ML20210B864
| ML20210B864 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/27/1987 |
| From: | Husar I Federal Emergency Management Agency |
| To: | |
| References | |
| CON-#287-3351 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8705060033 | |
| Download: ML20210B864 (145) | |
Text
{{#Wiki_filter:335I B a m c a u 9. 2 E W.- % 'IRAXSCluP1l_<c O NR OF PRDCEKD(, MS3:,e UNITED STATES OF AMERTRA'CE C-i',- r.A NUCLEAR REGULATORY COMMISSION;F t.n:a.. < !'1 00ChE;iN.' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD - - - - - - - - - - - - - - - - - - -x In the Matter of: Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY (EP Exercise) (Shoreham Nuclear Power Station, (ASLBP No. 86-533-01-OL) Unit 1) - - - - - - - - - - - - - - - - - - -x DEPOSITION OF IHOR W. HUSAR New York, New York Tuesday, January 27, 1987 ACE-FEDERAL REPORTERS, INC. Stenottav Rqvrters 444 North Capitol Street {d Washington, D.C. 20001 g (202) 347-3700 Nationwide Coverage 800-336-6646 8705060033 970127 PDR ADOCK 05000322 PDR
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In the~ Matter of: 6 LONG ISLAND LIGHTING COMPANY
- Docket No. 50'322-OL-5 (EP Exercise) 7 (Sho~reham Nuclear Pouer. Station, Unit 1)
- (ASLBP No. 86-533-01-OL)
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9 DEPOSITION OF IHOR U. HUSAR 4 New York City, New York to Tuesday, January-27,:1987 ~ 11 (^2 \\ Deposition ~of IHOR W.,HUSAR, called for examination b 12 13 pursuant to notice', at the~ Federal Emergency Management 14 Agency, Room 1337, 26 Federal Plaza, New York, New York 10278, at 2:05 p.m.,'before Garrett J..Walsh, Jr., a Notary Public. 15 in and for the Commonwealth of Virginia at Large, when were 16 present on beha'1f_of the res'pectivefparties': 17 18 P. MATTHEW SUTKO, ESQ. CHRISTOPHER M. McMURRAY..ESQ. 19 Kirkpatrick~& Lockhart 1800.M Street, N. W. 20 South Lobby,.9th Floor Washington,.D. C. 20036-5891 On Behalf of the Intervenor, the County of 21 Suffolk, State of New York 22 0) l s~
J 2 -s (L 1 APPEARANCES: (Continuing). .2 RICHARD J.'ZAHNLEUTER,-ESQ. Deputy Sp'ecia1. Counsel'to th~e'. Governor. ~' .3 Capitol,.Ro'om'229 Albany,.New York-12224 4 ' On Behalf ~of the Interven'or, the' ~ State of ~ New York 5 BERNARD BORDENICK, ESQ.. Officefof Gen'eral Counsel-o U. S.,Nucl~ ear Regulatory Commission . ashington',.D. C.-20555 W 7 8 STEPHEN MILLER, ESQ. Hunton & Williams' 9 707 East. Main Street P. O. Box 1535 to Richmond, Virginia 23212-On Behalf of the~ ~ Applicant, the' Long Island Lighting ~ i 11 Company
- V(' N WILLIAM R..CUMliING, ESQ.
12 Federal ~ Emergency'.M nagement Agency 13 500 C Street,.S..W. ~ ~ Washington,'D. C. 20472 ~ l 14 On Behalf of FEMA ^' 15 16 17 18 19 20 21 22 l e. c.v .r ,_-.,..--,.p, ,~#z. - ~, _..,y,
'3 i3 > ;Q- .-1 C 0 N T E.N T S 2 Ihor-W. Husar a Examination by Mr. Zahnleuter. Page 4 Examination by Mr. McMurray-Page 94 4
- Examination by'Mr.' Miller-Page 103 Examination by Mr. Cumming
.Page 108 5 6 7 8 E E-E 1 E 1 T_ g-9 FOR IDENTIFICATION. 10 11 Husar Deposition Exhibit Number 1 Page 37 O 12 Husar Deposition Exhibit Number 2 Page 48f 13 14 '15 16 17 18. 19 20 21 22 O
4 /m 1 P_ R_ O g E_ E D I N g 1 2 Whereupon, IHOR W. HUSAR 3 was called as a witness and, having first been duly sworn, 4 was ex'amined and testified as follows': 5 DIRECT EXAMINATION 6 BY MR. ZAHNLEUTER: 7 8 Q Mr. Husar, my name'is Richa~rd Zahleuter. I 9 represent the' State of New York and I am one of the Inter-venors in this procee' ding. I am heYe to ask you a few 10 it questions. O And, if my questions are vague'or you don't under-12 stand them, please 'tell~ me and I will try to straighten them 13 14 out for you. I don't believe that I've ever' been provided with 15 a resume of your background, so could you please tell me 16 when it was that you first became' associated with FEMA? ~ 17 18 A Okay. I was associated with FEMA from the' out-in 1979 when FEMA was formed, based on Executive Order 19
- set, I came from one in July of 1979 signed by Presiden't Carter.
20 of the five predecessor agencies of FEMA, the Defense Civil 21 22 Preparedness Agency. n ]
5 (v3 i Q What'were your duties at the' Defense Civil Pre-2 'paredness Agency just prior to becoming -- prior to joining 3 with FEMA? 4 A My maj or area of involvem'eht was providing assis-S tanceto state'and l'ocal governments with. respect to prepared-6 ness'for emer'gencies' and in particular those' emergencies chat 7-are funded and stipulated in defense, the' Civil' Defense Act 8-of 1950, primarily.whi'ch ha's to do with nuclear attach 9 preparedness. 10 Q And what was your first job with ' FEMA? 11 A My first ' job with. FEMA ~ was performing 'that same O w ~ % c )M a -+ I 12 function. I e6 one.'of the program officers related uv defense'preparednes's as part of governmental prep ~aredness 13 14 in the Agency. 15 Q Okay. And did there 'come a time 'whe~n your j ob 16 des'cription changed with FEMA? 17 A Yes'.~ 18 Q When was that? 19 A Very late'in 1979. My recollection is not clear. I was appointed by the'then Regional Director of FEMA to 20 21 be the Chairman of the Regional Assista' ce Committee. n 22 Q And how long did you keep your chairmanship? l ( 1
6 i k). 1 A
- My rec ~ollec' tion is that :I kept tha't chai'rmanship 2
until about Nov' ember of'1982. 3 Q. And thsn in 1982 what did your job' consist of? 4 'A I bec'ame 'the' ~ Branch' 'Chfef i of the' ' National. Pre-5 paredness Programs.and FEMA ~ Region II. 6 Q Could you explain what that medns, a. Branch Chief? ~ 7 A Sure.. In a FEMA regional office,.thdr'e "are j 8 program divisions. ~And ths next level, organizational level, 'And, I was a Branch Chfef h 9 -below a division ~a branchss. 10 in one~of the~ program offices'. 11 Q What program office was that? .I\\- - 12 A This is the ~Emergen~cy Management and National 13 . Prep ~aredness Programs Division. 14 Q Did that position have any duties with' respect 15 to nuclear attack? 16 A No. 17 Q Did it have'any -- j 18 A Well, let. me 'take that back and let me 'say, it has to do with nuclear attack but not on the'part of state 19 i and local governments and their prep'aredness, per se. It 20 had to do with ' continuity of government which is ensuring -- 21 one of my duties was -- and one of ths functions actually of 22 -.,r--, ,--,,,,-w--,. - -,.,
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~ 7 dtg 1 the branch'is to ensure'that-theTdifferent federal agencies 2-in our regional' ares, okay, have' plans and hsve'the' capability a to deal with ' emergency functions in 'accordance ~with an 4 Executive Order, Ex'ec~utive-Order 11450-.11490,.excuseme.jp,pr s It has to do.with agency-responsibilities' in' times of 6 national emergencies'. 7 So,, from that sense, to deal -with nu~ clear. attack 8 issues', yes.' 9 Q Okay. 10 A To deal with' nuclear attack ~preparednes's, yes, 11 but not specifically having to do with ~the ' state 'and local O' ' 12 governments. 13 Q Was there'anything else that you did in that i 14 job? 15 A Yes. 'The entire' area of the' national prep ~aredness 16 programs is thr'ee' fold: The cantinuity of the government, 17 which is the~ survivability of the federal establishment.to sustain a nuclear attack; it has to do also with industrial la preparedness, having to do basically with 'the economy being 19 able'to gear up for a national emergency, whether it's a 20 100 percent call-up of the ' services' and also having to do 21 with the specific subject of mobilization preparedness. 22 () 4
f-8 1 pG. 1 The'~ federal civil' establishment being able to 2 support a wartime lecon'omy;:. 3 Q Do you'have~any education b1-emergency planning? 4 A I don't understand'your question. 5 Q-What kind.of~ course-work did you' study'while'you: 6 were.in'colleg'e? ~ 7 A .Okay. My ' academic training is in sec'ondary educa-8 tion. So, as far as my baccalaureate degree, no, I did not ~ take ~any specific courses having to do with ' emergency ~ plan-9 10 ning. 11 Q Okay. Did you take'any post-graduate' training? O' 12 A My post-graduate work was in business.
- However, my experience 'and training having to do with ' planning,comes la from the military, my service in the Armed Forces', Land 14 15 subsequent to that, and other agenci'es I ha've worked for 16 prior to FEMA.
i 17 Q You'are not Branch Chief now, are you? l 18 A No. i 19 Q When did you change your position? 20 A In June, approximately June 22nd of 1986, my l 21 official reassignment was effec ~tive. 22 Q And what rea'ssignment was that? O
~ 2 9 (") v 1 -A _To.become ths Su'pervisory Natural and Technological 2 Hazards Program'Sp'ecihlist. 3 Q lCould you' exp. lain' whst thdt job ~ consisted 'of? - ~ 4 A Yes'. :Thi~s:is a super ~visory p'osition in the 5 -Natural and Technological Hazards Division, whereinfI am' 6 res'ponsibleIfor ths' day-to-d6y supervision of two-broad 7 program areds.of our work thdt we'do in that particular 8 division, one being the; National Flood Insurance ' Program 9 which'is on ths natural side'which'also has to deal with: 1 10 -flood' activities ~, it his to do with ' flood insurance sdministra 11 tion, it.has to do.with ' flood -plain management, :it.has to do h' with damf safety, hurricane -preparednes's and hazardg' material.}g@g ~ o45 12 13 And on a techn'ological hazards side, hdving to~ dowith'technologicalaspectsofhazar[ materia _1and. gg 14 radiological. emergency. prep'arednes~s which ' includes not only 15 16 commercial nuclear power ~ plant planning but also having to i do with regional response and coordination response ' planning ~ l 17 l for any kind of radiological ace'idents, for' instance. l 18 19 Q And you'still currently hold.that position? 20 A And I _ currently hold thdt p'osition. L i 21 Q Now, other thin Sho'reham, is thsre anything in your background that concerns nuclear power plants -in New 22 i (:) i i 1 k
10. O V 1 York State? 2-A Sure. 3 Q' Okay. 'Whatstime -- or,.whe'n' did,that 6ccur? 4 A Well, during ths~ time ~ frame'where'I was the 5 Chairman of the' Reg'ional Assistance C6mmittee'~the'first 6 time, I was involved with' reviewing plans as well as seeing 7 to it. that exe'rci~ses are held regarding the ~ implementation ~ 8 of ' those ' plans _ for~ Ginna, Nine Mile Point. ~My recollection 9 is not clear now~ whethe'r' that also included Indian Point. 10 It may have. Certainly, a review of plans but,1 don't remember 11 V 12 now whether or not it included an exercise at Indian Point. 13 Q Was NUREG 0654'in effect'whe~n you did this? 14 A Yes. 15 ~Q Did you have'any past hi' story to use'in your position as RAC Chairman or did -- were~you the first RAC ~ 16 17-Chairman? 18 A At Region II, yes. ID Q Did you create'the Radiological Preparedness ~ 20 Program yourself? 21 A You flatter' me. ~No. ~No, it was created by the Agency, and in each ' region we had an intensive ~ training 22 O
11 LJ 1 course for all those that would occupy that position. That 2 was conducted by the ' Age'ncy' in concert with 'the' ~ Nuclear 3 Regulatory Commission. 4 And from that point on, everybody had the same ~ 5 level of basic knowledge with respec't to our program re-6 sponsibilitieS~ and the process of off-site prep'aredness. 7 Q What standards did you use~to review the' plans 8 that you mentioned before? 9 A NUREG 0654, FEMA, Rev l. 10 Q Did you have ~anything to do with the ' development 11 of NUREG 06547 f', \\/ 12 A-No. No, I did not. 13 Q And -- 14 A That was basically handed to us as part of the is training process. 16 Q I assume tha~t you worked with the state and local governmen~ts-in your position as RAC Chairman? 17 18 A Oh, sure. 19 Q Do you recall which local governments? 20 A Oh,.sure. With respect to the' Radiological Emergency Off-Site Preparedness Program for the nuclear 21 22 power plant, part of our program responsibilities, okay, we ('; \\/
I 12 i worked with -- at that time it was called -- the' ~ predecessor 2 organization which 'is now REPG, Radiological Emergency ~ W6 3 Preparedness Group, has a predec'essor name whi<h name QF escapes me which wa's he'aded up by a gen'tleman by the'name of 4 Mr. Davidoff, Donald Davidoff, and he~ was the individual 5 and that fi organization that I had dealt with in the jpk e 7 State 'of New York 'in dealing with the ' nuclear power plant 8 off-site preparednes's matters. 9 Q Can you tell me how many exercises you attended ~ to in that period? 11 A I would say about four. i 12 Q Can you list them for me? 13 A Salem, Nine Mile Point, ~ My recollection is 14 Ginna and Oyster Cree ~k. ~ It may have also included Indian Point but again is my recollection is a little fuzzy. 16 17 Q Can you briefly give me'a synopsis of what your job duties consisted of at the exercises in New York State? 18 19 A They would be no different than with any other 20 nuclear power plant site. The job of Chairman of the Regional Assistance Committee, which'is the external title 21 22 for that function -- the way I will treat it because it ,7 I )
13 .. p d' 't involves' two related but really distinctive responsibilities.- 2 _My program responsibilities' for'o.ff-site preparedness'for 3 nuclear power plants internally incl ~udes having a staff that 4 works for me.whd.have.~ program responsibilities.for various -- 5 for a specific ' site. b 6 And so with'a staff to assist in internal plan 7 review and the' internal preparation of FEMA to be able to 8 evaluate the'impl'ementation of the' plan based on the 9 scenario was-done internally. And it. is my job' as -- at to that time it was another title -- as far as being responsible-11 for a staff to do the' internal FEMA work.withirespect to >,, O 12 fielding an evaluation team, a federal evaluation team, to 13 evaluate an exercise. 14 That responsibility comes with the title 'of ~ -15 Chairman of the' Regional Assistance ' Committee whfch 'is part d 16 of 44 CFR 0. 17 And there is a whole list of responsibilities 18 the RAC Chair has. 'One of them is to ensure that the off-site plans for a site, state'and local plans..for,a site, are 19 20 tested biannually.- And there is a whole list of things that 21 we do in order to (a) get our evaluator team ready and (b) 22 have'a scenario, an approved scenario, so that we know what O
14 we 'are evaluating, conducting the ' exercise ~and performing the t 2 evaluations and then after ths ' exer'cise ~is over~ putting 3 together a rep ~ ort on'ths' exercise.~'That is the~ process as 4 it relates to exercise. 5 Q Do you rec'all giving testimony at the ' Indian Point e licensing hea' rings? 7 A Yes, I do. 8 Q Was thdt in between 1979 and '82 while you were~a 9 RAC Chairman? 10 A Yes, it was. 11 Q What was the' subject of~that testimony? O 12 A It had to do with -- what prompted the' Atomic l/ Safety and Licensing Board h' earings were ' exercise ' deficiencies 13 14 that had occurred at Indian Point. The Nuclear Regulatory Commission, under their authority, invoked some sanctions 15 16 against the~ licensee,. gave them 120 days to show~cause why ~ the plant should not be shut down. 17 18 Q Were you asked to testify or were you subpoenaed? 19 A Yes, I was asked. 20 Q You were asked? Can you describe what your 21 testimony consisted of? 22 A The testimony was given' by a panel. The three of CO x>
15 '%_ l 1 us testified based on our expertise before the~ Atomic Safety 2 and Licensing. Board on a number of issues that had to do with 3 off-site preparednes's, with'the' adequacy of evacuation plans, 4 adequacy' of radiological monitoring and asses'sment. 5 My recollection is not that clear beyond those 6 words. 7 Q Do you have ~any more specific recollection? 8 A No. 9 MR. CUMMING: Counsel objects to this line of to questioning based on the' relevance. However, obviously the subject of the testimony is in the~ public record. It is 11 th 12 available to all parties. 13 However, to the extent the witness has memory he ~ may continue to answer with respect to this line of question-14 15 ing. 16 BY MR. ZAHNLEUTER: (Continuing) 17 Q I take 'it you don' t recall in any more specific ' 18 detail what your testimony -- 19 A No. I would have to refresh my memory by looking 20 at the record. 21 Q Okay. 22 A We had filed testimony prior to the ASLB and it ^/ \\ L)
16 (U I was transcripts of that ASLB, and my recollec' tion is not clear 2 on the' 'specificL, matters at issue 'that. we discussed. 3 Q Did you~ talk to anyone in preparation for your 4 deposition today? 5 A Yes',.I did. 6 Q Who is that? 7 A I talked to counsel. 8 Q Mr. Cumming? 8 A Mr. Cumming, and also talked to contractor person-I8 nel of FEMA tha't have been involved with our support, FEMA 11 support for an evaluation of plans - and other support services O 12 with respect to off-site radiological emergency preparedness. I3 Q Who is that contractor personnel? 14 MR. CUMMING: Witness may answer to the extent I5 he has memory. Is THE WITNESS: Okay. Dr. Thomas Baldwin of II the Argonne National Laboratory and Mr. Joseph Keller, Idaho I8 Nuclear Engineering Laboratory. BY MR. ZAHNLEUTER: (Continuing) 20 Q When did these conversations occur? 21 A Off and on for a good several weeks and also today. 22 Q Was Mr. Cumming present during those conversations? O
17-r~x. ,) 1 A Not in all cases, no. 2 Q When was -- 3 A Excuse me. And also Mr. Roger Kowieski, and also 4 my boss. 5 Q Who is your boss? 6 A Mr. Philip McIntire. 7 Q Could you specify when the first conversation 8 occurred between any one of those people? 9 MR. CUMMING: To the extent the witness has 10 knowledge, he may testify. 11 THE WITNESS: It's hard for me to sort out when O kl 12 my conversations stopped with respect to plan review issues 13 as they relate to that site, the LERO plan, and when the 14 discussion with respect to preparing for this deposition 15 began. 16 So, it's hard for me to say when one stopped and 17 the other one began. It runs together. 18 BY MR. ZAHNLEUTER: (Continuing) 19 Q Did you ever have a telephone conversation regard-ing preparation for this deposition with, for example, Dr. 20 21 Baldwin? 22 A Sure. O
18 (~b 1 J-1 Q Can you recall what you discussed?. l 2 A We discussed those matters that were related to Revision 7 and 8, that needed to be sorted out that weren't 3 specifically tied into problem areas that came out during 4 5 the exercise, because there were certain plan deficiencies 6 that were revealed in the post-exercise report that were not deficiencies and the plan reviews prior to the exercise. 7 8 So, I needed to sort that out in my mind which of those problem areas that were presented in our report, 9 10 comments on review of the plan that were pure plan matters as opposed to exercise-prompted plan matters that needed 11 (,) 12 improvement or correction. 13 Q Why did you feel that you needed to sort that 14 out before your deposition? 15 MR. CUMMING: I would like to state a continuing 16 objection to the record. I would like to pass out at this time a copy of the January 14th, 1987 OL-3 Order which I 17 18 would like bound with the witnesses transcript, furnishing a copy to all counsel. H' Discovery has been opened by the OL-3 Board on 20 reopened Contention 24. The Federal Emergency Management 21 Agency, since the conference of. counsel on December 6th, 1986 22 OV
O I st ? 19 ('v) i -has stated for the record that it is uncertain as to' the ~ 2 relevance of the Revision 7 and 8 of the LILCO plan and a the'RAC review of that plan to the'OL-5 proceeding. LHowever,- 4 while it does not waive any privilege with respect to either 5-deliberative process or any.other appropriate' privilege, e it has consented to: allow Mr. Husar to testifynbased on the 7 review, as RAC Chairman, of Revision 7 and 8. 8 And it believes that this is counsel's opportunity 9 to ask whatever questions l are appropriate reference 7 and 8,. to and that this' discovery and this deposition is for the.pur-11 poses of both Boards, and it_ does not intend to reproduce C' 12 for any party Mr. Husar to testify on Revision 7 and 8. 13 Counsel will also state for the record that 14 originally Mr. Husar was a designated witness and was with-15 drawn in the conference of counsel on -- it was either the 16 . December 6th or the January 6th conference of counsel, an ~17 a designated witness for the OL-5 proceeding. 18 With that in mind, to the extent possible, the 19 witness is instructed to answer questions as fully as possible with respect to his review and the Agency's review 20 21 of Revision 7 and 8. And that is a continuing objection 22 with respect -- on both relevancy and with respect to the o I i
20 (^3- ~ t fact that if it-is assumed to be relevant to the OL-3 proceed-2 ing that this is, in fact, counsel's opportunity, counsel 3 for all parties, to question the witness for the purposes 4 of that proceeding. 5 With that in mind, the witness, if he. remembers, 6 may answer counsel for New York State's question. And I 7 should state that although he was subpoenaed and I thought 8 that the counsel for Suffolk County was going to question 9 the witness, counsel for FEMA has no objection to the counsel to for the State of New York questioning the witness, 11 MR. ZAHNLEUTER: Before you answer, Mr. Husar, ,O kJ 12 Mr. Cumming, let me state that my question was what Mr. Husar 13 did in preparation for this deposition. It had nothing to 14 do with any matters that might be the topic of the OL-3 15 proceeding. 16 MR. CUMMING: I believe counsel is in error. 17 That was not counsel's question. If he would like to request 18 the reporter to read back, for the record, his most recent 19 question to witness he may do so. 20 But it is counsel for FEMA's understanding that 21 that was not the question that counsel for the State of New 22 York just asked. s
y 21 1 MR. ZAHNLEUTER: Uell, I will ask the question agai-1, 2 but I really intended to probe conversations relating-to 3 preparation for this deposition. -That will turn out to be-4 the question. 5 But for now, I would also like to say that I 6 cannot agree with your categorization that this'is the 7 State's opportunity to seek discovery under OL-3 and the 1 8 State of New York does reserve its right to subsequently de-9 pose Mr. Husar in the OL-3 proceeding. 10 MR. McMURRAY: Let me also speak for the County 11. on.that issue. As I said this morning, Mr. Cumming, this O 12 witness was subpoenaed fe,r the OL-5 proceeding. We are 13 here today to disc.uss all mattet.s relevant to the OL-5 14 proceeding. 15 Let me just say for myscif that I have not pre-pared questions or prepared to ask questions that would get 16 17 deeply into the subject of the OL-3 proceeding. And we 18 reserve our right to call this witness back in the event 19 that he is going to be designated as a witness or has 20 knowledge pertinent to the OL-3 proceeding. 21 MR. CUMMING: Let me state for the record that 22 counsel for Suffolk is incorrect. This witness was not O
22 ~) (U 1 subpoenaed. He is being produced voluntarily by the Agency 2 at this deposition. 3 To the extent our positions have been made clear 4 on the record, they have been very clear, maybe we can 5 proceed. 6 BY MR. ZAHNLEUTER: (Continuing) 7 Q Okay. Mr. Husar, I think the question was, with 8 regard to a conversation that you had with Dr. Baldwin in 4 9 preparation for this deposition, why did you feel that it was to necessary to discuss the matters that had been rated as 11 deficiencies in the post-exercise assessment that may not
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12 have been deficiencies previously? 13 A I needed to, in my own mind, sort out those 14 matters that were prompted, those plan review changes that is were prompted, by exercise deficiencies as opposed to those matters that were prompted by previous RAC comments on the 16 17 plan. 18 Q Did you feel that you were able to sort those to out? 20 A Pretty much. 21 Q Were there other conversations with Dr. Baldwin 22 in preparation for this deposition? O
23 1 A I can't recall. 2 Q How about Mr. Keller? 3 A With Mr. Keller, discussions in particular re-4 lated to matters that I needed to have clarified for me with 5 respect toradiologicalmonitoringwhichisMr.Keller'sato(th pd % cl40f P h expertise as one who has a background of -health-physics, gy 6 7 someone that could answer my questions with respect to those 8 matters. 9 MR. CUMMING: I should state for the record that 10 Mr. Keller and Dr. Baldwin are going to be deposed the rest of this week and they also will be available to answer 11 12 questions with respect to Revisions 7 and 8. 13 BY MR. ZAHNLEUTER: (Continuing) 14 Q Could you please specify what matters concerning 15 radiological monitoring you needed to discuss? 16 A I varited to have us revisit the subject of what we did during the plan review meeting and the specific nature 17 of the inadequacies that we found in the plan with respect la 19 to radiological monitoring issues. 20 Q I take it there was a plan review meeting. Could you tell me when that was? 21 22 A We had a plan consolidation meeting, plan review s
4 24 .q '~# 1 consolidation meeting, on November 25th, 1986. 2 Q Okay. Mr. Husar, I see that you are reading from some notes there. Could you tell me what you brought to the 3 4 deposition today in the way of documents? A Sure. On yellow pieces of paper are my own per-5 6 sonal notes in preparation for this deposition. The hand-7 written notes to myself regarding that day's consolidation -- P an review consolidation meeting. A copy of the RAC plan l 8 9 review comments for Revision 7 and 8. A copy of the 10 Regional Director's transmittal of those comments to our National Office. And copies of correspondence requesting 11 r~h kJ from the Nuclear Regulatory Commission -- asking for a review 12 13 of Revision 7 and 8, and a subsequent transmittal of that 14 asking from the National Office to the Regional Office. And, lastly a transmittal of the finalized plan 15 review comments to the members of the Regional Assistance 16 17 Committee that were a party to the plan review itself. 18 MR. CUMMING: Several of those documents, including 19 the January 5th, 1987 transmittal from Mr. Husar to the RAC, the 19 December '86 transmittal from Norm Steinlauf to 20 Dave McLoughlin, and the RAC review and an October 22nd, 21 22 1986 memo from Mr. Husar to the RAC, I am furnishing to O
^ / \\ 25 h I counsel at-this time. If you would like.to go off the 2 record for a few minutes-and study-that, that's fine. We s 3 have no objection. 4 And also we have no objection ;to producing Mr. 5 Husar's file at the close of the deposition. He has 6 basically stated' accurately that it is material that he has 7 prepared for the purposes of the deposition. FEMA is not 8 asserting deliberative process privilege over it, because it 9 does not feel with the RAC review it deals with his prepara-10 tion for this. 11 There is one other document which is the attendance O 12 list of the RAC which, when we go off the record, I will 13 have copied and furnished to you before we go bach on. 14 You may have a few minutes to study the documents. 15 MR. ZAHNLEUTER: Mr. Cumming, is the file that you 16 refer to the one that Mr. Husar has in front of him now? 17 MR. CUMMING: That's correct. 18 MR. ZAHNLEUTER: And your offer is to provide i 18 the documents that are in the file with some of the exceptions l 20 that you mentioned after the deposition? 21 MR. CUMMING: I will be happy to allow you to l inspect the file. We have not had an opportunity, since Mr. 22 . ()
L i 0 26 ^ 1 t-Husar has prepared it for the deposition even as late 'as ~ this ~ 2-morning,.to copy it. If you would like to inspect it, if 3 there -is something you would like to have while we are off 4 the record, or if you would'like'to wait to have us copy the s . entire file counsel has no objection. 6 There is one document, however, that'Mr. Husar 7 incorrectly stated he brought.with him. .He, in fact, had 8 turned it over to me. It is, in fact, a letter of January 9 20th, 1987 from the Nuclear Regulatory Commission to Mr. 10 Norman Steinlauf which I have provided to Mr. Bordenick 11 this morning, and Mr. Bordenick will have to make a decision 12 as to whether he wants that document released. 13 Otherwise, as I stated on the record this morning, 14 with respect to the actual RAC review of Revision 7 and 8, t l 15 counsel for FEMA is compiling a complete index to all docu- !~ 16 ments generated during that review not furnished here or i j previously to counsel for the Intervenors, and we will provide 17 f. 18 that as soon as it is prepared to all witnesses. 19 And assuming there is a request in accordance with f NRC's procedures for any or all of those documents, we will 20 I treat it with expedition and provide as much as we can, that 21 1 22 we do not wish to assert privilege over, and we will be happy llO !j.
27 /'N. C/ 1 to furnish that which we are not asserting privilege over 2 to all counsel of record. 3 THE WITNESS: I misspoke. Two other documents 4 that are here sort of got buried. I also have a copy of 5 the RAC comments regarding Revision 5 and also a complete reprint of the FEMA Operative Guidance Memoranda. 6 7 MR. ZAHNLEUTER: Mr. Cumming, I would like to accept your offer to look at the documents that you handed a 9 out, those memoranda that you refer to. I would also like to take a ten minute break to to read those documents and to persue Mr. Husar's file. 11 O' 12 MR. CUMMING: I have no objection if all counsel wishes to initial the documents.n Mr. Husar's file so that 13 when I provide you the initialed copies back, you will under-14 is stand that I did, in fact, give you everything that Mr. Husar 16 brought with him. 17 with that, we will go off the record. la (O f f-the-record. ) 19 MR. CUMMING: I will state while we are back on the record that copies of everything that is in this docu-20 21 ment dated November 13, 1986 has been served on all parties to this proceeding, although not in this format.
- Counsel, 22 O
1 i -.---__m. m y r
28 ,e~, _J 1 some time in the near future, would like to copy this format. + 2 I will have to furnish. 3 MR. ZAHNLEUTER: Mr. Cumming, that's the Guidance 4 Memoranda? 5 MR. CUMMING: That's correct. 6 MR. ZAHNLEUTER: Mr. Cumming, during the short 7 break we had, I have reviewed the file that Mr. Husar brought 8 with him. And I would like to request a copy of that file, 9 including the documents that are not his own individual notes 10 because I see there are notes that he has put on those docu-11 ments. 12 There is approximately two inches of paper, some 13 papers containing penciled notes, some papers containing 14 yellow sheets with numerous notes. And I haven't been able 15 to review them all to a satisfactory depth. And I would like 16 to request copies of those papers. 17 And it will be necessary to keep this deposition open. It may be necessary to recall Mr. Ilusar pending a 18 19 complete and comprehensive review of that file. 20 MR. CUMMING: Counsel for FEMA understands your 21 request. Counsel for FEMA has stated its position, but also I l counsel will furnish as requested a copy of the file to the 22 ( l l L
a 6 .s-cit a 29 .g -Q 1
- attorneys who are here'todayTpersonally~and'they can do q
2 with' chem what they want. 3 I should state on-the' record that FEMA understood-
- ' ' 3 originally the. purpose of this deposition to concern the 4
5 OL-5 proceeding and that Mr. ~ Husar'would be asked questions e concerning his involvement in the exercise. 7 MR. McMURRARY: Let me just state for the record ~ -8 that this deposition does deal with OL-5, and Mr. Husar has 9 stated on the record that there.are certain: changes in the' plan that are directly.related to deficiencies in the exerci'se ;. to 11 therefore, his.own testimony shows that the inquiries that O 12 Mr. Zahnleuter is making are ' perfectly relevant. 13 MR. CUMMING: Witness is not competent to answer with respect to the-legal implication.as to his understanding. 14 15 He is very competent to answer; and he has, in fact, so 16 testified. 17 I think the record is clear. Let's proceed. 18 MR. ZAHNLEUTER: Let me state for the record that I am conducting a deposition in the OL-5 proceeding. And 19 I. don't think I've actually ever brought'up the OL-3 proceed-20 cnd TlA 21 ing. 22 O' t
t 30 .,y N) i 1 BY MR. ZAHNLEUTER:
- (Continuing) 2 Q
I would like'to return.to a point before we took 3 the break where.you said you discussed with Mr. Baldwin 4 ' changes in the plan that related to deficiencies that were 5 observed during the' exercise. 6 Could you-list for me what changes those are? 7 A I think you misunderstood what I have said earlier 8 on. I had conversations with Dr. Baldwin with respect to 9 those matters in the plan review and the RAC evaluation of Revision 7 and 8 that may have been prompted'by exercise to 11 shortcomings that were reflected in the report.- 0 12 Q What were those matters? 13 A I did not discuss specific matters with him. We 14 basically talked generically.about reception, congregate 15 care issues. We talked about facility arrangements. He 16 talked about - ~.to refresh my memory -- status of agreements 17 that are plan related. 18 I, for myself, and over the week-end made a listing, and it's reflected in my notes, a correlation or an 19 analysis of plan deficiencies that existed at the time or as 20 a result of review of Revision 5 as compared to the plan 21 inadequacies -- I misspoke when I said deficiencies, 22 O y , _.--- -- +- -.m .,.,7- ,,e--e w.*,* r r-e m--+ e* - < - + t
~ 31 3 gs - \\j,. 1 inadequacies in the planc.that.were a. result of-the RAC review 2 of Revision 8.. I would like to point out 'thbt our plan - review 3 4 of Revision 7 and 8 also included review of Revision 6. And 5 that is so stated in writing in the transmittal of Revision 6 7 and 8 to our National office. 7 Q You are referring now to your notes in your file; 8 isn't that correct? 9 A That's cor' rect. 10 Q Are you able to testify today without referrin'g. 11 to your. notes? 12 A-About what? 13 Q The subject that we are talking about, the in-14 adequacies that you looked at with respect to Revision 5, 15 your review of Revision 7 and 8?' 16 A I suppose I could to some degree but not with a-17 great deal of trust on my recollection. 18 Q Correct me if I'm wrong. I think you said that you discussed with Dr. Baldwin matters in the plan review 19 20 that were prompted by the FEMA post-exercise assessment; 21 is that correct? 22 A I discussed with him things that I had a question j O
32 Q) I about. I didn't say: Look, I want you to refresh my 2 memory and let's discuss those things that were prompted by a post-exercise assessment of1the exercise at Shoreham. 4 In my own mind, this is what I wanted to do. 5 Whether or not I stated that to him in those words, I don't 6 know. 7 Q Mr. Husar, what I'm trying to get at is what it 8 was about the exercise that you thought was important to 9 review prior to this deposition? 10 A I did very little review of the post-exercise 11 assessment report in preparation for this deposition, since (~# '8 12 my understanding was that I would be deposed regarding the \\- 13 RAC review of Revision 7 and 8. 14 Q And that RAC review of Revision 7 and 8 also 15 included a review of the modifications to the plan that LILCO l 16 made in response to the FEMA post-exercise assessment, 17 correct? l 18 A Correct. Can we visit the subject of my experience and background at the outset of your questions -- l 19 20 Q Sure. 21 A -- so that I can enter into the record some other l l 22 matters that may be relevant with respect to my backgro'ind? l /~ L.)T
33- ,i 3 V 1 Q Sure,.go ahead.- 2 A Upon graduation from-college, I entered the Armed 3' Forces and I served 11 the United States Army, Military 4 Intelligence..Iservedonactiveduty[horthreeyearsand 5 ten months, and during that period of time I had started my broad background.in planning, strategic planning as well as 6 tactical planning as well as work in security and intelli-7 gen'ce,- which was my specialization while 'I was-in the service. 8 Upon my %,eretion from th@e..r=d "sys, DYd, ' ' _ I had h4 9 to work in security and intelligence, working for. the vy. gV 11 And after changing jobs efvy,Iworkedforthe (~) Defense Logistics Agency in{ industrial security also having 12 to do with planning, contingency planning,; as well as in 13 i 14 enforcement of D0D directives. And that portion of my background then 'l'ed me to I 15 my changing jobs and joining the Defense Civil Preparedness 16 Agency which subsequently became part of the Federal Emergency 17 Management Agency in July of 1979. i. 18 19 Q Do you recall what years those military experiences ( 20 occurred in? 21 A Vividly. 22 Q Just generally. . O
34 [d' - ? 1 A 1968 to 1972.'. I am still connect'ed with the 2 Armed Forces. I am in the U'.S. Army. Reserve at this time, a in the ~ selective reserves, and I hold.the rank of Lieutenant 4 -Colonel in the United States Army?Res~erve. -s Q Thank you for bringing that up. If you feel like 6 you have to supplement 'anything else in this deposition, 7 feel' free to do so. 8 A Okay. 9 Q I would like to get things'back on a little bit 10 of reorganization. When was it that you first became 11 involved with' LILCO and the Shoreham Nuclear Power Plant? [) 12 A I will answer your questian. I need~ to refresh 13 my memory here. 14 (The witness is looking at documents.) 15 Q Okay. 16 A October 6th is the date that I received the 17 directive through my Regional Director that our Agency Headquarters had requested the Regional Office to review 18 19 Revision 7 and 8. And that was the point in time that I got involved with the LILCO plan. 20 21 Q Uhat document is that in your file that refreshed 22 your memory? /~T V f y > -, --,--4, e nn ~ - -
35 /~~T U-1 A-This :is ~ a nemorandum for Norman Steinlauf, 2 Acting. Regional Director from Dave McLoughlin, Deputy 3 Associate Director, State'andLocElProgramsandSupport, 4 ' Subj ect : ; Review of 'the ' Long Island' Lighting Company Transi - 5 tion Plan and.LILCO Response to the FEMA Exercise Report. 6 Q So, you received that memo;and what did you.do 7 after that? 8 'MR. CUMMING: For the record, I should state. 9 that that memo was served on all parties' to this proceeding. 10 THE WITNESS: Shortly thereafter, and counsel 11 has it before you. It was served on you. October 22nd p 12 ' memorandum, I had sent out a request.to have the' members of the Regional Assistance Committee conduct that. review with. 13 a time frame by which I would like to have the responses. 14 15 And I requested that I wanted the responses, their 16 ' comments, by close of business November 14, 1986. 17 BY MR. ZAHNLEUTER: (Continuing) 18 Q This October 22nd letter was given to me by Mr. 19 Cumming a few minutes ago; am I correct? 20 A Correct. 21 Q About the third or fourth sentence, it says: 22 "Due to the time sensitivity of the action, NRC only asked O \\_/
36 t' l v 1 for a FEMA internal review." I think,that refers to Revision 2 6. 3 Could you explain what. you ' meant by the time 4 sensitivity phrase in that sentence? 5 A I'm sorry, where are we? 6 Q In your October 22nd memo to the RAC, about the 7 fifth line down. 8 A Just a second. There was previous-correspondence. 9 Based on the request from Sam Speck, dated January 22nd, 10 1986, FEMA prepared an internal review; that is, a review of Revision 6 of the LILCO plan without convening the Regional 11 i ) Assistance Committee and without asking them to conduct the 12 13 reviews. 14 MR. ZAHNLEUTER: I would like to mark this as is Husar Exhibit 1, but I'm afraid I don't have a copy right 16 now. 17 MR. CIDD4ING: Which do you wmat to mark, the 18 October 22nd memo? Okay. It's the October 22nd memo 19 you wish to mark? 20 MR. ZAHNLEUTER: Let's mark the entire package 21 that you handed out, Mr. Cumming, which is covered by a January 5, 1987 memo and which includes that memo plus a 22 /^\\ \\
.37
- .h 1
December 19th, 1986 memo to-Dave McLoughlin:and then lastly-c-L, 2 the October.22nd memo.'from'Mr.-.Husar.- ~ ~ 3 MR. CUMMING: Let's addfone'.more-passed.out-the'same time,~thb Novembe~r 25'tli,'1h86 Attendance list. ~ 4 at 5: MR. ZAHNLEUTERT 10kay.- We1will make Husar' Exhibit, 6 1-a four-document package. 'indexx 7 (The -documents-referred to are marked'as=Husar-Dep'osition 9 Exhibit Number 1 for identifi-: ~ to cation.) 11 BY MR.LZAHNLEUTER: (Continuing) 12 Q What was the time' sensitivity'for that action? 13 A I cannot speak to that subj ect.since -I wasn' t 14 party to that plan review. If you will notice the date of-15 this plan review, the date of February 6th, 1986', I was-in 16 no way connect'ed with the radiological emergency preparedness ~. 17 Q But you wrote this memorandum of October'22nd, 18 right? -19 A That's right. 20 Q Why did you think it was necessary to refer to 21 the time sensitivity of that action? 22 A What I am alluding to is the October 6th, 1986 O
38 r 's - (j memorandum requesting the review and the deadline thAt was 1 imposed on us by'the National'{ Office...The Jdeadline imposed 2 3 on us _ for ~providing the' complete plan review was' December 8th, 4-
- 1986, s
Q Well, what purpose would be served by reviewing 6 Revision 6, in effect, retroactively after Revision 7 and 8 7 came out? 8 A I felt that it was important that there be a complet e 9 RAC review of Revision 6 since none had been conducted. 10 And, for the record, I also provided to the Regional 11 Assistance Committee' the internal FEMA review of Revision 6 (~ k-so that they could review it and :Lf they had any comments 12 13 about it that might require'further discussion or any changes 14 to the comments that the' internal FEMA; review had resulted .1 15 in. 16 Q Okay. Were there any comments or changes? 17 A No. In fact, it's stated in a letter of trans-mittal that the Regional Assistance Committee supported the 18 19 evaluation, the comments with respect to Revision 6 to the 20 LILCO plan. 21 Q Did it state any reason? 22 A It was the subject of discussion. He made sure () \\
39 / I that we went over the different elements that we review under; 2 in accordance with NUREG 0654, and I -- the way we came to 3 closure on Revision 6 and the RAC acceptance of the comments 4 in Revision 6 was by voice vote, and it was unanimous. 5 Q When did that voice vote occur? 6 A The same date of the RAC consolidation meeting 7 for which you have the attendance list. 8 MR. ZAHNLEUTER: Mr. Cumming, have the Intervenors 9 been provided with the RAC review of Revision 6? 10 MR. CUMMING: It was encompassed in the transmittal 11 of December 30th, 1986. That RAC review, in fact, encompassed i i 12 6, 7 and 8. 13 You can ask my witness to clarify that. That was 14 my understanding. And you have been furnished that document. 15 MR. ZAHNLEUTER: I would like to make that docu-16 ment Husar Exhibit 2. It consists of a cover memo to Mr. 17 Victor Stello, S-t-e-1-1-o, dated December 30th, 1986. 18 And then behind it, attached to it, is the consolidated RAC 19 review. 20 MR. CUMMING: Why' don't you put th~e cover letter in with the understanding that attached ~to the Husar '-- to 21 avoid copying -- is the transmittal which was s'erved on'a'll-22 )
40 ~,,, U 1 parties I think'several times. You explain it the way you 2 want to. 3 MR. ZAHMLEUTER: That(would be fine if.we can-4 recall what the Bernacki exhibit number was for the same-5 document. 6 MR. BORDENICK: It was 8, Bernacki 8. 7 MR. CUMMING: Since 'we are-on the record, I notice that Paragraph 2 refers to the fact that it_'s the review of. 8 9 6, 7 and 8.. 10 MR. ZAHNLEUTER: Okay. Please allow me to clarify 11 'this for~the record. The offer of Husar Exhibit 2 is with-12 drawn. In its stead, we will refer to Bernacki Deposition '13 Exhibit.8 which includes a cover letter to Victor Stello, 14 ~ dated December 30, 1986, as well as the RAC review dated 15 December 15, 1986. 16 MR. CUMMING: No objection. 17 .BY MR. ZAHNLEUTER: (Continuing) 18 Q Now, Mr. Husar, where.is it in Bernacki Exhibit 19 8 that Revision 6 is referred to? 20 A First line, second paragraph. 21 Q Of the letter to Mr. Stello? 22 A Correct. O
41 O,m 1 Q. Okay..Could you read that. sentence? t 2 LA "A ful1JRegional~ Assistance Committee review of. 3 Revisions 6,.7 and 38 has been:'completedrand 5the' results are contained 'in the-enclosed report en' titledLILCO Transition 4 5 . Plan for Shorehau - Revision 8, Consolidated RAC-Review' 6 dated December 15, 1986." 7 Q Whereib-theenclosbdrep'o't, 4 r which~is the RAC J 8 report,..is Revision 6 mentioned? 9 A Okay.- Let me. just -.say1for the ~ record that. I wasn' t l 10-party to thelletter to Mr. Stello.. That was prepared byfthe~ 11 National Office'. l ~ i: ~ 12-The reference'to'the' review of Revision 15 is 13 contained as.part of.Husar Exhibit 1, the. memorandum from. Norm Steinlauf to. Dave McLoughlin, dated 19. Dec' ember 1986. v 14 i 15 The second paragraph.' It's'also.in the~'first paragraph. t 16 Q After-you asked the RAC for the~ir review of-L '17 Rev 7 and 8' in your October 22nd memorandum, what did you 18 do? 19 A T7e proceeded to conduct a FEMA review of those 20 revisions. 21 Q I am confused by what you mean by FEMA review. 22 Is that something different than a RAC review? L (:) n .__.,._.__.,.,..m.,
42
- ,.m.
0 1 'A Well, each' agency, as spelled out in 44. CFR )ST* -- 1 2 350,-excuse me, has a responsibility.in this process related a to off-site' emergency preparedness., Uhat-we'do is, we ~ c.. i 4 conduct our own review of-those plans based.~on the' UUREG s criteria so that when we come to the Jmeeting we will have. <6' our own evaluation, ourz own comments on those plans so that ~ 7 we are just not going: purely based ~ 0n! wha't other agencies might submit based on the -plan review requirements that - each 8 agencyLis.. supposed to' conduct. based on'their varied expertise. 9 10 Q And with respect to Revision 7 and 8, did the 11 other~ members of the RAC prepare a similar -- (' ' \\-) 12 -A Yes, t h e'y - d i d. They provided their written -- 13 comments on Revision 7 and 8. 14 Q. Okay. 15 A And,the ' RAC consolidation meeting on November 16 22nd was used for the purpose of just that, consolidating the 17 comments and coming up with the final set of plan review comments, not only the Revision 7 and 8 and addressing the 18 subject of Revision 6 but also disposing of the matter of 19 the plan changes that were prompted by the exercise results, 20 21 which is Attachment 2 to Bernacki Exhibit 8. 22 Q Uhich is the consolidated RAC report? O i m. ,.----_.,-y_ ,,m, ---r
>+ 43 U 1 .~A Well,- Attachment 2-is the sch'edule for corrective .2' action orLerrors requiring corrective' action directly tied 3 into the' exercise. 4 Q Are those ' wha ~t have' been refirred to as spread 5 sheets? 6 A Yes. 7 Q Did anything else happen between October 22nd 4 8 and the' meeting of November 25th? 9 A ' Routine busines~s. RAC members calling, asking for . Some RAC members calling asking for 10 some clarification. 11 a-time extension. Some RAC members calling and saying . f~'C ~ ) that -- basically related to me a difficulty witn other com-12 i F-13 mitments to meet the deadline that-I had given them. 'The 14 routine kind of things that we get in any.reques't for'RAC 15 review. 16 Q As part of Husar Exhibit 4, there is an attendance 17 list l 18 MR. CUM 11ING: I'm sorry, Husar Exhibit 1. I 19 BY MR. ZAHNLEUTER: (Continuing) j 20 Q Husar Exhibit 1, I'm sorry. It's the fourth 21 document in the package. Are those the' members of the RAC 22 that attended the meeting? f l ._..,_.-._..-___-__.---..-..,m
44 ( 1 L. ) 1 A These ~are all the parties present at that meeting. 2 Q Who on that list is a RAC member? 3 A Paul Lutz, Ron Bernacki, Charles Amato, Herb 4 Fish, Cheryl Malina. 5 The other person from the Nuclear Regulatory 6 Commission was Ed Fox, and he is an individual who was 7 there for transition purposes because of MRC's switch of 8 their designated RAC member.to' FEMA Reg' ion II. 9 Q You are also a member of the RAC, right? 10 A Yes, I am. Bob Acerno works for me. He was 11 party to that meeting as well. Phil McIntire, my boss, he p 12 was there at the beginning. 13 Q Were there members of the RAC who were not 14 present? 15 A An individual who came and attended at the very 16 end but was not there and, therefore, his name does not appear on here is Mr. Giardina from the Environmental 17 18 Protection Agency. 19 Q Was it actually he who attended the meeting? 20 A Yes, it was. 21 Q Was there anyone else who did not attend? 22 A Everybody we asked to attend did attend at some [( i r l
v 45 Ab 1- . point in time'during that day. 2 Q And is it fair to say that you asked all members ~ 3 af the RAC to' attend? 4 A Ho. 5 .Q Who'did'you not'ask? - ~ .6 A Department of Commerce,. Department of Interior 7 and Health and Human : Services. Now', cone might say that the f Food and Drug Administragion, is a part-of the Health 'and 8 ~ 9 Human ' Services ; therefore, that completes ~ that membership.. 10 However,. Health and Human Services, per se was not represent-11 .ed. 12 .Q The Department of Transportation is not a member i 13 of'-- 14 A Yeah, right-there on top, Paul Lutz. 15 Q Why were those three~,.the' Commerce Department, 16 the Interior Department.and HHS not invited? 17 A All right. Please restate the question. 18 Q Correct me if I'm wrong. I believe you stated 19 that members of the RAC representing the Commerce Department, the Interior Department and HHS were not invited to the 20 21 meeting and, therefore, were not in attendance. 22 A All right. With respect to the Department of-O i . - _. - _... _ _.. = _., _.,
46 p) - (~ 1 Interior'-- correction. With respect to the ' Department of 2 Commerce, they have notified us that they were unable ~to a support the RAC and plan review requirements.' That was 4 documented some time back and, therefore,"we did not ask them 5 .to participate in this RAC review.' 6 WithIrespect bo:the' Department'of Interior, the Department of Interior basically has advised our Agency 7 through the Federal Radiological Preparedness Coordination 8 Committee that unle's~s the specific matters to be reviewed -9 in terms of plans relate to the ingestion pathway where ~ to Department of Interior facilities are involved, i.e., parks 11 'o and other government properties that.are controlled by the 12 Department of Interior, they would no~t conduct any reviews. 13 And, so in this particular instance there were no matters 14 at issue in Rev' 7 and 8 that related to that; and, therefore, 15 16 we did not ask them to participate. 17 Q And what about HHS? 18 A With respect to Health'and Human Services', they have had a long standing position with FEMA that if there 19 were matters that needed review on the part of Food and Drug, 20 certainly the Food and Drug Administration could send their 21 22 member to participate. But with matters that deal primarily O 4
T f 47 -I with other ~ parts of-the Health and Iluman Services Agency, ~ 2 they.were not equipped and staffed to' provide. that kind of : 3 support to the.RAC. 4 _ Q. I'm going to.ask several questions now about the 5 RAC meeting on the 25th, but would you appreciate a break. 4 8 before I do get into that or would you rather continue? 7 A I-would ratlier. continue.- s Q Okay. Let 's continue. 9 MR CU19fING: I assume 'you are 'not going to ~ ask k to any deliberative proces's questions, just with respec't to - t -11 Mr.;Husar's personal knowledge'for which w'e have authorized. i - 12 him to testify. ~ BY MR. ZATIMLEUTER: (Continuing) 13 14 Q Mr. Ilusar, at that meeting on the 25th, do you recall what plan changes were' discussed that were prompted < 15 16 by the exercise res'ults? 17 A Without' referring to my notes, I would be hard is pressed. 19 Q Refer to your notes. (The witness is looking at documents.) 20 endT1 21 MR. CIDHfING. Excuse tne. Is that just one page? Do you want to go off the record and let me make comments, 22
- a
48 !v't i and then we'can make'this an exhibit? Would that be 2 appropriate if you are going to spend some time on this 3 issue? 4' I think the question was rather complex. 5 MR. ZAHNLEUTER: Make comments? 6 MR. CUMMING: Copies for everyone, and we will 7 just make it a Husar exhibit. It will just take two minutes. 8 MR. ZAFNLEUTER: Okay. 9 (O ff-the-re cord. ) } 1 to MR. ZAHNLEUTER: Mr. Cumming has provided to me 11 at this time part of Mr. Husar's file, the part that appears 12 to contain handwritten notes. 13 And I would like to mark that production as 14 Husar Exhibit 2. It's a package which consists of six indi-15 vidual components. And let's have it marked as Exhibit 2. 16 (The documents referred to are indexx 17 marked as Husar Deposition 18 Exhibit Number 2 for identifi-19 cation.) 20 21 BY MR. ZARNLEUTER: (Continuing) 22 Q Now, Mr. Husar, the pending question I believe A __ g
49 ' 's O' is what plan changes were prompted by the exercise results? i 2 A All right. ' would like to turn to my notes to 3 long sheets of paper wherein at the top it reads MUREG 4 Element, Location, Topic, Type, ARCA Page Mumber, Response and Remedial Action across the top. 5 What you see before~you is what I have extrapolated 6 from-the spread' sheets from my analysis that are plan changes 7 a that were directly tied into the exercise, post-exercise 9 assessment results. 10 Q Could you h'elp me interpret this document,ad list for me which plan changes were prompted by the ' exercise 11 g \\Y results? 12 13 A All right'. To explain to you what this represents, the way I did this analysis goes directly from Page'l of 14 through its conclusion. And so the plan changes 15 that were made were by location as they appear in the spread 16 17 sheet comments. 18 For example, the first nine'line items that I have listed relate to the LERO Emergency Operations Center. Okay. 19 20 So, if we take, for example, J.10.1; of the MUREG Element, listing the Emergency Operations Center as the location, 21 and cryptically I put down communications procedures and 22 O /
-r 50-
- f]-
G 1 training being the ~ issue,, and the ~ type; of inadequacy that ~~ 2 was made-throughJthe~' post-exercise' assessment report was-that it was'a d$ficien~cy. Land'that(particular complete a
- 4 narrative is found on Page 1 of-16lif the spread sheets.
So, lUE we - look at. Attachment : 2, ' Bernackf Exhibit. 8', 5 Page 1 of-16, we.can navigate.) thro, ugh-this. Hopefully, 6 7 this is in order. 'Yes. So, we11ook.'at, Table'3-1.at~the~ top, Pagel'of 16.:of 8-9 to 'Bernacki Exhibit 8,. I have~ found thatsthis -is one NUREG Element for whichith,ere4was a plan. revision 'in the- ~ ~ to 11 LERO plan submitted. And if we~look at-the column on thatf ~ j - (f 12' particular~ spread sheet, Page 1 of 16, it -will walk :us through ~ which particular= portion of the LERO plan was submitted and 3 ~ 4 13 i 14 . evaluated. And,'so that the' response to theLERO submission 15 'was that it was an adequate response, which is the next to 16 17 the last column on the spread sheet, and that the remediation of that is that it is still inadequate and.the reason being.-- I 18 r and this is my cryptic note -- the '(E) denotes to me that l 19 ( there has to be an exercise to complete.the evaluation lif this I 20 i 21 plan change. It cannot be done in the abstract. It still l remains inadequate because it has to be seen during an exercis e 22 L e
- O l
i i I
g 51 g V I' to be~able'to adequately; evaluate that. 2 So, basically, therefore, this two-page list 3 walks 'you through tho~se matters that are listed in this 4. spread sheet that are plan-related, driven by exercise in-5 adequacies in the post-exercise assessment report. 6 Q With respect to the last column entitled '.' Remedial 7 Action," the (Ef means exercise, and-isfil[ fair.tosaythat-8 FDfA cannot give > reasonable assurance until there is another-9 exercise? 10 A No, I didn't say_that. I said that what we are saying is we need to look at it dur' ing an exercise which is 11 ~0 d structured with a scenario which ' prompts that kind of play 12 or implementation of that portion of the' plan in order to 13 14 make a definitive evaluation.of the~ adequacy of that plan is revision. 16 Q Is it fair to say that FDfA cannot determine the adequacy of Revision 7 and 8 until that remedial exercise is 17 18 conducted? 19 A With respect to that particular line item as it relates to the NUREG and that particular procedure which is 20 21 identified in the column on the spread sheet, the column 22 entitled "FDfA Evaluation of LF.RO Response." O
52 l-1 Q So that I'm sure, let me recap which elements 2 those'are. That's MUREG Element J.10.K -- 3 A Correct. 4 Q -- I.10, F.1.D -- 5 A Correct. F.1.C. If you are going down the list 6 there, that's from the top to the bottom. Is that what you 7 are doing? 8 Q I was looking at' the ones 'that. had an (E) under 9 the -- to A Oh, I see, that need an exercise to evaluate, 11 complete the evaluation. Okay. Fine. /~') 12 Q Right. You called it a definitive evaluation 13 or a complete evaluation. 14 A Right. Of that particular plan change. Right. 15 All right. Proceed. The first one you mentioned is J 10 K. 16 What is next? 5 17 Q I.10. 18 A Correct. 19 Q F.1.D. 20 A Correct. Those two are related to that same line 21 item. 22 Q I.10. F7 U
53-43 D 1 A . Correct. 2 Q E.2 3 A Correct. 4 -Q I believe~J.9_and J.10.G; am I reading that 5 right? 6 A. Yes'. -7 Q Okay. 8 A - Now, j ust to explain the' others', tokay. P says 9 we didn't buy off on a particular plan submission, in to parenthesis. (T) denotes' trainitig.1 This:is my cryptic way-11-of identifying what isl going to = fix it. ~(P)_is for plan, 12 (T) is for training and (E) is for exercise. 13 So, in the case of what they did from the Patchogue 14 taging ea, that particular item on the' spread sheet that MN 15 is found on Page~1 of 19-that relates' to the.Patchogue' stag-16 ing area which relates to the bus driver dispatch issue, 17 we didn't like the~ plan revision and we are saying on the 18 spread sheet -- I don't need to represent those words here because you have them in front of you in Bernacki Exhibit 8, 19 20 -- it's going to require basically a threefold effort on the part of LERO in order to fix that particular 21 And that's another rewrite of the plan b @ 22 planning problem. O
54 \\ 1 be1 submitted. It's going to require ' training and 'also ~ followed up by a demonstration of that particular capability. 2 3 during an exercise. Okay. -4 Q How about the'next line~on.that.page which has 5 N/R under NUREG Element? 6 A Okay. The' N/R denotes no MUREG reference. These 7 are purely items that were picked up during the exercise that L cannot be'directly correlated to any planning criteria in a 9 NUREG 0654,.that in the estimation of the federal evaluators to during the' course of the exercise were problem areas that 11 needed fixing, and the rest speaks for itself. 7% 12 And, for the record", I would like to say that the ~ 13 uay we normally do business, we would ask the ' level of 14 government that would generate this plan to demonstrate-this 15 Particular capability at the next exercise. So, what we are 16 saying is that this whole process related to LILCO is not 17 typical specifically to the extent-that we are not dealing i is with a level of gover6 ment, we are dealing with a licensee. 19 But, the point I wanted to make is that an exercise 20 is what it's going to take to finally come to closure and 21 our definitive evaluation of that plan provision. t 22 MR. ZAHNLEUTER: Okay. I would like to note for I I
55 (., td 1 the ' record that the -list of 11UREG Elements goes on regarding 2 remedial actions that'must be' exercised. And-I can't refer 3 to them anymore because they are' denoted by N/R. 4 THE WITNESS: Might-I suggest the'page numbers? 5 For example,_Patchogue' staging area, page'of pages. 6 MR. ZAHNLEUTER: Okay. 7 BY MR. ZAHNLEUTER: (Continuing) 8 Q Page :1 of 19.- Is thatta,5 of-19? 4 ~ 9 A Correct. ~ 10 Q 6 of.19. 11 A Correc't. O 12 Q 7 of 19,_.that shoul'dibe? 13 A Let me just double check here. (The witness is looking at a document.-)' 14 is Q Okay. 16 A Correc't. That should be a 7 of 19 and it should 17 be 8 of 19 and 9 of 19, 18 Q And then the list continues', 10, 11, 12, 13, 14 19 of 19. 20 A Correct. And that completes the spread sheets 21 related to the Patchogue staging area. 22 Q What does the next reference mean, 2 of 6? O
56 L) v 1 A Okay. WithrespecttoRiverheadftaging/brea 2 on Page 2 of 2. 3 Q And exercise would be the' remedial action called 4 for in the next entry pertaining to NUREG Element J.12 for s the reception centers, right? 6 A J.12, reception center, correct. And my note 7 there ~is length of personnel monitoring. That's how I-characterized cryptically the nature'of the' problem area. 8 9 Q What does' an (A) under remedial action mean? 10 A Agreement. 11 Q What about an (H)? t ) 12 A Hardware. 13 Q Besides a discussion of this topic, did anything 14 else occur in the meeting of November 25th? 15 A I think I have~ stated earlier it was threefold. The RAC consensus with respect to the FEMA internal review 16 of Revision 6, the comments on Revision 6; Revision 7 and 8; 17 and, also the disposition on the spread sheets which is 18 to Bernachi Exhibit 8, whether or not we had 19 20 agreement on the evaluation in the last two columns. 21 MR. CUMMING: Could I ask one clarification for 22 the record before he leaves this? When exactly did you O
m ;;. g =. ^ -57 /~)N.. A prepare this form that Mr.- Zahnleuter: Just referred? I 2- .THE.UITNESS: Sunday. 3L BY MR. ZAHNLEUTER: (Continuing) 4 l-Q But you. prepared it on this last Sunday 'from 5~ your. memory _ of what ' occurred on the 25th; isn' t that 6 correct? 7 Let me rephrase that. What did you prepare it. 8 from? ' 9' A' .I wanted to'be'able to. perform an analysis. This is nyf analysis of what'we had done on-the' '25th, not. that ' I to wanted to refresh myself Lof twhatiwe ha~d done on the 25th 11 ~ < but to have an anaiysis so that I could speak to the subject 12 of which matters require wha't kind { of L rem ~ediation. For T is . example, which matters req'uire additional plan changes; 14 i ' which matters have.to be ex'ercised for us to make a final 15 a determination with'respec't to that plan revision and so t 16 F 17 [on. 18 .Q Okay. For example, on the spread sheets of Bernacki-Exhibit 8 for the LERO EOC, Page 1 of 16, the last 19 I. 20 column says remedial action (I) for incomplete, and what you 21' are telling me is that (I) means that the required remedial 22 , action is an exercise? l r
58 Vi 1 'A Correct. 2 Q And so on and so forth'throughout-the~ rest of the a spread sheets? 4 A Uh-huh. 5 Q In the ' spread sheets, an (I) La the' column of 6 remedial action means incomplete; is that correct? 7 A Correct. 8 Q And in your notes that we marked as Exhibit 2, 9 an (I) also means incomplete when.it's under the remedial 10 action colunn? 11 A Correct. [D 12 Q And an (I) when it's under the response column la mean inadequate; is 'that correct?. 14 A Correct. 15 Q After the' November 25th meeting, did any other events occur with regard to the' review of Revision 7 and 8? 16 17 A Only the usual process that we go through in l consolidating our comments and putting pen to the ~ paper and 18 1. getting the final language of the RAC comments on the plan 19 I 20 review. 21 Q Let me refer you to Husar Exhibit 1 which contains 22 a December 19th letter from Mr. Steinlauf to Mr. McLoughlin. p/ (, 1 1
59 1 A Right. 2 Q The second page of that letter refers to a 3 normal review process for nuclear power plants in Region II. 4 Do you know why it is that the circumstances around Shoreham would effect the review process for other nuclear power plants 5 6 in Region II? 7 A Could you show me where that is in this memorandum? 8 Q Well, I was looking at the first sentence on the 9 top of Page 2. How do you interpret that first sentence? 10 A I think we stated for the record, not only with 11 respect to this memorandum but before whet other ASLBs, what [W@b 12 our process is. And, this memorandum says what it says.
- And, 13 we have gone on with testimony before countles's ASLBs with 14 respect to our process and who we do business with.
15 Q Okay. The first item under that sentence refers to corrective action that has not been followed for Shoreham. 16 17 Do you know why corrective action has not been 18 followed? 19 A The way we do business, we deal with the state where power plants are situated as well as the local govern-20 21 ments where power plants are situated. That's the way we 22 normally do business, through them and with them and for l
60 7 1 ~ them. And so this is not the case where we are dealing with 1 2 a non-governmental entity. So in that respect and that a context, we have not in our normal way of doing business 4 asked the state to respond with corrective action or the 5 state consolidate corrective action on the part of those 6 levels of government that have the plans to be written and 7 to be changed and to have meetings with them, because that's 8 the way we do business, an ongoing process where we are always 9 in touch with the levels of government through the state. 1o And, so this is an evolving process. And planning, 11 as you have maybe seen in other testimony that FEMA has ,,I i 12 made, is a dynamic process, ever changing. And so we have la not had that contact and that dialogue with the licensee. 14 So, that's why corrective action;probably has not been taken. We don't know. We didn't ask. He have not is communicated with the licensee with respect to any remediation is of those deficiencies or inadequacies, whichever M case g 17 is fits. 19 Q Have there been any discussions or communications 20 with LILCO, the licensee, regarding the scheduling of a 21 remedial exercise? 22 MR. CU?UIMG: Ashed and answered. To the extent (b
5 '61 LI 1 witness has knowledge, he may answer. 2' THE WITNESS: To the ' extent' that I have knowledge, 13 and to the extent of my involvement as RAC Chairman, 'no. 4 'BY MR ZAHNLEUTER: -(Continuing) ' 5 Q Have there been any such discussions internally. 6 within FEMA?- 7 MR. CUMMING: Objection, based'on relevancy. To 8 the extent the witness has knowledge, he may answer, is 9 instructed to answer. 10 THE WITNESS: I have not been party to any conver-11 .sation with respect to another exercise. ~ BY MR. ZAHNLEUTER: (Continuing) 12 13 Q Do you have any knowledge'of.a(Revision 9 to- ~ 14 the LILCO plan? 15 A .I have no direct knowledge of any additional revision or revisions to the LILCO plan. 16 17 Q Could you turn to Bernacki Exhibit 8 and to the second page of-the ' letter to Mr. Stello, specifically to the 18 - 19 fifth paragraph? (The witness is looking at the document.) - 20 21 A Okay. 22 Q Have you familiarized yourself with that O
/ 62 L k Q) - 1 -paragraph? 2 'A-I -have j ust read it for the -'first time'. 3 Q Could yougive me your opinion of what:that ~ 4 paragraph'means? 5~ -A - As I stated j ust.-a little while ago, we are - not a doing business e.he way we.normallyjdo in the caseLof LILCO -and the LERO plan, because we~ 'are not dealing with our ~ 7 8 normal. constituent which-is a government entity, state'or- -9 ' local. And since we don' t have the ' dialogue.that-we would to normally have'with them', it's -- it.would be very difficult for us to plan: allocation of resources for plan reviews and 11 - -.0' ' for any other-work ~ that is necessary in connection with.off- ~ ~ 12 13 site emergency. preparedness. '14 Q .Does this paragraph mean-to you that:-if Revision 9 is submitte'd to FEMA. that. FEMA ~will -be unable to conduct - 15 .16 a further review?. 17 tiR. cut 9fING: Obj ection. - It calls for the 18 witness to speculate. 19 To the extent he has knowledge, he may answer. 20 THE WITNESS: That's not a question that I can since that would require a decision on the part of 21
- answer, that FEMA Headquarters as to what we would do in the event 22 O-
63 .(~ ~ 1 the Nuclear Regulatory Commission would want us under the' 2 MOU to review the -next iteration of the plan.- 3 Q In the first-paragraph on that page, theLlast 4 sentence contains a reference to Element E.-5~andathen a-3 parenthesis, perhaps others. 6 Could you read that sentence'and,-if,you have 7 knowledge, explain to me what other NUREG elements are 8 referred'to? 9 (The' witness is looking at the document.) ~to A All.right. At the time of the review of 7 and 8, 11 we had gotten. indication that in the case of the EBS radio h 12 station, WALK, that they'had withdr wn.from their association la with and their agreement to be the entry station for emergency broadcast alert notification dissemination. 14 We only review what is submitted to us to review; 15 16 and, therefore, although we had knowledge of there being this letter from the radio station saying they are not going 17 to participate in any response as an EBS station, we could ~ 18 19 not use that as part of our plan review. And, so what we were saying, if we were to look 20 this again we would certainly have to take the EBS radio 21 at 22 station issue into account, and we would want to have the ~ ( L
- s ~64 v t. writer of the_ plan,'the' author of'the1 plan,-demonstrate!to 2 us who or whichiradio station would be the-EBS radio station, 3 as.an example, since~if it is not UALK who is it'and where 4 ~is'the agreement that says it'is so. 5 Q In Exhibit 2, in your chart which you entitled ~ 6 "ARCA Chart" there isn't any entry for NUREG Element E.5. 7 Is' there a reason.why? 8 A The spread sheets relate to exercise ' inadequacies. 9 And, let me look at.this.again.. 10 MR. CUMMING: I'm.sorry. For clarification, are-11 you referring to this document? ~ 12 MR. ZAHNLEUTER: <Yes.: It's part of Husar Exhibit ~ 13 2 It's the'one we referred to earlier entitled "ARCA ~ 14 Chart." THE WITNESS: I'm not qualified to answer that 15 16 question, since that relates to an' exercise iscue. 17 BY MR. ZAHNLEUTER: (Continuing) f 18 Q What do you mean, an exercise issue? 19 A There was a demonstration four times in the _ exercise, and I believe that is correct although I'm not -- 20 21 haven't been party to that. There was an evaluator observa-22 tion of a test emergency broadcast system. The notification O
4 -65
- q 1-that we - had l received _ and. a copy of the letter that. we had
~ '2 gotten'in our office'with respect 1 to action taken by the ~ management of.the radio station,: WALK,:_ occurred subsequent 3 4
- to.the exercise.
5-And,. therefore, Lit is not part iof the spread-sheets, Attachment 2.to.Bernack'i Exhibit 8 6 7 Q Now,'it is part'of Att'achment 1 to th'e consolidated 8-RAC review, correct? 9. A- .Yes, it is. Correct. 10 Q And I-see that there is a _ rating of A for 11 ' adequate. 12 A -I think that statement: speaks.for itself. D 13 Q Right. ~ Going 'back' to Page'2 of that memo to Mr.- - 14 'Stello, do you know what other NUREG el~ements he is referring 15 to in that parenthetical note? 16 A No. It would be,only. conjecture on my part. 17-Q On the first page of the RAC review, there is a definition of adequate, not._the letter to Mr. Stello but 18 19 the actual pdc review. 20 A Oh, okay. 21 Q Is it fair to say that an adequate rating means that the plan is adequate to provide reasonable assurance 22 O
66 \\v-1 that appropriate protective measures can be taken to protect 2 health and safety? 3 A No, that's not what this says. 4 Q Okay. What does it say? 5 A This is an evaluation of a particular planning 6 requirement measured against a NUREG element. 7 Q So, you are saying that when there is an A, that 8 means that that planning element -- or, planning requirement, 9 I think you said -- is adequate? 10 A Yes. 11 Q Okay. And, what would a comparable definition of i / 12 inadequate be? 13 A It doesn't meet the standard. 14 Q And, if it doesn't meet the standard, the 15 appropriate remedial action would be as listed in your ARCA 16 chart; is that correct? 17 A Well, in case of plan deficiencies, all right, 18 this is what represents the comments. What we would normally do is request the state -- if we were dealing with the state, 19 20 ask them to give us schedulest corrective action, when they MW A A 21 are going to fix all these plan inadequacies. That's what 22 we normally do with inadequacies with plans that we have (~h N_)
~ 67 r~s (v.F I reviewed. 2 Q Why is that you, as a RAC Chairman,. don't take 3 that step with respect to LILCO? 4 And, why don't you ask-LILCO? 5 A May I have a conference with counsel? 6 (The witness is conferring with Mr. Cumming.), 7 A The answer to your question is, there is 7 8 correspondence between the top management of our Agency and i - 9 the Nuclear Regulatory Commission, how -- 5duit we would do 10 in connection with any plan submitted by the licensee and 11 what we would do -- and also in the event that there should ~ ') 12 be an exercise. 't 13 The Nuclear Regulatory Commission hasn't asked-i 14 us to do that. 15 Q In a normal. case where you deal with the state 16 and local governments, do you, as a RAC Chairman, ask the i 17 State and local -- 18 A Yes. If Q -- governments directly -- 20 A Yes. 21 Q -- or do you wait for instruction from the NRC? 22 A As part of what we do in our normal business I, C)
l' 68 w(% I as RAC Chairman, would send!a letter to the top official 2 responsible for radiological emergency preparedness, off-- 3 site preparedness, forwarding the plan review comments and 4 ask, of course, for a schedule for corrective action. 5 Q Has the RAC seen a schedule of corrective actions 6 from LILCO regarding the deficiencies noted in the post-7 exercise assessment or even the ARCAs? 8 A To my knowledge, there have b'eennoneprovided and 9 there are none furnished to the RAC; none provided by LILCO ( ~ 10 to FEMA and, therefore, none provided to the RAC. 11 And with the exception that 7 -- our review of O 12 Revision 7 and 8 in part reflect plan revisions prompted by 13 exercise shortcomings. 14 Q Have you, as RAC Chairman, seen a LILCO response to your consolidatedlRAC review?. 15 16 A No, I have not. 17 Q Or had any cotanunications regarding a response?' 18 A I have no knowledge of that. 19 Q On Page 1 of 15' of At'tachment 1, I want ' to ask you a question about the last three lines on that page. 20 Perhaps you could read it to become familiar with it. 21 22 A I'm sorry. Uhere are we? O
..~. C 69^ h ~ i Q. Page 1 of 15 of Attachment 1. - 2 A .Got it. And what would you like me to read? 3 Q "However, based on.results of the February 13,- -4 1986. exercise and the PAC review of subsequent plan revisions .5 it is recommended that LERO notify FAA directly..."- s Could you tell me what results of the February'13th 7 exercise you.are referring to?. 8 A Remember, these are comments on review of plans,. 9 okay. And A.3 has to do -- Element A.3 of the NUREG has 10 to do with agreements. And, so' t'.lis is a planning comment, i. 11 a comment on planning, not on an exercise, anything prompted i ~ 12 by the exercise. I' 13 Q Well, I'm sorry. I didn't mean to cut you off. 14 - A And, so what we are saying here is that it is our 15 view as of December 15th, 1986 that-to minimize the process-to ing time of various intermediaries in getting federal response 17 that the caller should deal'directly with the agency that 18 would respond to that particular emergency request. 4, t 19 Q What -- 20 A And, therefore, we would also like to have it in I I l~ 21 writing as a letter agreement between LERO and the Federal i 22 Aviation Administration. ) 1 e www-v -ee-a- --mw er,-. we. w -r-, w w*p g eer -.y:, y,,-warr.e----m,-.,wmw o w m wm y.,,,m--..w.av- -v--rm---t g*<wr-y-v,.,,ym--vrv* v = www - m e'-+- ~ v-
70 f) LJ 1 Q What was it about the exercise that caused the 2' RAC to come to that conclusion? 3 A I am not qualified to speak to that subject be-4 cause I wasn't a party to the exercise process. 5 Q On'the next page, Page 2 of 15 of the RAC review, 6 there is a paragraph dealing with the American Red Cross. 7 Are you familiar with the letter that is referred to there? 8 A I'm familiar with the issue. 9 Q Is it your belief that the American Red Cross to has responsibilities just at congregate care facilities? 11 A No. I think the statement speaks for itself. (~T 12 Q Do you believe that the American Red Cross has la responsibilities at reception centers? 14 A I think the matter at issue here has to do with end2A 15 congregate care centers. 16 Q Did the RAC consider reception centers? 17 A The answer is, we had consulted with the -- le t 18 me speak for a minute what I know about this matter. That 19 the role of the Red Cross is sheltering. Sheltering occurs by definition and the parlance of New York State planning as 20 21 being called congregate care centers; that sheltering does 22 not take place at reception centers. Therefore, we did not
71 p LJ 1 view the need and did not see a responsibility of the Red 2 Cross at reception centers. 3 Q Does that mean that in your view the Red Cross 4 has no responsibilities under the LILCO plan at reception 5 centers? 6 A I think what I said is an adequate answer to your 7 question. 8 Q You have said that you have reviewed Revision 6 9 to the LILCO plan, right? 10 A No, I did not say that I reviewed Revision 6 to 11 the LILCO plan. I said there was a FEMA internal review 12 conducted of Revision 6 of the LILCO plan. '~' 13 Q And, wasn't there a subsequent RAC review -- 14 A That's right. 15 Q -- of Revision 6? 16 A And there was a subsequent RAC review of Revision 17 6, in which case I stated' earlier the consensus of the RAC 18 was that they had no difficulty in the. plan review comments 19 for Revision 6. 20 Q Could you switch to Page 10 of 15? For NUREG 21 Element J.10.H, there is a description of the American Red 22 Cross. In the middle of that paragraph it says, "This policy ) l l I k
.a 1 ry 1 is unworkable." Could you explain what you meant'by that? ~ 2 A What LERO' wanted to do is to get the American. Red a ' Cross to-enter into the' agreement.with the various' facilities 4 that it Jwould select-for this purpose. We found that un-5 acceptable, and if you look at the last sentence'of our 6' evaluation in J.10.H, "It'is FEMA's position that' letters of 7 agreement are required for alljfacilities which are planned l 8 to be used in an emergency response." Not just with the Red 9 Cross but between LERO and those facilities. 10 Q In the next sentence it says, "The new materials 11 submitted for Appendix B raises many questions concerning. ! O 12 the participation of the American Red Cross in a Shoreham 13 incident..." i 14 Could you elaborate on what kind of questions are i 15 raised? 16 A Well, the. agreement letters basically say there 17 is no agreement.- There l's no agreement.b'etween the Red Cross is and LERO for this purpose. 19 Q And FEMA's position'is that a letter of agreement l 20 is required? l 21 A That's right. 22 Q At the bottom of that page, there is a footnote !O l l l i
73 ./') \\~J ~ 1 with'an asterisk next-to it,where.it says, "It should be 2 noted'that one RAC member felt that this element should be 3 rated adequate." 4 Is this the only instance when such a situation 5 arose? 6 MR. CUMMING: Objection. Witness may answer to 7 the extentihe has knowledge. Objection based on deliberative 8 process. 9 THE WITNESS: 'I wanted to state for the record to that we were not unanimous on this particular matter, And' 11 so I wanted to give recognition to the : fact that it's not O-always the case where we he.ve unanimity, that the final 12 decision with respect to the evaluation rating for a 13 14 particular plan element rests with FEMA. 15 BY MR. ZAHNLEUTER: (Continuing) 16 Q Do you know of any instances where one RAC member 17 or one or more RAC members rated an element inadequate but 18 the overall rating was adequate? 19 MR. CUMMING: Continuing' objection. Witness may 20 answer to the extent of.his knowledge without identification 21 of individuals concerned. 22 THE WITNESS: That happens often. It's not unique
A 74 A'. ' k_) 3 1 with respect to the Shoreham plan review. It happens where 2-there is no unanimity, that we have people at variance -to a the consensus. And, again as I stated earlier, it.isLthe 4 final decision as to the rating for a_particular element, s that rests with' FEMA and the RAC Chairman. 6 BY 11R. ZAHNLEUTER: (Continuing). 7 Q What made this particular element, J.10.K, 8 noteworthy so that you decided it was important to place 9 into the review? 10 A I think it was at the request of that particular 11 agency; my recollection is that we wanted to show that-a ~ , O 12 particular agency had an evaluation rating that was at 13 variance with the majority, and they wanted to go on record 14 as saying that they are not in agreement with the evaluation. 15 Q With respect to the ratings of adequate in your 16 review of Revision 7 and 8, do you recall any other instances j, 17 where the rating was not unanimous? 18 A There were a number, 19 Q How did you' determine that a rating of adequate 20 should be given over the objections of some of the other 1 21 RAC members? j 22 MR. CUMMING: This isn't what the witness testified t !O
r ~ 75 (b ~J; I to. He said there were disagreements..Are you asking now 2 were they -- 3 MR. ZANNLEUTER: Okay. _I will rephrase the 4 question. 5 MR. CUMMING: -- graded adequate? 6 BY MR. ZAHNLEUTER: (ContinuingT 7 Q I would like to know how differences were re-l 8 solved? 9 A Through discussion, hearing the. opposing points to 'of view with respect to an evaluation on a particular 11 . planning issue, the pros and cons. And after discussion O 12 when all parties were heard, I made the_ final determination 13 of what that rating should be. 14 Q Did the RAC members have an opportunity to review 15 this document after you made the rating but before it became 16 final? 17 A That's right. 4 18 Q And, :were there agr objections or comments noted? 19 A As part of the process we had sent different language on various matters that were still subject to further 20 21 discussion. That language and rating of differene plan l 22 elements was communicated to the RAC members that had ( i i
l-76 p. 'V -1 evaluations at variance to what the consensus was. So, in 2 answer to your question was, where there.were RAC members that had evaluation comments at variance to what the consen-3 4 sus.was, we made sure that we provided them. with the language 5 as the language was being formulated on a particular. element 8 and what the' final rating would be prior to the release -- 7 or prior to the final report being furnished from the 8 Regional Office to FEMA Headquarters, which is the way we 9 do. business routinely. 10 Q And on'the next page, Page 11 of 15, at the very. 11 bottom there is a reference to the new reception centers and 12' the statement says, "The adequacy of these facilities as reception centers must be evaluated at a future exercise." 13 14 Is that a remedial exercise that you are referring 15 to? 16 A No. I'm saying basically at a future exercise,- 17 since these facilities have not been examined nor used in 18 any exercise that was evaluated in February, whatever that to exercise date was. 20 Q Will that rating remain inadequate until it's 21 evaluated at an exercise? 22 A I think if you read the entire comment, it will O
77 ('b 1 ~ answer your question. You have to read all the paragraphs t 2 that relate to J.12. ~ 3 Q Can you answer that yes or no? 4 A What is your question so I can answer it yes or 5 no? 6 Q Will that rating of inadequate remain inadequate 7 until NUREG Element J.12 is tested at a future exercise? 8 liR. CUMMING: Objection. It calls for witness 9 to speculate, 10 To the extent that the question is intended to 11 state how may this deficiency be corrected, which I don'.t ('D 12 think is counsel's question, witness can answer. With N/ 13 respect to his speculation, he can answer to the extent he 14 has knowledge. is However, witness is instructed that unless he has 16 some knowledge I don't think he has, he is speculating.
- But, 17 he may speculate if that is what counsel for the State of 18 New York wishes him to do.
19 THE WITNESS: In answer to your question, seeing 20 it at a future exercise is not the only thing that would be 21 taken into account to fix this problem area. 22 BY MR. ZAUNLEUTER: (Continuing) C) V
78
- OV 1
Q Okay. Seeing it at a future exercise is one of 2 the things -- 3 A Yes. 4 Q -- that would be required? 5 A Yes. 6 Q Let's look at Page 13 of 15.where it says at the 7 top, "LILCO's commitment to provide training and equipment for exposure control to school bus drivers is understood." 8 9 What is your understanding? 10 A Just what it says here. 11 Q This means that the RAC understands what LILCO's G 12 commitment is? 13 A LILCO has in its plan said that it will provide the equipment, i.e., dosimetry and the training for all 14 that might be at risk in receiving doses beyond the PAG's 15 16 emergency workers. 17 And the last sentence that we put in there is 18 the crux of our concern regarding the matter of exposure 18 control training for school bus drivers. Q That last sentence is that, "...it is not evident 20 in the plan how these non-LERO workers are to be informed that 2 they need to initiate the request." 22 O
79 q(/ 1 A That's right. 2 Q Do you, and/or the RAC and/or FEMA, know what 3 training it is that LILCO is going to implement? 4 A You have to take the evaluation on the bottom of 5 Page 12 of 15 in concert with what is said in the first 6 sentence, "See review of Revision 5." You have'to look at 7 that plus what is stated here in order to get the full 8 meaning of our concern with respect to exposure control for 9 cmergency workers. to MR. MILLER: Excuse me. Can we take about a five 11 minute break? (') 12 MR. ZAHNLEUTER: Sure. Yes, this would be a 13 good time. 14 (Whereupon, a recess was taken at 4:50 p.m., 15 to reconvene at 5:20 p.m., this same day.) 16 BY MR. 7.AHNLEUTER: (Continuing) 17 Q Mr. Husar, I would like to refer you to Bernacki Exhibit 8, specifically the spread sheets which I believe is 18 19 to the RAC report, Page 1 of 16 for the LERO 20 EOC. 21 A Okay. Q Do you see the column headed "RAC Recommendation fo r 22 O d
80 g/ \\_ 1 Corrective Action?" 2 A Yes. a Q And the other column headed " FEMA Evaluation of 4 LERO Response?" 5 A Yes. i 6 Q Is there a substantive reason why one' column is -- 7 why one column refers to the RAC and why one column refers to 8 FEMA? o A It's not in all cases that we have to go back to ( 10 RAC to evaluate the response on the part of the constituency 11 we are dealing with, the state. In this case, let's say O 12 LERO. However, we certainly do provide the opportunity -- 13 in other words, we don't necessarily convene a meeting of 14 the Regional Assistance Committee when it comes time for us 15 to fill out that column. If we feel there is a need for us 16 to do that, we will. 17 In the case of Attachment 2, we did convene a 18 Regional Assistance Committee on the 25th, I believe it was, ID of November, 1986, wherein we did this_ evaluation.
- But, 20 it's not necessarily the case that we have to convene the 21 Regional Assistance Committee to fill out that column.
22 Q With respect to Shoreham and the review of O
81 O t Revision 7 and 8, the RAC did evaluate LERO's' responses -- 1 -2 A Yes, they did. 3 Q -. correct? 4 A Correct. 1 5 Q Do you see the column " Proposed Completion Date?" s For the dates that are entered in'these columns on this page 7 and all of the other.pages, do you know if LILCO has met a those completion dates? l 9 A Let me explain to you how to read this spread 1 j. to sheet. Basically, what we do, we send these spread sheets -- i 11 and these spread sheets relate directly to the exercise. l ($) These spread sheets are related 100 percent to the. exercise, 12 4 j 13 okay, for the record. 14 When we send these spread sheets to, in this case is they wound up with LERO, though I'm not sure -- with LILCO -- 16 how they did, you will find that what was completed that was 17 sent was the first column which is the number line item, I 18 the second column which is the NUREG element, the third t 19 column which is the RAC recommendation for correction action, l I and the next column, okay, the evaluation of that item. It 20 i 21 goes to, in this case, LILCO, okay. They then fill out the next two columns. And then 22 - ()
82 Ps V 1 We Put in the FEMA evaluation of the LERO response based on 2 what they say they are going to do and when they are going to do it. 3 4 In answer to your question, if it ain't done we 5 will so state if it's not completed. Strike what I just said. 6 If it is not completed, we will so state in our evaluation 7 that that deadline has not been met. a In answer to your question, unless we specifically 9 say that that deadline has not been met, and at the FEMA to evaluation column they have met that deadline and they have 11 submitted to us either a plan revision or the response in C) k-the LERO response action, to the extent to which they have 12 13 completed or responded to the recommendation. 14 So, for example, where the first line says, " Pro-cedures have been reviewed and revised to ensure information 15 on impediments is promptly passed to all relevant personnel to 17 and a coordinated response impicmented," if you look down is in the FEMA evaluation column beginning with the last 19 full paragraph, " Internal communications within the LERO EOC regarding assessment of and response to evacuation impediments 20 21 have been adequately addressed through modification to the procedures, especially OPIP 3.6.3," that was submitted. 22 O
83 O v 1 All right, as part of the LERO response action 2 and the schedule that was submitted. So, unless we say a specifically that they haven't met the proposed completion 4 date, they did. We have evaluated and concluded our evalua-5 tion in that column. 6 Q Look, for example, at the third from the last page, 7 which is Reception Center, Page 1 of 1. 8 A Okay. 9 Q The LERO response says, " Training material will be to modified..." And the proposed completion date is 9/1/86. 11 Do you know if LILCO has modified its training O 12 material as of 9/1/86? 13 A No, we do not. 14 Q So, then -- 15 A The commitment and the schedule, okay, we found, 16 to be an adequate response, as we have indicated in the 17 response. However, if you look at the final column, it's is still incomplete. 19 And now getting to my cross-reference here, I am saying that it's incomplete because there is training 20 21 involved and it has got to be shown during an exercise to 22 properly evaluate it. So, giving us the schedule as to when
84 O 1 they are going to conduct training is something that we have 2 accepted as being a reasonable response to a training issue that has been cited in the course of that exercise. a 4 And I can give you examples of that and how we 5 have treated that at other sites in this Region, both in 6 New Jersey and in New York. And what we say: Okay, this 7 7 sounds good and we may come down and sit in on your training 8 classes. 9 And both the State of New York and the State of ( to New Jersey have done that, where we found that there were 11 training inadequacies. We have, at our discretion, sat in O 12 on training classes and then also earmarked these matters as part of exercise objectives to be developed and elements 13 of the response capability to be tested at a future exercise. 14 15 Q With respect to these spread sheets, isn't it to that what has been rated adequate is the LILCO commitment or promise to train rather than the content of the training? 17 18 A That's correct. That is correct. 19 Q I would like you to refer now to Page 1 of 19 regarding the Patchogue staging area in the spread sheets. 20 21 A Okay. 22 Q The FEMA evaluation of LERO response states that,
n;b, ! n -l.z;- bif-80 1E -,u;; j,j' i 4 1 " FEMA and the RAC.have reviewed additional information supplied' 8 .( 2 Eby LILCO regarding this issue..." ~ Is that additional information Revision 9? c' 3 4 A ENo. There has been no' additional' revision to 5 the LERO plan submitted to us for review. s Q Do you know anything about Revision 97 7 A No, I do not. I've stated -- j s MR. CUMMING: Asked and answered. Witness may 9 antver again for the record if he wishes. to BY MR. ZAHNLEUTER: (Continuing) 4 11 Q What is this additional information that has been () 12 supplied by LILC07 13 A My recollection now is not clear. I would have. 14 to go back to the files and.get you the answer. 15 Q Does the fact that this information caused FEMA 16 to change a rating from a deficiency to an ARCA refresh 17 your recollection? 18 A I would have to go back to the files. 19 Q Do you recall why FEMA changed this deficiency 20 to an ARCA? j 21 A Based on the additional information, but now I '22 do not remember the time frame and that's why my recollection (
86 g) N~.,l 1 is not clear that this additional information was provided 2 and it was in connection with the -- LERO's response to the 3 exercise results. 4 I think what you should note also is that the 5 response was inadequate. 6 Q Well, I want to refer you to your notes which are 7 contained in Husar Exhibit 2 and specifically the note that 8 is entitled "ARCA Chart," and correct me if I'm wrong but 9 J.9 and J.10.G have under the Response column an A for I 10 adequate, right? 11 A No. A for ARCA. On the -- under Type it's A ( '~1 12 and that denotes ARCA which was the original evaluation of 13 the inadequacy, or the problem area. 14 Q What about under the column Response? Isn't there 15 an A under the column Response? 16 (The witness is looking at the document.) 17 A We are looking at Page 1 of 19, Patchogue staging 18 area? Is that where you are right now? 19 Q Yes. And why don't I ask it this way? Show me on your notes in Husar Exhibit 2 where the information on 20 21 Page 1 of 19 is contained? 22 A All right. Page 2 of my notes that you have just l l /; (J l l
87 (3 ) 1 identified is found on Page 1 of 19, Patchogue staging area. 2 What I see now is that I may have made a mistake in identify-3 ing that the res'ponse -- no, I did not. 4 Excuse me. I have identified it correctly. It 5 is an inadequate response, and the remedial action is also 6 (I) for incomplete. 7 What is your question? 8 Q I think that you have corrected my misunderstanding 9 already. Is there a reason why that (I) is circled? 10 A What I wanted to do is to circle all the elements 11 related to the exercise on the spread sheets, which ones 12 were evaluated as being inadequate responses just so that I 13 could key in on them. I didn't have a whole lot of consistency, as you can see because I didn't circle all of the (I's). But 14 is some of them I did. la It was my intent to circle them all so that I 17 would know which ones' were inadequately responded to based 18 on our evaluation. 19 Q Do you or the RAC or FEMA have any criteria that i you use when you change a deficiency to an ARCA? 20 21 A Yes. The way we go about evaluations are contained i 22 in Guidance Memoranda, and there are definitions for the O l l l l
88 O 1 term " deficiency," " area requiring corrective action," and 2 " area recommended for improvement." 3 Q-Does' that help you recall-what it was about this 4 particular correetive' action? 5 A No, it does not. At. 5:38 in the evening, it does 6 not. 7 Q Do any of your notes that are contained in Husar 8 Exhibit 2 or the file that you brought with you contain any-9 information with respect to this decision to downgrade a to deficiency to an ARCA? 11 A I've already answered your question. 12 Q Uhat was that answer? 13 A I don't recall, and I don't have it in my notes, end T2 14 I also should state for-the record that the spread sheets is relate to exercise findings, not all of which' I~have total 16 recall on. 17 Q Well, that's true. But the question that'I'm 18 asking you about is relevant to the column " FEMA Evaluation of LERO Response," which I think you explained before was 19 20 something that you filled out; isn't that correct? 4 21 A That's correct. 22 Q So this.would be within your conceivable knowledge, -O
'4 89 7,L) i correct? 2 A Yes'. Yes'. 3 Q Mr. Keller was a participant in the formulation 4 of this information under this column heading, wasn't he? 5 A Mr. Keller was part of the' meeting. And, yes, 6 Mr. Keller, as I explained at the outset how we use our 7 contractor personnel, did participate in his evaluation of 8 this element, in evaluation of this particular element. 9 Q I would like to ask you some questions about to Husgr Exhibit 2. 11 A Okay. k 'I 12 Q Could you describe for me~the' order in which 13 you have them in your file? In other words, which document 14 is first in your file? 15 And we will make that order the proper order for 16 the compilation of Husar Exhibit'2. Okay. So, which docu-17 ment is first? 18 A What should be first is the sheet of paper stating, " Listing, LILCO Transition Plan Summary Ratings of Inade-19 20 quacies." And that relates to Attachment 1 to Bernacki 21 Exhibit 8. 22 Q Okay. Which is the next? rm
>s s 90 ( )' 1 A Okay. And the.next one should be the one that 2 says "ARCA-Chart," and.that. relates to Attachment 2 to-3 Bernacki Exhibit 8. 4 Q Which is next? 5 at The next item should be " Plan Consolidation 6 Meeting, Rev 7 and 8, November 25, 1986." 7 Then,.there'is this half a page having to do-8 with Element J.12, Monitoring. If you can't read my writing, 9 that's what it should say.. 10 And, lastly'the piece of paper that says " Plan E 11 -Review History." . h_ 12 Q Now, that may be your last page but we were also 13 handed a document entitled "LILCO Transition Plan for 14 Shoreham - Revision 8." And I believe it has your hand-15 written notes.-- 16 A That's right. And that is exactly ~to-the word -17 and to the letter of Attachment 1, Bernacki Exhibit 8 with 18 my penciled notations on it. 19 Q So, that would be the last document in Husar 20 Exhibit 2? 21 A Yes. 22 MR. ZAHNLEUTER: Mr. Cumming, I think I should (
t. 2 2 1 - j, 1 91 1 note rightinow that on my copy at' least the. handwritten' notes 2 in'that last component of Husar Exhibit 2 are not' legible. 3 1I think that's probably because they are written in-pencil. 4 So, I would request perhaps - - 5 MR. CUMMING: Okay. It's. a. matter of xeroxing them. a 7 BY MR.'ZAHNLEUTER: (Continuing) 8 Q Now, Mr. Husar,.the first pagefthat you mentioned 9 in Husar Exhibit 2, would" you tell.me when' that was prepare'd to by you? 11 (Pause.) ^ Q%- 12 To the'bes~t of your knowledge. la A Some time last week, in the evening at home. 14 Q-What about the; next page? 15 A All right. The next page, I've mentioned that 16 I Prepared that on' Sunday, this past Sunday. l 17 Q And the next one? '~ i 18 A The next one, which is the Plan Consolidation Meeting, Rev 7 and 8, was prepared on the day of the meeting, 19 i 20 November 25th, 1986. 21 Q I have a few questions about this one. .22 A Okay. O L
t 'L 92 A,/ 1 Q In the second paragraph at the very end it says, 2 " List of Attendees ~, Attachment 1." 3 Is that by any chance the last document that we 4 have' compiled _under Husar Exhibit 17 I see you are holding 5 it up, sozit is? 6 A Yes'. 7 Q Okay. 8 A This is the' meeting attendance record.which has .9 been processed this date,-1/27/87, ~ 10' Q Then, underneath Roman Numeral II, Discussion, 11 there is a reference in parenthe'ses after ANL~to Attachment ~ O 12 2. 13 What is Attachment 2? 14 A.to Bernacki Exhibit 8. Attachment is 3 is the document that we made copies of earlier, dated February 6th, 1986, which-is the FEMA Internal Review. f 16 17 Q Excuse me. For the-sake of completeness, let's 18 insert that. Well, let's insert it as an attachment like l 19 it says in your notes. l-So, what -I've just inserted is the February 6th, 20 L 21 1986 -- 1. 22 A I'm sorry. I misspoke. Excuse me. I misspoke. ' /3 [ -V i l l
s, 93 1 . Attachment 111n'this piece of paper called " Plan Consolidation 2 Meeting," this is Attachment 1 to Bernacki Exhibit 8. 3 'are the spread sheets commonly 4 referred to as-the spread sheets which are Attachment 2 to 5 Bernacki Exhibit 8. 6 is this memorandum dated February 6th, 7 1986. 8 .And, Attachment 4 is a' document that we-have 9 discussed earlier which11s the~ RAC Review of Revision 5. ~ 10 Q And.on the~second page of your notes, there is a-11 reference'to Attachment 5. 12 MR. CUMMING: That's the letter that I referred la to earlier, the NRC/ FEMA communication that Mr. Bordenick 14 has taken under advisement as to whether~ he is going to 15 release it. 16 MR. BORDENICK: Are you going to be here tomorrow? 17 MR. ZAHNLEUTER: Yes. 18 MR. BORDENICK: I will let you know tomorrow. I have a call in to the NRC Region I attorney who was supposed 19 20 to check with someone and get back to me. And, unfortunately 21 I have not he~ard from him. I will try to reach him in the 22 morning. O
94 1 E / 1 MR. ZAHNLEUTER: Mr. Cumming, at this point I 2 have no further questions. However, I do not wish to adjourn a this deposition. I must review the ' documents which we just learned of during the deposition today that Mr. Husar brought 4 5 with him. And, I would like to review them. o And, depending on the outcome of that review it 7 may be necessary to recall Mr. Husar. So, at this time I 8 have no other questions. 9 But, the State of New York does not waive its 10 right to rec'all Mr. Husar. 11 Thank you, Mr. Husar. MR. CUMMING: Why don't we get to other questions 12 la first, and I have a closing statement. 14 MR. McMURRAY: I've just got a few questions. CROSS EXAMINATION indexx 15 BY MR. McMURRAY: 16 17 Q Mr. Husar, my name is Chris McMurray. I represent 18 Suffolk County. You mentioned earlier a Revision 9 to the LILCO 19 30 plan -- 21 A No, I did not mention a Revision 9 to the LILCO 22 plan. O
95
- \\
C/ 1 Q Well, I think that there was some mention -- 2 A Counsel for the' State of New York nentioned 3 Revision 9. 4 Q -- of Revision 9. And I believe that_you said you 5 had some knowledge of it although you may not have seen it. 6 Has anyone told you that a Rev 9 is coming? 7 MR. CUMMING: This question has been~ asked and 8 answered several times. 9 However, witness may answer to the extent he 10 has knowledge. 11 THE WITNESS: I have only heard casually, not ? j 12 from any source that I want to ascribe'any credence to, that 13 there is another revision coming. 14 BY MR. McMURRAY: (Continuing) 15 Q Have you been told what issues that revision 16 would address? 17 A No, not at all. Q Let me refer you to Bernacki Exhibit 8, Attach-18 ment 1, Page 11, under NUREG 0654, Element J.12, regarding 19 20 the reception centers. 21 Do you have that in front of you? 22 A I do. o .J l t
i 96 ,cG l' Q Other.than what is stated here~in the RAC review, 2 'has the RAC reached any further conclusions regarding the 3 adequacy or inadequacy of LILCO's proposed reception ~ 4 centers? 5 A In answering your question, it.has got to be taken 6 into account with respect to the RAC review'of the matter of 7 LERO reception centers. You would have to also read.that' 8 element in Revision 5 as is so stated in the first sentence. 9 In answer to your question, no, we have not made to any further determination'with respect to the.LERO reception 11 centers. [D 12 Q Just-so I understand your qualification, has there been any review to determine whether or not'the la facilities are physically capable'of handling'the number of 14 15 evacuees who might - go there for monitoring? 16 A I think that the last sentence on this page answers 17 your question. 18 Q Okay. Fine. Would your answer be the same for 19 the staff which LILCO has committed to those reception centers 20 under the plan? 21 A In answer to your question, I would like to bring your attention Page 12 of 15, the last paragraph under J.12, 22 A (/ l ( r
97 /~'T 1 (j. t wherein we are questioning the adequacy of the monitoring 2 capability in terms of personne1' resources to perform that-function'in that paragraph'. 3 4' Q Are'there'any documents other,tha'n this RAC review .5 which pertain to the J.12 element as it' applies to Rev 7 and 87 6 7 A Generated by FEMA or the RAC? 8 Q Or the RAC? 9 A The documents that do exist that relate to this . are the individua1' RAC comments that were ' submitted = that to it ultimately were fashioned and formulated into the' comments (~) 12 to the plan that you see' before you. s-13 Q Let-me go to the first sentence of the last para- ~ 14 graph -- I'm sorry, the second sentence which says, "It is 15 not adequate to plan.for this monitoring with personne1'and 16 equipment when available." 17 Does that mean that the' personnel that-LILCO has 18 not committed is not an adequate number'of personnel? 19 A If you read the next.-- in answer to your question, 20 if you read the next sentence I think it answer's your 21 question. "It is not possible'to evaluate the number of ~ 22 personnel required for monitoring at the special population 0
v i' t 98 >-5y-I reception centers' sin'ce:th'e~ plan shows in procedure OPIP 1 2 3.6'5,.pages-21 through^37, 'to be arranged' for most of the .a special population ~ rec'eption centers.'" -4 Q That just deals with special ; population' reception 5 centers, correct? ~ 6 A ' Correct. 7 Q Okay. 8 A And so with respect to the' general reception 9 centers, the thren that arefidentified on'Page 11 of.15, -10 Bellmore, Hicksville'and Roslyn,'the'same ques' tion does apply. We _ question ths number of personnel res~ources that 'would be 11 D d used to perform ths monitoring function and the associated 12 13 training. 14 In the' paragraph preceding that, ths last sentence of that paragraph, "This screening procedure is inadequate 15 since the applicable.~ guidance requires ~ the' capability of 16 monitoring within about a 12 hour period all residents and 17 transients in the' plume EPZ arriving at the reception centers. 18 19 Q Uhich member of the RAC is responsible, primarily 20 responsible, for evaluating this HUREG element, specifically 21 the issue ~of monitoring? 22 A You are talking about Region II or generically?
99 1 Q I'm talking about your RAC? 2 A Okay. Our RAC. Let me say that normally this 3 would be done internally. We do not have on staff a person 4 with those credentials. M C do MM
- bO (,,
N 5 Andrin-that-regard-that-is-horve use one--of-o r 6 contractor people, to provide that .vi e to us, that 7 technical service to us. 8 And, so it is not a RAC member per se who does it. loc., ctl6D M 9 -It'EB an individual who is under contract to FI2iA that has g% A 10 provided those kinds of services. 11 Q Would that be Mr. Keller? t 12 A Yes, it is. 13 Q With respect to the issues set forth on Pages 11 14 and 12 of Attachment 1, have you drawn any conclusions -- you personally -- regarding the adequacy of LILCO's reception 15 16 centers or the monitoring procedures different from what is 17 Stated here? 18 MR. CUMMING: Obj ec tion. Witness is testifying 19 in an official capacity. To the extent he has personal 20 knowledge, however, he is instructed to answer if he has 21 a personal opinion. 22 MR. McMURRAY: I'm asking him in his own official
t t f 4 3 +* _ ~ 100 ~ capacity as Chairman. I 2 THE WITNESS:. Could we'go off the record? 3 (Of f-the'-~re c~ord. ) 4 THE WITNESS: Please' restate the question.. ~ 5 BY MR. McMURRAY: (Continuing) e Q Do.you have 'any opinions regarding the adequacy of. 7 LILCO's reception centers other than.what.is stated in -- 8 on Page Lil of; Attachment 1 of Bernacki. Exhibit 8? 9 A No, I do not. 10 Q Is this an issue that the RAC intends to take a ~ closer look at-in the' future? 11 ~ MR. CUMMING: Asked and answered. _To the extent 12 13 .the witness has information -- it requires' speculation, but 14 if witness wishes to speculate he may so speculate. 15 -BY MP.. McMURRAY: - (Continuing)- 16 Q Let'me qualify that. Other than the statement 17 here about the nee'd for a future exercise, does' FEMA intend ~ to take any other steps to review the' adequacy of the reception 18 19 centers? 20 A FEMA will only pursue other work with respect to .the plan, the LERO plan, the LILCO plan, for Shoreham when 21 22 directed to do so. O
1 101 6I00P.M. 1 Q You have not yet been directed to do so? EVENING 2 A No, wo have not. 3 MR. McMURPAY: I take it, Mr. Cumming, that you 4 have compiled a comprehensive list of the documents that were 5 generated as a result of the reviews of Revisions 7 and 8? 6 MR. CUMMING: We are compiling it bas'ed on Mr. 7 Husar's files. And as soon as it is done, it will be made 8 available to all counsel. 9 This gets into the issue I was going to state for 10 the record again, that FEMA has provided this witness with 11 respect to Revision 7 and 8. FEMA does' not understand how [ ) 12 7 and 8 integrates into the OL-5 procee' ding, wishes to have 13 this testimony be considered and not be repeated with respect 14 to the OL-3 proceeding. 15 It has, despite the fact there is no formal 16 discovery request encompassing the testimony presented here today, furnished as many and as much of the documentation as 17 18 it feels it appropriately can at this point informally 19 without such a formal request. But it will take under 20 advisement and consider any formal request when it is, in 21 fact, received. 22 MR. McMURRAY: Mr. Cumming, your statement is 4
4 g ~ l 102 ..,O 1 incomprehensible 'to.me based'on 'the testimony-of your witness who drew a very clear' connection,between the; exercise re-2 ^ 13 sults and all the' matters : that Mr. Zahnleuter has discussed 4 today-regarding the' correc'tions. 5 I think we have'gone over this a lot. We don't. 6 need to argueL'it again. I understand your position. 7 MR. CUMMING: We understand your position, too. 8 I think the~ rec ~ord is clear. 8 MR. McMURRAY: I think in addition, there is no 10 basis for stating that the' governments'have' exhausted ~their 11 review of Revision 7 and 8 since the~re has not yet' been any- 'O 12 review by the' governments of the documents that were generated regarding Revision 7 and 8, nor have 'the~ governments been' 13 14 able to take'a close'look at the^ documents that we received l 15 today. 16 And, pending that we may very well have to come l back and review any documen'ts that we get in the future 17 l-18 regarding Revision ~7 and 8 or the reception centers. l 18 MR. CUMMING: I believe that has been stated about i five times by you or Mr. Zahnleuter on the record today, 20 21 but counsel for FEMA understands your position -- 22 MR. McMURRAY: In response to your five speeches. O
103 ,9 ~% 1 MR.. CUBMING : LAreithere:-any-other questions?L I 2 have at least one question. ~ 3 MR. MILLER: I'have'a few questions. indexx 4 CROSS EXAMINATION .5 BY MR. MILLER: 6 Q I would like to direct your attention to Husar 7 Exhibit 2, the' ARCA Chart which I believe is the second 8 document. 9 In the ~ column marked " Remedial Action" we have to already discussed what your notations in the' 'parenthe'ses 11 stand for. You'say that (E) ' stands for exercise and that 12 anything that is so marked-needs to be run through an -13 exercise. 14 I would like'to get a clea~r picture of what you is mean when you'say exercise. Does that mean that each'of 16 those modifications in the' plan need to go through a full-17 scale, full participation exercise or something less? For table-top drill? Would that be sufficient. 18 instance, i 19 MR. ZAHNLEUTER: I object to the form of that question unless we have 'a clear definition and understanding 20 21 of what is meant by those terms, full-scale and full 22 participation. O r i
1 104 b,, i MR. MILLER: IJwouldLjust like' Ar. Husar to explain 2 to me what he'means by the term " exercise." 3 MR. CUltiING: Well,s theSBoard in the December lith 4 Order said that FEMA witnesses could not speak ~to what is 5 a full participation exercise under NRC regulations.' 6 However, with respect to FEMA regulations to the 7 extent that the' witness has knowledge he may answer. 8 THE WITNESS: Are you saying that you would like 9 a definition of what an exercise is? 10 BY MR. MILLER: (Continuing) 11 Q' Right. Wha't type 'of drill could be ' required in p k-order to establish'the sufficiency of'the remedial action'-- 12 -13 I'm sorry, the sufficiency of the modification? 14 A I would say that in the' case ~of Shoreham and 15 in the case of the LERO plan, we want to see a fully inte-16 grated exercise'in order to properly. evaluate this. capability. 17 Q Are you saying then that it would not be sufficient is if there was a drill simply of that particular aspect of the 19 plan? 20 IE. McMURRAYi Objection. Asked and answered. 21 MR. MILLER: I'm just trying to clarify what his 22 statement was.
105 ~. ~ .,,b i THE WITNESS: l'y answer. again is, a. fully 2 integrated exercise is-what'we would be looking for with a a scenario tha't would: prompt; these kinds of res~ponse measures 4 -so that we'can properly evaluate the' adequacy.of the' plan 3 that treats those' planning criteria. 6 BY MR. MILLER: (Continuing) 7 'Q Is this your.own particular view? Is this the 8 Region'n view'or. FEMA. Headquarters' view?- 9 A I'm speaking to you'as the Cha'irman of the 10 Regional Assistance Committee, and that's the' official view. ~ 11 MR. MILLER: Okay. I have.no further questions. 12 MR. ZAHNLEUTER: No questions. 13 MR. CUMMING: I have one' question for the ~ indexx 14 record. 15 CROSS EXAMINATION '1 16 BY MR. CU12fING: 17 Q What various remedial actions are -- first of all, 18 let me state, because I don't believe tha~t the counsel for 19 either Suffolk or State of New York asked'thisg, question on j l 20 the record. 21 Did you, in fact, participate in any fashion in ~ 22 the exercise in February of 1986 with respect to the Shoreham O
. m 106 i WA t E 1 station?- 2 'A No, I did'not,',in"notway., So that you have no' personal knowledge-other Q 3 ~ ~ than of-the' rec ~ords that were'forwar'ded to you completing 4 5 the post-exercise asses'sment as'of:the, time you reassumed the RAC Chair? a 7 A That is correct. l 8 Q With respect to plan inadequaci~es, what' alternative 9 remedial ' actions' may be 'taken to. cure plan inadequacies under. ~ 10 current guidance, in your judgment? ~ 11 MR. McMURRAY: I obj ect'.: to the form of the pg - 12 question. It's vague. d ~ 13 Are'we talking about'any particular ones','or are i 14 we talking about just generic ones? ~ 15 MR. CGTfING: Generic. THE WITNESS: In order for us to pursue-further 16 ~ review or any othe~r kind of effort on the part of the 17 Regional Assistance Committee, we would have'to be directed' la 19 to do this by our National Office. 20 BY MR. CUMMING: (Continuing) 21 Q I don't believe that was my question. My. question generically for plan inadequacies', what metho'ds exist 22
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O 107 (~~'t s J: 1 by which those inadequacies may be~ correct'ed? 2 A Gener1cally speaking; what we'~would ask is for ~ ~ 3 a schedule of correc'tive action and we'would then have an 4 expectation to have' plan changes' submitted based on the 5 dates that the -- in this case, the utility submits, and 6 then we would evaluate'the submissions using the criteria, 7 the planning criteria, and make a determination..whether-those i 8 plan ~ modifications meet' the' standard. 9 Gener'ically, that's what.we would do. 10 Q With~ respect to guidance memorandum that existed 11 as of the date'that the' RAC reviewed Revisions 6, 7 and 8, Q 12 is that reflected in the package ~of November 13th, 1986 13 that.was discu~ssed previously was-in~your file? 14 A Yes.- All the guidance memoranda that are relevant 15 to LERO plans, okay, ha've been applied to our -- the RAC revie-e. j 16 of Revision 7 and 8. 17 MR. McMURRAY: Just for clarification, did you say, la Mr. Cumming, that we have been provided with those' guidance 19 memoranda? 20 MR. CUMMING: Yes. i 4 21 THE WITNESS: And to underscore the fact, the ones 22 that are relevant we have used. There are'some'that may not O I l-
108 h (G - 1 particularly applyLto Revision 7-and 8, 2 MR. CUl&i1NG: I have no further questions. 3 MR. McMUPJ1AY: I have~'no questions. 4 MR. ZAHNLEUTER: No questions. MR. CUMMING: End of dep~osition. 6 (Whereupon, the taking of the' deposition was 7 concluded at 6:07 p.m.,_this same~date.) 8 9 ,g 1; 10 11 'l IHOR W. HUSAR 13 SOS g p .upa COMM* on D N,, 17 19 20 21 22 O
109 \\_,i - 1 CERTIFICATE OF NOTARY PUBLIC AND' REPORTER 2 3 I, Garrett J. Walsh, Jr., the officer-before whom the 4 foregoing deposition was take~n, Pages' 1 through'108, do hereby certify that the~' witness whose testimony appears in 5 6 the foregoing deposition was duly sworn by me; that the testimony of said witnes's was taken by me and thereafter 7 reduced to typewriting by me or under my direction; that 8 said deposition is a true record of the testimony given by 8 10 the witness; that I am neither counsel for, related. to nor employed by any of the parties to the action in which this 11 7 V deposition was taken; and further, that-I am not a relative 12 or employee of any attorney or counsel employed by the 13 parties hereto, nor financially or otherwise interested in 14 15 the outcome 'of the ' action. 16 /g] 17 v GARRETT J. WALSH, JR. 18 A Notary Public in and for the g Commonwealth of Virginia at Large 20 My Commission Expires: January 9, 1989 21 22 v
..>b (q UNITED STATES OF AMERICA V NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: Morton B. Margulies, Chairman Dr. Jerry R. Kline Mr. Frederick J. Shon ) In the Matter of ) Docket No. 50-322-OL-3 ) (EP Exercise) LONG ISLAND LIGHTING COMPANY ) ) (ASLBP No. 86-533-01-OL) (Shoreham Nuclear Power Station, ) Unit 1) January 14, 1987 ORDER (Setting Discovery and Hearing Schedule) By Memorandum and Order of December 19, 1987, the Board reopened the record on Contention 24.0; determined that the reopened proceeding constitutes the mechanism for hearing and deciding the remanded Coliseum matter in ALAB-832; defined the issues in the reopened proceeding; and requested the parties to file proposed discovery and hearing schedules. Timely responses were filed by LILCO, Suffolk County, New York State and NRC Staff. The responses were carefully reviewed and due consideration has been given to the respective positions of the parties for the scheduling of discovery and hearing. Particular attention was paid to the matter of resources and the ongoing companion proceeding. The order requiring testimony to be prefiled was determined on the bases of the burden of O
i 2 the parties in the proceeding and the information that should be I available. I Based upon all of the foregoing, the Board hereby orders that: 1. The time for discovery will commence immediately and conclude on March 6, 1987. 2. LILCO's prefiled testiinony is due on March 23, 1987; Intervenors' on April 6,1987 and Staff's on April 13, 1987. 3. Motions to strike testimony are due April 20, 1987 and responses by April 27, 1987. 4. The due dates are the dates the documents are required to be in the hands of the Board and the parties. 5. The hearing will commence on May 4, 1987. FOR THE ATOMIC SAFETY AND LICENSING BOARD K Mort.anB.Margulies,plairma~n ACMINISTRATIVE LAW JUDGE %A1/A e @rry R. Mlinb RDMINISTRATIVE JUDGE cad / u-Frederick J. Shon ~ ADMINISTRATI F .DGE Dated at Bethesda, Maryland this 14th day of January,1987 g
ft'C/3A' g. $y # / ( O '$N,o Federal Emergency Management Agency 4 i s f Region II 26 Federal Plaza New York, New York 10278 .v DATE: January 5. '967 '1D40F A *:Dt'M rnR: Her!.-rt F 1. - r, 7 3.u " '.u t For.11 d E. B+ r n m;'r. Flui A Giardina E. . ' Fc;L Cher'/1 M a '. i n a Jo.veph H. Keller Thomas E. Baldwin Fobert L. Acerne ( FROM: Ihor W. Husar. Chairman Fec;onal A.ssistance Comm.ttee
SUBJECT:
Transmittal of RAC Review of LILCO's Tr an.s s t ion Plan for Shoreham. Revision 8. With' Attachments Enclosed please find the conso. dated RAC Plan Review forwarded by FEMA Headquarters to the Nuclear Regulatory Commission on December 30. 1986. Again, thank you for your assistance during the plan review process. I wish you and your families a healthy and happy 1987. i l i O
( ( t p i / Federal Emergency Management Agency T l, - Region II 26 Federal Plaza New York, New York 10278 .f 19 DEC 1966 MEMORANDUM FOR: Dave,cLoughlin De ty Associate 1 rector ate'a d cal' rograms and Support a ,/ FROM: orman S nlauf / Acting egional Director f
SUBJECT:
Transmittal of RAC Review of LILCO's Transition Plan, Revision 8, For Shoreham, With Attachments On July 16, 1986, FEMA received a request from the NRC to conduct 'a review of Revision 7 of the LILCO Transition Plan and of LILCO's responses.to FEMA's assessment of the February 13, 1986 Exercise of Revision 6 of the plan. On September 30, 1986, the NRC requested that FEMA include Revision 8 in its {h review'. ~ Attached, please find the consolidated RAC review as requested - in your memorandum to me dated October 6, 1986. In addition to reviewing Revision 7 and G, una smv uvavutiou 4.u uno,,.un ' internal evaluation of Revision 6 dated. February 6, 1986. These consolidated comments were reviewed and discussed at the November 25, 1986 RAC meeting. Please note that Attachment 2, Concerns Pertainina to LERO's i Authority, remains'as in the previous submission. The RAC, during its review, made the following assumptions: - LILCO would have the authority necessary to implement and manage this off-site emergency response plan. - All LERO personnel identified in the plan will substitute for representatives of Suffolk County, which is not participating in radiological emergency response planning for the Shoreham Power Station at i p this time. l l - This plan makes reference to the New York State Radiological Emergency Preparedness Plan (July, 1981). However, the LILCO Transition' Plan for Shoreham has been submitted without a State Site Specific Plan and, O, therefore, has no provisions for participation by New York Stato. - ~ - -
O The unique circumstances around which the Shoreham Plan is reviewed (i.e., no State and local involvement) effects the normal review process for nuclear power plants in Region II. For example: - Corrective action has not been followed for Shoreham, as there has been no Remedial Exercise since February 13, 1986. - LERO support facilities are in a state of flux. Nassau County has withdrawn use of the Nassau Coliseum as a reception center during a radiological emergency at Shoreham; WALK Radio has also withdrawn as the primary EBS station. - There has been no communication between FEMA Regional Office and the State on Shoreham. We understand that LILCO is preparing Revision 9 of the plan. In light of the unique circumstances regarding the () review of the Shoreham Plan, and the ongoing ASLB proceedings, we wish to suggest that a RAC review of future revisions of the LILCO plan would be premature, and at b'est, questionable until the official bodies involved have ruled on the issues. If you have any questions on this matter, please do not hesitate to call me. 2 Attachments O
( r f 4% / i Federal Emergency Management Agency u e e Region II 26 Federal Plaza New York, New York 10278 October 22, 1986 ? MEMORANDUM FOR: Members Pegional Assistance Committee 1 I ls M i lup <-- FROM: Ihor W. Husar, Chairman Regional Assistance Committee i
SUBJECT:
Shoreham plan Review Each of you should have already received Revision 6 to the Shoreham plan prepared by LILCO. You have already received from LILCO directly, plan Revisions 7 and 8. The last RAC review was of Revision 5. Revision 6 was submitted to you prior to the Shoreham exercise. Due to the time sensitivity of the action, i /~' NRC only asked for a FEMA internal review. NRC has now requested (_) and FEMA has agreed to a full RAC review of Revisions 7 and 8. I d am enclosing with this memorandum for your information and use, the FEMA internal review of Revision 6. J In order to meet the ASLB hearing schedule, I ask that you c* perform a formal plan review of plan Revisiens 7 and 8 and submit your written comments tv me by COB, November 14, 1986. Thereupon, we will have a RAC consolidation meeting on a date to be mutually agreed upon by phone during the week of October 27, ,9 1986. s I recognize these due dates will be difficult to meet in light of the exercise at Artificial Island on November 12, 1986 and any of your own work that you may have. If it is impossible for you to meet this schedule, please notify j me as soon as possible. ..I If you have any questions, please call me at FTS 264-8395 or 3276. b Enclosure _;(2) q e
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g6 p) g t ~ > j Federal Emergency Management Agency 3 -() ' $, [f Region 11 26 Federal Plaza New York, New York 10278 b o o February 6, 1986 MEMORANDUM FOR: SAMUEL W. SPECK ASSOCIATE DIRECTOR STATE AND LOCAL PROGRAMS SUPPORT FROM: FRANK P. PETRONE /k REGIONAL DIRECTO /
SUBJECT:
FEMA REVIE OF Tile LILCO TRANSITION PLAN FOR SHOREHAM, E' VISION 6 Per your request of January 22, 1986, FEMA Region II has completed an internal review of Revision 6 of the LILCO Transition Plan and our comments are attached. Elements identified by an asterick are affected by legal concerns.. If you have any questions concerning the results of our review, please call me. Attachment i O
m .s ~- V LILCO Transition plan for Shoreham - Revision 6 FEMA Review Dated February 7, 1986 NUREG-0654 Element _ Review Comment (s) Ratino A.2.b This element retrains inadequate. No material in Revision 6 address nis element. All comments in the RAC review of Revision 5 are still in effect. A.3 This element remains inacequate. 'All comments in 1* tne RAC review of Revision 5 are still in effect. In aedition, this revision recuires the accition of a letter of agreement witn the owners of the Brookhaven Multiplex Cinema for use of their property (parking lot) as a transfer ooint. The reviseo page B-vii shows tnis letter to be on page B-68 newever, page B-68 is the letter of agreement with the previous transfer point property owner. C.4 This element remains inadequate. See the review comments under A.3. J.9 This element is now rated adequate. Revisions to A of procedure OPIP 3.6.6 reflect the current FDA response level tables including all footnotes which are necessary for proper use of the numeric data contained in the tables. J.10 9 This element remains adequate. The designation of A of replacement transfer point required numerous changes to specify this new location. The plan changes are all involved with the logistics of the movements of buses for the transit dependent population wno need assistance in evacuating the EPZ. The new logistics do not change the concept of any orocedures. J.10.k This element remains inacequate. No material in 1" Revision 6 address tnis elemont. All comments in ene RAC review of Revision 5 are still in effect. T is element is inadecuately accressed in tne plan. In addition, concerns pertaining to LER0's legal authority to implement the plan were identified by the RAC curing the review of Revision 5 and are still in affact. O
) s t 't QJ a LILCO Transition Plan for Shoreham - Revision 6 FEMA Review Cated February 7, 1986 NUREG-065c Element Review Comment (s) Rating J.12 This element remains inadequate. As discussed colow I Revision 6 aceouately addresses two concerns raised by the RAC review of Revision 5. A new Attacnment 8 to procedure CPIP 3.9.2 gives a trigger levels for declaring items contaminated. This resolves the RAC issue of not having a trigger level for t'le interior of vehicles. Revision to the Plan on oage 4.2-1 and in procedures CPIP 3.9.2 anc 4.2.3 nave deleted all reference to a carticulate release as ceing a trigger for various actions. These enanges resolve a RAC issue. Drocecure Op!P 4.2.3 nas been completely rewritten. The new procedure gives a new evacuee traffic cattern and a new monitoring arrangement at the Nassau County Coliseum Reception Center. This new O aroc evr 's a a" t - This plan revision raises a new issue due to a change in procedure OPIP 3.9.2. In step 3.2 of the revised procedure, the statement is made that if a radioactive release has occurred, monitoring r oersonnel will be dispatched to special facility reception centers when available. t.ERO is o responsiele for monitoring all evacuees arriving at reception centers. It is not adequate to plan for this monitoring with personnel and equipment when available. It is not possible to evaluate the number of personnel required for monitoring at the special population reception centers since the plan shows in procedure OPIP 3.6.4 pages 21-37, "to be arranged" for most of the special population reception centers. Four (4) reception centers are shown whien are not the Nassau County Col i s e t.m. Monitoring personnel and equipment must ce available for these four (4) reception centers anc an other locations currently shown as "to be arranged". O
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pf $4cm $K M O (AST </ocox e}c -(/ /' LILCO Transition Plan for Shoreham - Revision 8 Key to Consolidated RAC Review Dated December 15,1986 Y The Regional Assistance Committee (RAC) review of the LILCO Transition Plan for Shoreham (Attachment 1) is based upon planning criteria specified in NUREG-0654, FEMA-REP-1, Rev. 1; Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, November,1980. The plan has been evaluated against each planning element specified in NUREG-0654 applicable to State and/or Local jurisdictions. These evaluations are keyed to the following rating system: 'o ADEQUATE RATING A (Adequate) A* (Adequate - concerns pertaining to LERO's legal authority identified during this review) The element is adequately addressed in The element is adequately addressed in A the plan. Recommendations for the plan provided concerns pertaining U improvement shown in italic are not to LERO's legal authority are resolved. mandatory, but their consideration The issues of legal authority affect-would further improve the LERO plan. Ing these elements are described in These recommendations include to the RAC review of revisions to the NUREG-0654 cross-Revision 5. reference, and other minor improvements. O haiii ie ii
m ~ y a OQ LILCO Transition Plan for Shoreham - Revision 8 Key to Consolidated RAC Review Dated December 15,1986 INADEQUATE RATING I (Inadequate) l' (Inadequate - concerns pertaining to LERO's legal authority identified during this review) The element is inadequately addressed The element is inadequately addressed in the plan for the reason (s) stated in in the plan for the reason (s)(not related bold type. The plan and/or procedures to legal concerns) stated in bold type. must be revised before the element can The plan and/or procedures must be be considered adequate. revised before the element can be considered adequate. In addition, concerns pertaining to LERO's legal authority were identified ( by the RAC, and are described in \\ Attachment 2 to the review of Revision 5. 3 Os
e m l J ATTACHMENT 1 (~} LILCO Transition Plan for Shoreham - Revision 8 V Consolidated RAC Review Dated December 15,1986 Page 1 of 15 NUREC-0654 Element Review Comment (s) Rating A. Assignment of Responsibility (Organization Control) ' A.1.a See review of Revision 5. A* A. I.b See review of Revision 5. A s A.1.c See review of Revision 5. A N-A.I.d See review of Revision 5. A* A.1.e See review of Revision 5. A T' :id - A.2.a See review of Revision 5. In addition, two (2) key A* l positions have been added to the LERO organiza-tion. The plan has been revised to add a traffic engineer i to the staff at the EOC to evaluate any possible impediments to evacuation and to make recom-mendations on necessary changes to evacuation routes in response to potential impediments. Another position, a LERO Spokesperson, and additional staff have been assigned to assure better coordination of information in the ENC. A.2.b See review of Revision 5. l' A.3 See review of Revision 5. In addition, the following I* comments pertaining to revised letters of agree-ment presented by LILCO with Revisions 7 and 8 are now applicable. Federal Aviation Administration (FAA) - A letter of agreement with the FAA has been withdrawn by LILCO since responsibility for notification of the i FAA has been shifted to the U.S. Department of Transportation (DOT) via FEMA as recommended in the review of Revision 5 of the plan. However, based on results of the February 13, 1986 exercise and the RAC review of subsequent plan revisions it
.~g m V ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 O Consolidated RAC Review Dated December 15,1986 Page 2 of 15 NUREC-0654 Element Review Comment (s) Rating A.3 is recommended that LERO notify FAA directly 1* (Cont'd) (see comments for element F.1.c in this review). In order to assure the most timely notification of FAA, LERO should again obtain a letter of agreement with FAA. American Red Cross - The letter dated August 21, 1986 submitted with Revision 8 of the plan states that "... there is no agreement between Long Island Lighting Company and this (Nassau County) Chapter relating to the chapter's responsibility to provide emergency assistance during a radiological emergency." This letter is not an acceptable letter of agreement to assure that American Red Cross responsibilities for Congregate Care facilities described in the plan will be carried out. Teledyne isotopes - The new purchase agreement with Teledyne isotopes, Appendix B, B-74A to 74D is an agreement for the routine Radiological Environmental Monitoring program. No indication of detection limits or any assurance that there will be capability for analysis in the event of an emergency could be located in the plan. There is some mention of 24 hour emergency analysis; however, this reference is in regard to routine samples being over prescribed limits. In response to an issue identified at the February 13, 1986 exercise, the plan has been modified to include notification of the Long Island Railroad (LIRR). These planning provisions are adequate but point of contact and telephone number for notification of the appropriate LIRR official (s) should be documented with a letter of understanding between LERO and the LIRR. Congregate Care Centers - Neither of the two (2) congregate care facilities activated for the February 13, 1986 exercise are identified in the
R,e im ) ~. ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 h Consolidated RAC Review Dated December 15,1986 Page 3 of 15 NUREC-0654 Element Review Comment (s) Rating A.3 latest submission of the LERO Plan. The Plan (Cont'd) should be revised to include all facilities intended for use as shelter facilities during a radiological emergency at SNPS. These facilities must be included in the list attached to LERO's letter of agreement with the American Red Cross. It is noted that OPIP 3.6.3, p. 2, mentions contacting the U.S. Coast Guard for helicopters 2 (paragraph 5.1.1.c). There is no mention of helicopters in the Coast Guard letter of agreement contained in the plan. Brookhaven Multiplex Cinemas -- The new letter of agreement for the use of the Brookhaven Multiplex Cinemas parking lot as a bus transfer point, Appendix B, B-68A-B-68E, is acceptable. g,, A.4 See review of Revision 5. A C. Emergency Response Support and Resources 6,,,u h C.I.a See review of Revision 5. A* I' v o I. 4c o, C.1.b See review of Revision 5. A L /: w.. ~~ cm C.I.c See review of Revision 5. A SV. a 'I F C.2.a See review of Revision 5. A I 8b.4, C.3 See review of Revision 5. A u. N.., e., m u,, r C.4 Specific reasons for the inadequate rating of this l' element are detailed in analysis comments for element A.3 in this review and the review of Revision 5. O D. Emergency Classification System CSH - D.3 See review of Revision 5. A
_r ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1986 1 Page 4 of 15 i NUREC-0654 Element Review Comment (s) Rating A % r e. ut u D.4 See review of Revision 5. A t E. Notification of Methods and Procedures .h Urle64mE.1 See review of Revision 5. A Pt s,,n 9 E.2 See review of Revision 5. A 6, v, n tw u p er E.5 See review of revision 5. In addition, it has come to A* j l '..,u,,'. <..S., FEMA's attention via the letter of transmittal for Revision 8 of the Plan that WALK has withdrawn from its agreement to serve as the Shoreham Emergency Broadcast primary station. Based on p) ( Revision 8 which includes WALK FM Radio, this element has been rated as adequate. However, in future reviews of the plan this element will be rated inadequate unless a suitable primary EBS station has been established and is supported with the necessary letter (s) of agreement. 4 N.. 63,,. g.\\ E.6 See review of Revision 5. It is recommended that A* n n, % 4, the EBS message recommending evacuation be revised to include a sentence urging people to be " good nelghbors" in an evacuation. Some suggested wording would be " Persons in the area to be evacuated are urged to be good neighbors and to l assist one another by sharing rides and otherwise helping others with problems." It is also } recommended that this same sentence be included in the public information brochure. t w,, p......, E.7 See review of Revision 5. A i F. Emergency Communications mk.cm.,, F.1.a See review of Revision 5. A
- J.,
F.1.b See review of Revision 5. A c ve'l n,, p,,
I s ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1986 Page 5 of 15 NUREC-0654 Element Review Comment (s) Rating p, i ;., u..., /,o F.1.c See review of Revision 5. In addition, the following I comments are now applicable. A letter of agreement with the FAA has been withdrawn by LILCO since responsibility for notification of the FAA has been shifted to the U.S. Department of Transportation (DOT) via FEMA as recommended in the review of Revision 5 of the plan. Ilowever, based on results of the February 13, 1986 exercise and the RAC review of subsequent plan revisions it is recommended that LERO notify FAA directly. In order to assure the most timely notification of FAA, LERO*snould again obtain a letter of agreement with FAA. The plan, has been modified to include notification of the Long Island Railroad (LIRR). Procedure OPIP 3.3.2 Page 4 of Attachment 4, instructs the Support Services Coordinator to contact the LIRR at the Alert, or higher emergency classification, and to request closure of parts of the mainline if evacuations are called for in certain sectors. Figure 3.3.4, page 4 specifies that the Long Island Railroad will be notified at the Site Area Emergency and/or General Emergency ECLs. The LIRR should also be added to Figure 3.3.3 and to the notification diagram shown in Figure 3.3.5. 0 -f'i F.1.d See review of Revision 5. A L.i. t c F.1.e See review of Revision 5. A g g p,.,
- p., '. A M ' --
,,, ;. 3. (, , F.2 See review of Revision 5. A t.a M h." 4 i,.,,, s F.3 See review of Revision 5. A* '{ L, f. y 2...,.
A'ITACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 3 Consolidated RAC Review fC' Dated December 15,1986 Page 6 of 15 NUREC-0654 Element Review Comment (s) Rating G. Public Education and Information P G.I.a-d See review of Revision 5. It is recorr, ended that A the public information brochure include nr. formation g. to encourage boaters in the EPZ to listen to Chanel 16 so that they can receive radio notification in the event of an emergency at Shoreham. ,Ap i., s.G.2 See review of Revision 5. A h.3 i u .s G.3.a See review of Revision 5. A* G.4.a See review cf Revision 5. A g,4,,g., T,_ m %,.,G.4.b See review of Revision 5. In addition, the following I / w,s; r comments are now applicable, t nem WA.' " ' * $ Insufficient copying capabilities at 'the ENC resulted in delays in the distribution of information during the February 13,1986 exercise. These delays affected the following two (2) areas: Hard copies of EDS messages were not provided to the media in a timely manner. Rumor control personnel were not able to answer questions received from the public because they were not given accurate up-to-date status reports. LERO should make provisions for reliable and rapid equipment to reproduce, in hard copy, all appro-priate messages for distribution to the ENC staff. The plan has been modified to create an additional position, LERO Spokesperson, and additional staff have been assigned to assure better coordination of information in the ENC. The LERO spokesperson is responsible for coordinating the release of infor-7 mation working in conjunction with the County Executive, or his designee, if he chooses to
/ ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1986 Page 7 of 15 NUREC-0654 Element Review Comment (s) Rating G.4.b participate. The LERO spokesperson will represent (Cont'd) LERO at press conferences. Press releases are to be distributed to utility, government and media personnel at the ENC. As provided in OPIP 3.8.1, Section 5.2.4, changes in important emergency information will be elec-tronleally transmitted to Rumor Control District offices and call boards via TSO printout (also see OPIP 3.8.1, Section 5.3.4). LILCO is still evaluating the lack of hard copy capability for distribution of EBS messages to the press in the ENC. Until LILCO completes the evaluation of this equipment for providing hard copies of EDS messages to the media, the response to this element is rated inadequate. Also see comment for element G.4.c in this review. L'+. 7, M G.4.c See review of Revision 5. This element is rated I r u,w.e A. Inadequate for the same reason given for element G.4.b of this review. k*O G.5 See review of Revision 5. A L.a,.sp 7 ew s II. Emergency Facilities and Equipment 5... A F E 11.3 See review of Revision 5. A 'I
- w n \\..'
'4 11.4 See review of Revision 5. A* o.- A : i., ;.... J ,o h.,;,,.; <
- II.7 See review of Revision 5.
A g m.,... :...w I' , I.10 See review of Revision 5. A h II. I' 1 See review of Revision 5. A i A c,. 7"7 ' II.12 See review of Revision 5. A U-N Y-( \\ q., .4, ~V . ec. ,11 f dh ', i
l. Q ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 7(d Consolidated RAC Review Dated December 15,1986 Page 8 of 15 NUREG-0654 Element Review Comment (s) Rating I. Accident Assessment I :.,* % ; " '/'d 1.7 See review of Revision 5. A
- u.........,
t ,.n... -. N$ .8 See review of Revision 5. A v % I.9 See review of Revision 5. A ti'+L i. { d d (!.10 T See review of Revision 5. In addition, two (2) plan A ^ - W '- changes have been made to address issues identified en -, u % L at the February 13,1986 exercise. ...... 3,. % 4 < i j The plan has been modified in OPIP 3.5.2 Section 3.6, to require that when field data are received, the data is identified as an actual measurement or as extrapolated data. All extrapolated data are now to be posted under " projected data" on the status board. Procedure OPIP 3.5.2, Section 3.5 has been revised to specify that all distances reported by DOE-RAP teams are to be recorded in miles. a f. '- } I.11 See review of Revision 5. A ~ae J. Protective Response ?. s.,,,. . - J.2 See review of Revision 5. A p(<;,.,, A See review of Revision 5. In addition, the following (1) J.9 p, . s. :. N....u 3 comments are now applicable. Le,.,... rto c..s Revisions to Attachment 1 of procedure OPIP 3.6.6 reflect the current FDA response level tables including all footnotes which are necessary for proper use of the numeric data contained in the tables.
O ATTACHMENT 1 v s LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1986 us Page 9 of 15 NUREC-0654 Element Review Comment (s) Rating J.9 As discussed in the Post Exercise Assessment of the (Cont'd) February 13, 1986 exercise, delays were observed in the dispatch of bus drivers due to delays in issuing dosimetry and in the briefing of bus drivers and transfer point coordinators. This element is rated inadequate until the plan is revised to accomplish timely distribution of dosimetry to the large number of Bus Drivers required to be dispatched from the Patchogia Staging Area. This inadequate rating also affects element J.10.g of this review. IA w~6 J.10.a See review of Revision 5. In addition, Procedure A*') OPIP 4.2.5 provides details on the set up and use of L1LCO's B__ellmore, Hicksville and Roslyn Operations Centers as reception centers for evacuees in the event of Shoreham radiological emergency. ) k/u4Es,-{,J.10.b See review of Revision 5. 2 :,n k. > A J.10.c See review of Revision 5. x A* ,Y $.vyb r pg.f..;t.-J.10.d See review of Revision 5. A v t..., t J J.10.e See review of Revision 5. Several issues involving Il W,,t, emergency worker knowledge and use of KI were identified at the February 13, 1986 exercise. This element has been rated inadequate because bus drivers used for school evacuation have not been trained in KI policy and the use of KI. Sufficient supplies of K! are not available for school evacuation Bus Drivers. (1) Bus Drivers used for school evacuation should be trained in K! policy and the use of KI. (2) Adequate supplies of K! should be provided for Bus Drivers used for school evacuation. LILCO's commitment to provide training and equip-ment for exposure control to school bus drivers is
V ~ ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review O Dated December 15,1986 Page 10 of 15 NUREC-0654 Element Review Comment (s) Rating J.10.e understood. Ilowever, it is not evident in the plan (Cont'd) how these non-LERO workers are to be informed that they need to initiate the request. '. J.10.f M..~,..<.. See review of Revision 5. A* [ J.10.g See review of Revision 5. This element is rated I 't inadequate for the same reason given for the inadequate rating of element J.9 in this review. }',,.. J.10.h The letter from the American Red Cross to LILCO I J dated August 21,1986 (see Appendix B pages B-11 to Bil-d), states that the American Red Cross has not agreed to respond to a radiological emergency O at Shoreham (see lines 1-4 page B-11a). Page B-11b implies that the American Red Cross only works with nnd through the government. It also states that letters of agreement between the American Red Cross and owners of a facility to be used as a shelter will be entered into at the time of an incident. This policy is unworkable. The new material submitted for Appendix B raises many questions concerning the participation of the American Red Cross in a Shoreham incident, not only in the operation of shelters but also in connection with EOC participation. It is FEMA's position that letters of agreement are required for all facilities which are planned to be used in an emergency response. E ' 4. J.10.1 See review of Revision 5.
- bket, A
J.10.) See review of Revision 5. A* u sw \\ q. f.1/.10.k This element has been rated inadequate for the 'l*)
- p'[(i reason (l.c., snow removal resources and procedures) l,
speelfied in the review of Revision 5.* p +, :,* s
- It should be noted that one (1) RAC member felt that this element should be rated adequate (A). (,h)lf,d.
I
V$r 3 d V ATTACHMENT 1 { LILCO Transition Plan for Shoreham - Revision 8 / Consolidated RAC Review Dated December 15,1986 Page 11 of 15 NUREC-0654 Element Review Comment (s) Rating J.10.k In response to an exercise issue, the plan has been (Cont'd) revised to add a traffic engineer to the staff at the EOC to evaluate any possible impediments to evac-ation and to make recommendations on necessary changes to evacuation routes in response to poten-tial impediments. Procedures for field workers, i.e., bus drivers, traffic guides, etc., have been modified to include instructions to make prompt notifications through their communication network of any potential impediment. Provisions have been made to issue an EBS message in the event that changes to evacuation routes are necessary. Internal communications within the LERO EOC regarding assessment of an response to evacuation impediments has been adequately addressed through modification to the procedures (esp. OPIP 3.6.3,- Traffic Control). The Evacuation Route coordinator is responsible for obtaining periodic updates from the Evacuation Route Spotters, and for immediately reporting road impediments or other problems to the Traffic Control Coordinator and Road Logistics Coordinator (See OPIP 3.6.3, Section 5.6.7) Lead Traffic Guides (at the staging areas) are to report any incident. L t *.. ".. J.10.1 See review of Revision 5. A L,j 4., 4, v......c.:.h ').10.m See review of Revision 5. A
- 3 pgw x.4 J.11 See review of Revision 5.
A .s-( h p;,,,..,C',{J.12 See review of Revision 5. In addition, the following h' F ~ comments are now applicable. ,j g..... * * * "' o The LERO Reception Center previously designated at the Nassau County Veterans Memorial Coliseum O { has been changed to three (3) LILCO facilities tec i o i 8 m att. ><ie* iiiis e ae iv=. Tae .i 4 adequacy of these facilities as reception centers i must be evaluated at a future exercise. f -ww- -, - - - - -
q ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 g3 y Consolidated RAC Review Dated December 15,1986 Page 12 of 15 a NUREC-0654 e Element Review Comment (s) Rating J.12 In addition to the change of Reception Center (s) (Cont'd) location, the plan specifies (see page 3.9-5 of Revision 8) that a screening process will be used to check evacuees for contamination. Incoming vehicles will be directed to monitoring stations where the vehicle and driver will be checked for contamination. According to this screening procedure, passengers of the vehicle will also be assumed to be uncontaminated and a clean tag will be issued to them if the driver is below contamina-tion limits. This screening.prpcedure_la.inadequale l j sinca the applicablejuld, ance_rgguires the c_apability ? of monitoring within about a 12 hour period allf residents andjansients in the_ plu,me EPZ arrig at the Recepiiog Qg!11.qrs. t LERO is responsible for monitoring all evacuees arriving at reception centers. It is not adequate to plan for this monitoring with~ personnel and equipment when available. It is r.ot possible to evaluate the number of personnel required for I monitoring at the special population reception (' centers since the plan shows in procedure OPIP 3.6.5 pages 21-37, "to be arranged" for most of the i special population reception centers. K. Radiological Exposure Control l K.3.s See review of Revision 5. Several issues involving emergency worker knowledge and use of dosimetry 2 M W N.wd H b W.s. a were identified at the February 13, 1986 exercise. .i b e,. n e A l W C...;,4 y This element has been rated inadequate because p.s-nd dosimetry and training were not provided to the Bus Drivers used for school evacuation. (1) Bus Drivers used for school evacuation should be trained in the use of dosimeters. (2) Adequate supplies of dosimetry should be i provided for Bus Drivers used for school evacuation. 's
A'ITACHMENT 1 1 f] LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1986 { Page 13 of 15 NUREG-0654 i Element Review Comment (s) Rating j K.3.a LILCO's commitment to provide training and (Cont'd) equipment for exposure control to school bus drivers is understood. However, it is not evident in the plan how these non-LERO workers are to be informed that they need to initiate the request.
- h. A. *I K.3.b See revies. of Revision 5.
This element is rated I f M '; *bs, ( inadequate for the same reason given for element ' ' ' ' i " ^ / K.3.a in this review. 4. ',,. K.4 See review of Revision 5. This element is rated I CW g. Inadequate for the same reason given for element a K.3.a in this review. .., p,,,,, w f u y ex ~<.%. C {,,,L..e,c y,Q K.S.a See review of Revision 5. A mn,< y j,,g, K.S.b See review of Revision 5.- A he-l L. Medical and Public Health Support Le,\\ g Ld., L.1 See review of Revision 5. A j L. s W j g g,z , L.3 See review of Revision 5. A l L.p.%'W r ~ + ; * I' L.4 See review of Revision 5. A .:.qw
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- 2 M.
Recovery and Reentry Planning and Postaccident Operations M... M.1 See review of Revision 5. A k- " U ~ M.3 See review of Revision 5. A / ~ n.,.a*y I'<. i f+t. M.4 See review of Revision 5. A dfy A r<v Q.s N. Exercises and Drills I* ' % d N.1.a See review of Revision 5. A* e,o_. m. j LW O +-~ N. I.b See review of Revision 5. A* e. v' i.4. : <..,(
r' ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1986 Page 14 of 15 NUREG-0654 Element Review Comment (s) Rating ( ,.s-
- 3. c N.2.a See review of Revision 5.
A h,. t. - ) N.2.c See review of Revision 5. A s, s N.2.d See review of Revision 5. A g,,. - iG m. *, - N.2.e.(1) See review of Revision 5. A L.. S f.- ,\\N.3.a-f See review of Revision 5. A y.... .V N.4 See review of Revision 5. A 4, g..,. /.a,uf,)rN.5 See review of Revision 5. A b O,... t' h., eO. Radiological Emergency Response Training O.1 See review of Revision 5. A J. '. ) h O.1.b See review of Revision 5. A a v.- c.'g See review of Revision 5. In addition, it is A M**l g,u,.,0.4 D suggested that LILCO consider requiring that training be provided per module 11 to personnel assigned to the Emergency Worker Decontamination Facility and the Reception Centers. It would also be adviseable to consider requiring training per module il for personnel assigned to the following positions: Emergency Medical Coordinator, Hospital Coordinator, and Ambulance Coordinator. ?!/,, 0 0.5 See review of Revision 5. A c P. Responsibility for the Planning Effort N,wu n P.1 See review of Revision 5. A* b D d...j,g P.2 See review of Revision 5. A* .a.. <,. m g y.... g wr-P.3 See review of Revision 5. . A* r % g, m. f' P.4 See review of Revision 5. A*
t 3 s ) ~J ~- ATTACHMENT 1 - LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1986 Page 15 of 15 NUREC-0654 Element Review Comment (s) Rating i P See review of Revision 5. A* r;...,,,.,, g.5 auf, Jp t 4 E.6 See review of Revision 5. A P g, A i.w.et-- .7 - See review of Revision 5. A A g.. ,a. .. -n... ,,,; a,.9 si. h, r f.x P.8 See review of Revision 5. A ,b.' . cec.1w r s. L '",,o s P.10 See review of Revision 5. A e b y,,...
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