1. What was the name of the bus-driver you observed? 2. Name the bus company from which Y the vehicle was picked up. AlW 3. What transfer point did the bus report to? D'k b (h hw H1^q M ( n~ ' W J 4. List the time for each of the lt,*.84, E ' - & following events if observed. u 6 u.4 AcJ.** m. M) )' departure from staging area i V. D arrival at bus yard u '. O departure from bus yard 3 t.' ed arrival at transfer point (u i 'f ) 5. Did the bus driver have the {b required maps or dire::tions to g 'p g M ' l 4.' M provide an efficient route for j 1 trips defined in #47 6. Did the bus driver follow the ) directions? 7. Did the bus drivers have the necessary maps or directions for* the pick-up routes to be run? / ) 8. Were bus drivers able to complete their assigned routes in a timely manner? 9. Did the bus drivers have the correct / ) maps or directions from the transfer / points to the reception center? 10. Did the bus driver follow the correct route and arrive promptly at the relocation center? ) of 008 ) -3

>)- ) RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE CBSERVATIONS AND EVALUATIONS STAGING AREA MODULE ) EMERGENCY OPERATIONS MANAGEMENT ) OBSERVER DATA ) Fac11ity: $4 T&lt*$ M e.Pr*]/ as h et 1//{/4 I Date: [7JJ/94 MW 4 444/ba#/,/v.( djeawhF ) Specific Assignment: M ~t **n,'> J"**1* fg [/f Name: ) IA (24 O Crgani::stion: /*d $4dier Es9/sffer Ti 21e: C 2 I b

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Business Address: ) Business chone: t U01064 )

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y__ 1 IMPORTANT r RADIOLOGICAL JOB RELATED m Read dosimeter every 15 m Obey traffic laws. minutes. m Establishguidanceplan as LOCAL EMERGENCY RESPONSE ORGANIZArloN mll0-200mR Qoesoff scale, detailed in packet. read 0-5R and inform minform evacueestotuneto Ld. Traffic Gde. EBS stationforinformation. m At 3.5R inform Ld. Traffic a Reporttraffic problems to RESTRICTED Gde. Ld. Traffic Gde. m At SR, go to EWDF unless a Consultemergencypacket higher dose is authonzed for more information. by Ld. Traffic Gde. per LERO Director. TRAFFIC GUIDE mif you break oriose your dosimeter, inform Ld. ~ JOB CODE #22B Traific Gde. m Consult dosimetry form for more information. R R

___--_y______ IMPORTANT l RADIOLOGICAL JOB RELATED a Read dosimeter every 15 m Obey traff~c laws. minutes. m ReportstatustoEOCevery a if 0-200mR goes off scale, 15 minutes by radio. toCAL EMERGENCY RESPONSE ORGANIZArioN read 0-SR and inform aIf assigned multiple routes, Evac. Rte. Coord. alternate your routes. m At 3.5R inform Evac. Rte. minform evacuees to tune to RESTRICTED Coord. EBSstationforinformation. m At SR, go to EWDF unless a Report traffic problems to higher dose is authorized EOC by radio. by Evac. Rte. Coord. per a Consultemergencypacket EVACUATION m h'y"u i !'aE"~iese your ' " * " * " " * ^

• d $c"L*'a.infam Evac.

ROUTE SPOTTER ? JOB CODE #24 "$Ya$'*1'Y '"* '" o e

g __g IMPORTANT M RADIOLOGICAL JOB RELATED m Read dosimeter every 15 m Obey traffic laws. minutes. m Road Clearing-wait for LOCAL EMERGENCY RESPONSE ORGANIZAllON mIf 0-2OOmR goes off scale, assignment by radio. read 0-5R and inform a Fuel Trucks-stand by, Road Log. Coord. provide 3 ga! of gas if m At 3.5R inform Road Log. requested. Coord. mInform evacuees totune to a At SR, go to EWDF unless EBSstation forinformation. higher dose is authorized a Report traffic problems by Road Log. Coord. per to EOC by radio. ROAD CREW mEv"o b$awEse your"Fo "2"e'i 73a"iftn" '"*' dosimeter, inform Road JOB CODE #21 'o9 coord-m Consult dosimetry form for more information. l m MM

-I IMPORTANT RADIOLOGICAL JOB RELATED m Read dosimeter every 15 m Obey traffic laws. minutes. m Checkbusforgasandsafe LOCAL E MERGENGY RFSPONSE ORGANIZArloN m lf 0-2OOmR goes off scale, operation. read 0-SR and inform a Use flashers when picking Trans. Pt. Coord. up or discharging m At 3.5R inform Trans. Pt. passengers. RESTRICTED Coord. mInform evacuees to tune to a At SR, go to EWDF unless EBS station forinformation. higher dose is authorized a Report traffic problems to by Trans. Pt. Coord. per Trans. Pt. Coord. BUS DRIVER e E'y"u b fof"mo" e i format on ak or lose your dosimeter, inform Trans. JOB CODE #23 ei. Coord. I m Consult dosimetry form for l more information. 1 .. _.._ l

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l IMPORTANT M RADIOLOGICAL JOB RELATED m Read dosimeter every 15 m Obey traffic laws. minutes-m Call Ld. Traffic Gde. by iOcAL E MERGFNGY RESPONSE ORGANIZATION m lf 0-200mR goes off scale, pay phone before read 0-SR and inform Ld. leaving EPZ. Traffic Gde. by pay phone. minform evacuees to tune to e At 3.5R inform Ld. Traffic EBS station forinformation. STMCTED oee-m Rene,,ireff>c oreeiems te m At SR, go to EWDF unless Ld. Traffic Gde. higher dose is authorized a Listen to EBS station. by Ld. Traffic Gde. per When GeneralEmergency LERO Director. is declared'take ond ROUTE ALERT DRIVER m it you breax or iose your xiianici. dosimeter, inform Ld. m Consult emergencypacket JOB CODE #20 Traff,c Gde. ny pay o one. ,o, mo,e in,0,ma, ion n a Consult dosimetry form for more information.

a V LILCO, March 20,1987 00CMETEP USNBC 4 CERTIFICATE OF SERVICE T1 ImR 23 Pl2:30 In the Matter of (Shoreham Nuclear Power Station, Unit 1)[0 NyCk US AW LONG ISLAND LIGHTING COMPANY E Docket No. 50-322-OL-5 I hereby certify that copies of LILCO's TESTIMONY ON CONTENTION EX 50 were served this date upon the following by hand, as indicated by an asterisk, by Feder-al Express as indicated by two asterisks, or by first-class mail, postage _ prepaid. Atomic Safety and Licensing John H. Frye, III, Chairman *- Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers Oreste Rtr:s Pirfo,' Esq.

• 4350 East-West Hwy.

Edwin J.' Reis,' Esq. Bethesda, MD 20814 U.S. Nuclear Regulatory Commission 7735 Old Georgetown Road Dr. Oscar H. Paris * (to mallroom) Atomic Safety and Licensing Bethesda, MD -20814 Board U.S. Nuclear Regulatory Commission Herbert H. Brown, Esq.

• 1 East-West Towers Lawrence Coe Lanpher, Esq.

4350 East-West Hwy. Karla J.' Letsche, Esq. Bethesda, MD 20814 Kirkpatrick & Lockhart South Lobby - 9th Floor ~ Mr. Frederick J. Shon

• 1800 M Street, N.W.

Atomic Safety and Licensing Washington, D.C. 20036-5891 Board U.S. Nuclear Regulatory Commission Fabian G. Palomino, Esq. ** ~ 1 East-West Towers, Rm. 430 Richard J. Zahnleuter, Esq. -4350 East-West Hwy. Special Counsel to the Governor Bethesda, MD 20814 Executive Chamber Room 229 Secretary of the Commission State Capitol Attention Docketing and Service Albany, New York 12224 Section - U.S. Nuclear Regulatory Ccmmission Mary Gundrum, Esq. 1717 H Street, N.W. Assistant Attorney General Washington, D.C. 20555 120 Broadway Third Floor, Room 3-116 Atomic Safety and Licensing New York, New York 10271 Appeal Board Panel U.S. Nuclear Regulatory Commission L Washington, D.C. 20555 1 l - _. _.--..~.-_ _ _ -__-__. _ __ _. _ _.. _,. _. _ _ _ _.. _ - _ - _ _ _. _ _ _... _ _

__ I; - Ms. Nora Bredes - Spence W. Perry, Esq.

• William R. Cumming, Esq.

Executive Coordinator. Federal Emergency Management Shoreham Opponents' Coalition 195 East Main Street Agency 500 C Street, S.W., Room 840 Smithtown, New York 11787 Washington, D.C. 20472 - Gerald C. Crotty, Esq. Counsel to the Governor. Mr. Jay Dunkleberger New York State Energy Office Executive Chamber Agency Building 2 ' State Capitol Empire State Plaza - Albany, New York 12224 Albany, New York 12223 Martin Bradley Ashare, Esq. Stephen B. Latham, Esq. ** Eugene R. Kelly, Esq. Suffolk County Attorney Twomey, Latham & Shea _ H. Lee Dennison Building . 33 West Second Street. Veterans Memorial Highway P.O. Box 298 Hauppauge, New York 11787 Riverhead, New York 11901 Dr. Monroe Schneider Mr. Philip McIntire . Federal Emergency Management North Shore Committee P.O. Box 231 Agency Wading River, NY 11792 26 Federal Plaza New York, New York 10278 Jonathan D. Feinberg, Esq. New York State Department of - Public Service, Staff Counsel Three Rockefeller Plaza Albany, New York 12223 ) Y '$4L.- essine A. Monaghan / / Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 I l -DATED: March 20,1987 i r, r-, ,--,-a- --,,.,--w,m- ,~ ,e, ,--.,w,---, --a--,.--,-n,-,-.---w-~,-

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