ML20211D164
| ML20211D164 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/14/1987 |
| From: | Schwartz S, Weiss B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| References | |
| CON-#187-2551 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8702200340 | |
| Download: ML20211D164 (126) | |
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G OF PROCEEDINGS,19 PS:27 UNITED STATES OF AMERICA NE -
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'l NUCLEAR REGULATORY COMMISSION 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
~
'v' DEPOSITION OF SHELDON A.
SCHWARTZ AND BERNARD H.
WEISS Bethesda, Maryland Wednesday, January 14, 1987 ACE-FEDERAL REPORTERS, INC.
Stenotype Reporters 444 North Capitol Street g
Washington, D.C. 20001 (202)347-3700 Nationwide Coverage 8702200340 870114 800-336-6646 PDR ADOCK 05000322 lY PDR
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION O
H A OM A
AND LICENSING BOARD 3
- - - - - - - - - - - - - - - - - -x 4
In the Matter of:
Docket No. 50-322-OL-5 5
LONG ISLAND LIGHTING COMPANY (EP Exercise) 6 (Shoreham Nuclear Power Station, (ASLBP No. 86-533-01-OL)
Unit 1) 7
- - - - - - - - - - - - - - - - - -x 8
DEPOSITION OF 9
SHELDON A.
SCHWARTZ AND BERNARD H.
WEISS 10 Bethesda, Maryland 11 Wednesday, January 14, 1987 12 Deposition of SHELDON A.
SCHWARTZ and BERNARD H. WEISS, called for examination pursuant to notice of deposition, at the 14 offices of the United States Nuclear Regulatory Commission, 15 7735 Old Georgetown Road, Ninth Floor Conference Room, at 16 10:00 a.m.
before KATHIE S.
WELLER, a Notary Public within and 17 f r the State of Maryland, when were present on behalf of the respective parties:
19 DONALD P.
IRWIN, ESQ.
LEE B.
ZEUGIN, ESQ.
Hunton and Williams 20 707 East Main Street P.
O.
Box 1535 21 Richmond, Virginia 22312 On behalf of Long Island
(
22 Lighting Company.
-- continued --
ACE-FEDERAL REPORTERS, INC.
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APPEARANCES (Continued):
2 KARLA J.
LETSCHE, ESQ.
SUSAN M.
CASEY, ESQ.
3 Kirkpatrick & Lockhart South Lobby, Ninth Floor 4
1800 M Street, N.W.
Washington, D.
C.
20036-5891 On behalf of Suffolk County.
6 BERNARD M.
BORDENICK, ESQ.
ORESTE PIRFO, ESQ.
United States Nuclear Regulatory Commission Washington, D.
C.
20555 8
On behalf of the Nuclear Regulatory Commission Staff.
9 RICHARD J.
ZAHNLEUTER, ESQ.
10 Deputy Special Counsel to the Governor 11 Executive Chamber
')
Capitol, Room 229 Albany, New York 12224 12 On behalf of the State of New York.
13 14 WILLIAM R.
CUMMING, ESQ.
Federal Emergency Management Agency 15 500 C Street, S.W.
Washington, D.
C.
20472 16 On behalf of FEMA.
17 ALSO PRESENT:
18 RONNIE LO MELINDA MCDONALD U.S.
NRC 19 20 21
()
22 ACE-FEDERAL REPORTERS, INC.
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CONTENTS 2
WITNESS EXAMINATION 3
Sheldon A.
Schwartz and Bernard H. Weiss 4
by Mr. Irwin 5
5 by Ms. Letsche 43 by Mr. Zahnleuter 68 by Mr. Irwin 70 6
by Ms. Letsche 70 by Mr. Bordenick 71 7
8 EXHI BITS NUMBER IDENTIFIED 9
Exhibit 1 13 10 Exhibit 2 13 11 Exhibit 3 14 i
'~
12 Exhibit 4 19 Exhibit 5 21 13 Exhibit 6 41 14 15 16 17 18 19 20 21 (j
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PROCEEDINGS.
2 MR. IRWIN:
My name is Don Irwin, counsel for Long 3
Island Lighting Company.
We're taking the deposition of 4
Sheldon Schwartz and Bernard Weiss pursuant to agreement with 5
the NRC and in response to answers provided by the NRC to 6
interrogatories from Long Island Lighting Company in the 7
Shorehan case.
8 It is now 10:00.
Notice has been given to all 9
parties.
Representatives of all parties except for Suffolk 10 County and New York State are present.
I propose that we go 11 off the record for five minutes to allow them to be present,
{}
12 and if they are not here, we'll just resume.
13 MR. BORDENICK:
That's agreeable.
You might point 14 out no representative of the town of Southampton is here.
15 MR. IRWIN:
That's true.
However, a 16 representative of FEMA is here.
17 (Discussion off the record.)
18 MR. IRWIN:
Back on the record.
19 It is now five minutes after 10:00.
We have l
20 i received no indication of the arrival of representatives of 21 Suffolk County, New York State or the town of Southampton.
22 Mr. Pirfo of the NRC Staff has been in the lobby since 10:00 ACE-FEDERAL REPORTERS, INC.
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awaiting their arrival.
I propose to begin the deposition.
2 Would you swear the witnesses?
3 Whereupon, 4
SHELDON A.
SCHWARTZ 5
and 6
BERNARD H.
WEISS 7
were called as witnesses and, having first-been duly sworn, 8
were examined and testified as follows:
9 EXAMINATION 10 MR. IRWIN:
Would you state your names, please.
.{ }
11 WITNESS WEISS:
Bernard H. Weiss.
12 WITNESS SCHWARTZ:
Sheldon A.
Schwartz.
-13 MR. IRWIN:
Mr. Weiss and Mr. Schwartz, I'm Donald.
14 Irwin.
I'm counsel for Long Island Lighting Company.
I will 15 be taking this deposition.
You have been proposed as 16 deponents pursuant to answers provided by the NRC Staff to 17 interrogatories filed by the Long Island Lighting Company in 18 which you were designated as persons knowledgeable about the 19 meaning of the phrase " full participation exercise."
20 l I show you a copy of a document entitled "NRC 21 Staff Response to LILCO's Motion for Discovery of the NRC 22 Staff" with an attachment labeled "NRC Staff Answers to LILCO O
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1 Interrogatories" of December 19, 1986'^1and I'Dnvite your
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2 attention to the answers to those interrogatories, 3
Interrogatory 1 and Interrogatory 2.
'y Haveyougentlemenhadanopportunitytorehiew 4
t t
5 this document prior to today?
N 6
WITNESS WEISS:
Yes.
,f 7
WITNESS SCHWARTZ:
Yes, I have.
8 MR. IRWIN:
Are the answers provided in this 9
document correct to the best of your knowledge?
10 WITNESS WEISS:
Yes.
,(}
11 WITNESS SCHWARTZ:
Yes.
12 MR. IRWIN:
Let me indicate three brief ground 13 rules of this deposition.
The first is that I will -- when I 14 ask a question I will assume that you understand it unless 15 you ask me for clarification.
The second is that I will 16 address you as a panel unless the sense of the company 17 obviously indicates otherwise, and the two of you should feel 18 I free to respond as your knowledge commands.
The third is, as i
l 19 l I indicated earlier, you have been proffered by the 20 Commission as -- let the record note the arrival of
- we 21 !
were just getting into introductions.
22 f (Discussion off the record.)
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1 MR. IRWIN:
Let's go back on the record.
x 2
The third ground rule which we have already 3
covered is that you all have been designated by the Staff as.
4 being knowledgeable about the meaning of the term " full 5
participation exercise," and that will be the subject matter 6
of our discussion t his morning.
7 Mr. Weiss, would you state your position with the 8
NRC Staff and business address, please.
9 WITNESS WEISS:
Federal response coordinator, NRC
-10 office of Inspection and Enforcement, 7735 Old Georgetown
(}
11 Road, Bethesda, Maryland.
12 MR. IRWIN:
State the le gth of time in your 13 present position, please.
14 WITNESS W'JISS :
About five years.
15 MR. IRWIN:
Can you describe briefly your 16 responsibilities with respect to off-site emergency planning 17 at the NRC and the length of time you have been involved in 18 off-site emergency planning?
19 WITNESS WEISS:
I'm responsible mainly for the t
20 !
manner in which the NRC responds to an emergency and how we I
l 21 !
integrate our response with the other federal agencies.
I h
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22 I have been responsible for the design and conduct of several
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1 exercises, particularly the federal field exercise in 1984, 2
and many of the other exercises that,we run here to train our 3
staff.
4 MR. IRWIN:
Federal field exercise in 1984, can 5
you describe that more particularly?
6 WITNESS WEISS:
That was a large-scale exercise 7
involving St. Lucie in which most of the federal agencies 8
that would participate in an actual emergency actually ran a 9
field exercise, went into the field and played there in 10 conjunction with a full-scale exercise conducted by St.
' (}
11 Lucie.
12 MR. IRWIN:
Your reference to having participated 13 in several or many or numerous other exercises as well, were 14 these exercises conducted at commercial nuclear power 15 plants?
16 WITNESS WEISS:
Yes.
17 MR. IRWIN:
Can you give me an idea of 18 l approximately how many exercises there have been and over 1
19 what period of time that you either participated in the 20 development of or the observation of?
t 21 I WITNESS WEISS:
Over the last four or five years, 22 I would guese maybe 15 to 20 exercises.
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MR. IRWIN:
Of these, have any of these been full 2
participation exercises or been intended to be full 3
participation exercises?
4 WITNESS WEISS:
My understanding is that they 5
.were.
6 MR. IRWIN:
Did you participate in the development 7
of scenarios or objectives for any of these exercises?
8 WITNESS WEISS:
Yes.
In some cases.
A limited 9
amount of scenarios, generally with regard to NRC's 10 participation, i
11 MR. IRWIN:
With respect to these exercises, did
{}
12 your role include any responsibility for assessment of 13 whether the exercise would be a f
'l participation exercise 14 within the scope of --
15 WITNESS WEISS:
No.
16 MR. IRWIN:
From your knowledge or your experience 17 do you have a general understanding of how the term " full 18 participation exercise" has been used to implement the 19 Commission's regulations?
j 20 WITNESS WEISS:
A general understanding.
I 21 !
MR. IRWIN:
How have you arrived -- by what r^g 22 l process have you arrived at that understanding?
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' WITNESS WEISS:
Generally, by participation in 2
these exercises, but I have not been involved in the 3
licensing end of this.
4 MR. IRWIN:
But how does participation in these 5
exercises give you an understanding of'the meaning of a full 6
participation exercise?
7 WITNESS WEISS:
Generally in the writing of an 8
exercise is an understanding of the exercise which defines 9
what it is in the exercise that will be arccomplished.
10 MR. IRWIN:
Mr. Schwartz, could you state your i
11 position and your business address with the NRC.
(}
12 WITNESS SCHWARTZ:
I'm deputy director, Division 13 of Emergency Preparedness and Engineering Response at the 14 Nuclear Regulatory Commission, Office of Inspection and 15 Enforcement, Washington, D.C.
That's the easiest way to 16 answer that.
My current position as deputy director, about i
17 three years.
18 MR. IRWIN:
Could you describe your responsibility 19 for off-site emergency planning within the NRC's l
20 responsibility and the approximate length of time of your f
involvement in this area?
21 rg 22 WITNESS SCHWARTZ:
Well, the NRC's involvement U
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g with off-site emergency planning is not direct.
My role has 2
been in involving myself in meetings with the Federal 3
Emergency Management Agency and their carrying out of 4
functions with respect to off-site planning and emergency 5
preparedness.
4 6
MR. IRWIN:
How long approximately have you been 7
involved in this area?
8 WITNESS SCHWARTZ:
I have been involved in this 9 l particular area since the regulations for emergency planning i,
( and preparedness were upgraded.
That takes us back to about 10 i
/^h 11 1980, 1981.
%.)
12 MR. IRWIN:
Approximately how many exercises have 13 you had occasion to become acquainted with during that i
14 !
period?
WITNESS SCHWARTZ:
I would say at least 20 or 15 i
i 16 more.
17 l MR. IRWIN:
In what connection have you become l
d acquainted with them?
18 19 WITNESS SCHWARTZ:
It is either in observation of f
20 the exercise on site, becoming acquainted with the exercise 21 I because of a licensing case where an exercise was conducted, (3
22 j and then in reviewing the findings by FEMA as a result of v) 1 s
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'l that exercise, involvement in the operations center as a-2 participant in an NRC response'during exercises, i
3 MR. IRWIN:
So your involvement has included j
4 participation or review of off-site as well as on-site 5
aspects of these exercises?
6 WITNESS SCHWARTZ:
Participation from the sense of I-7.
being in the operations-center-and being a player within an 8
exercise that involved off-site components.
From the sense 9
of a reviewer, no, I have not reviewed individual scenarios p
10 for exercises, particularly off-site.
t s
11 MR.-IRWIN:
Has your involvement in these l (}
12 exercises been -- strike that.
i 13 Have any of these exercises been full 14 participation exercises?
l 15 WITNESS SCHWARTZ:
Yes.
1 L
16 MR. IRWIN:
Do you believe you have a general L
i 17 understanding of the concept of a full participation exercise 18 as the NRC regulations use it?
i i
19 WITNESS SCHWARTZ:
Yes.
7 20 MR. IRWIN:
On what is that belief based?
21 WITNESS SCHWARTZ:
It is the belief based on, as I 22 mentioned earlier, one in discussions between and among the ace-FEDERAL REPORTERS, INC.
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.!v) 1 NRC Staff and the FEMA Staff and the general public, in the 2
establishment of the regulations in the '80-81 time frame, 3
and also in the working with FEMA and the NRC Staff on their 4
establishment of the scope and depth of what a full 5
participation exercise is.
6 MR. IRWIN:
Gentlemen, let me show you three 7
documents, and I will give them all to you at the same time 8
because they may relate-to one another.
The first. is a 9
document entitled NUREG-0654/ FEMA-REP 10, and it is an 10 excerpt of the document.
The title is " Criteria for 11 Preparation and Evaluation of Radiological Emergency Response 12 Plans and Preparedness in Support of Nuclear Power Plants."
13 (Deposition Exhibit 1 identified.)
14 MR. IRWIN:
I have designated within that document 15 the cover page and pages 71 through 74, which involve a topic 16 entitled " Exercises and Drills."
The second document I would 17 refer each of you to is a provision from the commission's 18 regulations 10 CFR 50.47, which I would ask the reporter to 19 mark as Deposition Exhibit 2.
20 (Deposition Exhibit 2 identified. )
21 MR. IRWIN:
The third document I provide to you is 9
22 another provision from the Commission's regulations entitled ACE-FEDERAL REPORTERS, INC.
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I would ask the reporter to mark 2
that as Deposition Exhibit 3.
3 (Deposition Exhibit 3 identified.)
4 MR. IRWIN:
Mr. Weiss and Mr. Schwartz, have you 5
had an opportunity to review these documents before this 6
morning?
7 WITNESS SCHWARTZ:
Yes.
8 MR. IRWIN:
Are you familiar with these documents 9
in general terms?
10 WITNESS WEISS:
Yes.
11 WITNESS SCHWARTZ:
Yes.
}
12 MR. IRWIN:
With respect to Exhibit 1, the 13 NUREG-0654, on page 71, there is a section, there begins a 14 l
section marked " Exercises and Drills."
Is there, to your 15 knowledge -- is this a basic description of NRC and FEMA 16 expectations as to the requirements for off-site exercise 17 requirements?
Let me rephrase that question.
18 WITNESS SCHWARTZ:
Please.
19 MR. IRWIN:
What in your view is the purpose of or 20 meaning of this " Planning Standard" and " Exercises and 21 Drills" in your regulatory framework?
s 22 WITNESS SCHWARTZ:
Well, we look at NUREG-0654.
i s
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It also has enother title,_and it is reg guide'1.101, and it 2
has the status of a Commission regulatory guide which 3
provides guidance to licensees on a way to satisfy the NRC 4
regulations.
In particular, with respect to exercise and 5
drills, I believe it lays out the criteria that the 6
Commission would expect to be demonstrated in exercise and 7
drills to carry out the intent of the regulations.
I will 8
stop there.
9 MR. IRWIN:
Mr. Weiss, do you have anything to 10 add?
{)~
11 WITNESS WEISS:
No.
12 MR. IRWIN:
Does this document indicate anything 4
13 specific with respect to the definition of a full 14 participation exercise?
15 WITNESS SCHWARTZ:
I would have to review it to 4
16 see if those words " full participation" appear in here.
I 17 don't remember.
If you want to give me the time, I can do 4
18 that now.
It is up to you.
19 MR. IRWIN:
Would you review it to determine i
20 whether the term " full participation" occurs in there?
4 21 WITNESS SCHWARTZ:
On review, I don't find the i
p%J -
22 words " full participation" in this guidance.
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MR. IRWIN:
Turning briefly to Exhibit 2, 50.47, 2
entitled " Emergency plans," would -.and in particular 3
inviting your attention to section 50.47 (b) (14), that's on 4
page 455 of the excerpt from 10 CFR -- would you agree with 5
me that paragraph 14 is the provision within section 50.47 l
6 which contains the requirement of this regulation respecting i
7 off-site exercises, off-site emergency planning exercises?
8 WITNESS SCHWARTZ:
I believe this --
9 MR. BORDENICK:
Talking about (b) (14 ) ?
10 MR. IRWIN:
Yes.
(~T 11 WITNESS SCHWARTZ:
Yes, but I would be a little --
V 12 I would like to expand that.
There's a requirement with 13 respect to exercises off-site and on site.
14 MR. IRWIN:
In this document, is there any -- in 15 section 50.47, is there to your knowledge any discussion or 16 is there any mention of the term " full participation 17 exercise"?
18 WITNESS SCHWARTZ:
Not in 50.47.
Not as far as I 19 can tell.
20 MR. IRWIN:
Inviting your attention to Exhibit 3 I
21 now, which is 10 CFR Part 50, Appendix E, inviting your r-22 attention particularly to paragraph P -- I guess it is IV F, (s}
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4, is there a discussion or mention of the term " full 3
participation exercise" in that section?
4 WITNESS SCHWARTZ:
Yes.
5 MR. IRWIN:
Are those the only places to your 6
knowledge in the NRC regulations or guidance, NRC specific 7
regulation or guidance that the term " full participation 8
exercise" is used?
9 WITNESS SCHWARTZ:
Yes.
10 MR. IRWIN:
Can you tell me, in terms other than a 11 literal reading of the regulation, as a general concept what
{}
12 you all or the Commission looks for in determining what are 13 the constituents or components of a full participation 14 exercise?
How do you tell, in other words, if something is a 15 full participation exercise versus its being something other 16 than a full participation exercise?
17 WITNESS SCHWARTZ:
Again, me,fbe some of the words 18 are not in the regulation, but it is a demonstration of the 19 plan -- an integrated demonstration of the plan for 20 responding to an event at the nuclear power facilities with 21 j as much of the plan oeing exercised without mandatory public 22 participation.
I l
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Is it required that every element of a 2
plan be exercised for an exercise to be a full participation 3
exercise?
4 WITNESS SCHWARTZ:
There's no NRC requirement.
5 Can I delve into a FEMA -- I am familiar with a FEMA GM -- I 6
can't remember the name of it, we may get into it later --
7 which lays out that there are some 35 elements of exercise,,
8 and that those elements should be. covered over, I believe, a 9
five-year period or three-year period, I can't remember the 10 exact words, and that's the standard by which the NRC has
(~)T 11 accepted full participation.
12 MR. IRWIN:
In other words, if those elements are 13 covered within the three-year or five-year period or whatever 14 the period is that FEMA requires exercise -- well, strike 15 that.
16 It follows from that that not every element that 17 FEMA requires has to be demonstrated at each exercise for it 18 to be a full participation exercise; is that right?
19 WITNESS SCHWARTZ:
- Yes, I will say yes to that.
g 20 l However, I must put a footnote on that and recognize also I
21 I that exercises for new licensees carry -- and I don't know
(-
22 how many of the 35 would be acceptable, but it carries more
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1 than just -- more than just some of the 35 elements.
2 MR. IRWIN:
In short you don't simply divide 35 by 3
three and if you --
4 WITNESS SCHWARTZ:
Exactly.
There has to be an b
integrated demonstration of the capability.
6 MR. IRWIN:
But within that, given that basic 7
requirement, there's no further requirement, as you 8
understand it, that all 35 be demonstrated at each given i
9 exercise?
i 10 WITNESS SCHWARTZ:
It is not my understanding.
11 MR. IRWIN:
Mr. Weiss, is that your
(}
12 understanding?
I f
13 WITNESS WEISS:
Yes.
14 MR. IRWIN:
Why don't we look at another exhibit.
15 I will refer you to a document entitled FEMA Guidance 16 Memorandum 17, Revision 1, which I will ask the reporter to 17 mark as Deposition Exhibit 4.
18' (Deposition Exhibit 4 identified.)
19 MR. IRWIN:
We might as well take a minute to look l
20 at this guidance memo.
Is this the document that you were l
21 !
referring to a minute ago as being the FEMA guidance memo l
22 I which lays out --
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'l WITNESS SCHWARTZ:
I believe it was, or it may 2
have been even the precursor of that.
-I think there were 3
also in the August 15 memorandum of 1983 by Dave McLaughlin.
4 4
I think that may have also included such a listing.
5 MR. IRWIN:
But to the extent that you are aware 6
of --
t 7.
WITNESS SCHWARTZ:
This is the latest.
8 MR. IRWIN:
This is accurate or this memo is 9
consistent with your understanding of the FEMA guidance that 10 you described to me earlier?
i 11 WITNESS SCHWARTZ:
Yes.
'{}
12 MR. IRWIN:
Is the FEMA guidance you were 13 describing to me earlier summarized by the last paragraph on 14 page 2 of this FEMA Guidance Memorandum 17, the paragraph 15 beginning with:
"The basic objectives for the exercise 16 should be taken from the list of 36 in Attachment 1," and 17 proceeding thereon for about a dozen lines?
18 WITNESS SCHWARTZ:
Yes.
t 19 MR. IRWIN:
Let me ask you gentlemen whether -- I l
20 will show you an additional FEMA guidance document.
This is i
21 entitled " FEMA Draft Guidance Memorandum EX-3".
It is dated 1
22 August 15, 1986.
I would ask the reporter to mark it as l
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1 Exhibit 5.
2 (Deposition Exhibit 5 identified.)
3 MR. IRWIN:
Please take an opportunity.to review 4
that.
5 WITNESS SCHWARTZ:
I'm generally familiar with 6
it.
7 MR. IRWIN:
Mr. Weiss, have you seen this document 8
also?
9 WITNESS WEISS:
Yes.
10 MR. IRWIN:
Directing your attention particularly 11 to the paragraph at the top of page 3 of the Draft Guidance
{}
12 Memorandum EX-3, the paragraph which begins:
"The basic 13 objectives for the exercise should be taken from the list of 14 35 in section III," and continuing on for approximately 20 15 lines, does this paragraph once again, Mr. Schwartz, 16 summarize, or is it consistent with your understanding of 17 FEMA's guidance with respect to the content of exercises?
18 WITNESS SCHWARTZ:
Yes.
19 MR. IRWIN:
Referring you to the portion of this 20 i paragraph beginning on the seventh line of the paragraph l
21 which states that:
"The objectives should be selected in i
i i
22 order to test a signific nt portion of the emergency response i
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1 capabilities.
The selection of objectives should also ensure 2
that all major elements of the plans and preparedness 3
organizations are tested at least once every six years as set 4
forth in Guidance Memo PR-1.
Some objectives, because of 5
their fundamental nature to emergency response, are to be 6
included in each biennial exercise.
This set of exercise 7
objectives is to be referred to as the ' core objectives.'"
8 Do you see that paragraph?
9 WITNESS SCHWARTZ:
Yes.
10 MR. IRWIN:
That segment.
Does that segment which 11 I just read to you summarize accurately the kind of M
12 prioritizing of exercise objectives or exercise requirements 13 that you were referring to earlier?
14 WITNESS SCHWARTZ:
I'm not sure I understand your 15 question.
16 MR. IRWIN:
I will try it again.
Does that 17 segment of that paragraph state a policy with respect to the 18 conduct of exercises which is consistent with your 19 understanding of NRC requirements as well as FEMA 20 I requirements?
l I
21 WITNESS SCHWARTZ:
Yes.
(S 22 MR. IRWIN:
I take it that -- strike that.
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In your evaluation of the content of an exercise, 2
how do you use the sum total of the guidance contained in the 3
five exhibits that we have reviewed?
Namely, NUREG-0654, 10 4
CFR 50.47, Paragraph (b) (14 ), Appendix E, FEMA Guidance Memo 5
17, and to the extent you use it, Draft Guidance Memo EX-3?
6 Is there some way in which you put all these together either 7
objectively or as a holistic kind of subjective analysis?
8 WITNESS SCHWARTZ:
The process as described in GM 9
17 as to the way NRC and FEMA work to make a determination as 10 to whether exercise objectives and exercise scenarios meet 11 the requirements.
In summary, the NRC has relied on the
(}
12 evaluation by the Regional Assistance Committees of the 13 exercise objectives first, and then the exercise scenario as 14 to whether it meets the criteria for an exercise -- full 15.
participation exercise.
The NRC has a representative on each 16 Regional Assistance Committee, and if he is satisfied after 17 his review that it meets NRC requirements, then the NRC is 18 l satisfied.
19 MR. IRWIN:
Was that process followed to your 20 !
knowledge in the case of the development and conduct of the l
21 l Shoreham exercise on February 13, 1985?
22 WITNESS WEIGS:
Yes.
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2
'86, yes.
3 MR. IRWIN:
Do you agree with Mr. Schwartz's 4
characterization of the process, Mr. Weiss?
5 WITNESS WEISS:
Yes.
6 MR. IRWIN:
Let me note for the record that a 7
phone message was received from Mr. Zahnleuter, counsel for 8
the State of New York at 10:05.
The message was recorded at 9
that time.
He indicated he would be late for the deposition 10 and authorizing all parties to start without him.
We 11 received the message at 10:40.
{}
12 Let me clarify one thing, gentlemen.
Are you 13 aware of any documents that have regulatory significance that 4
14 use the term " full participation exercise" other than 15 Appendix E to 10 CFR Part 50?
16 WITNESS SCHWARTZ:
I know of none.
17 WITNESS WEISS:
No.
19 MR. IRWIN:
When one is sr.tting out to structure a 19 full participation exercise, how does one -- what does one 20 look to in terms of the desired scope of participation with i
21 respect to the organizations who will participate relative to 22 l the content of the emergency plan?
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MS. LETSCHE - I object to the form of the.
l' 2
question.
3 MR. IRWIN:
Do the witnesses understand the 4
question?
5 WITNESS SCHWARTZ:
Why don't you repeat it or --
6 MR. IRWIN:
Can you read it back?
7 (The reporter read the record as requested. )
8 WITNESS SCHWARTZ:
As I mentioned earlier, the 9
exercise is to demonstrate an integrated capability to 10 respond to protect the public health and safety in the event 11 of an accident, so at first you would look at the plan itself 12 to see what are the major components of response that are 13 necessary to be tested.
We can go into a litany of what 14 those are, but pick any plan for emergency planning and 15 preparedness, and the basics are always decision-making and 16 protective action recommendations, communication, field 17 monitoring.
18 There's a number of things that you would look to 19 to assure that that capability is adequately demonstrated, 20 and the first issue is really to set those out in the 21 objectives.
The other thing that you look at in establishing 22 the objectives for an exercise are past performance when you I
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1 look at an operating plant or past performance in previous 2
exercises.
Then you establish what areas may have been weak 3
in past performance, and you want to make sure that those are 4
in the objectives to be evaluated and observed, tested, 5
implemented, evaluated.
6 MR. IRWIN:
I take it the actual structuring of 7
each exercise will then vary from plant to plant and for any 8
given plant from exercise to exercise?
In other words, a 9
full participation exercise at plant A in year 1985 is not 10 necessarily identical in structure to a full participation
(')h 11 exercise at plant B in 1986.
\\_
12 WITNESS SCHWARTZ:
That's correct.
13 MR. IRWIN:
In terms of the magnitude of resources 14 deployed for an exercise, is there any criterion or general 15 set of guidelines that you expect for a full participation 16 exercise, and here let me invite your attention to three 17 different aspects of deployment.
One is the actual number of i
18 personnel mobilized at the outset.
Secondly, the number of 19 personnel deployed to actually undertake functions in the 20 l field, and the third is the extent of observation of i
21 l performance by those persons who are deployed in the field.
22 j Let me stop there.
Do you understand the question?
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1 MS. LETSCHE:
I object to the form of that.
2 WITNESS SCHWARTZ I think I understand the 3
question.
There's no -- as far as I know, there are no 4
criteria.
There are no regulations or guidance to either 5
staff or others, or licensees, as to the amount of resources 6
that are necessary to carry out an exercise.
For NRC, we 7
have put out guidance to our regions as to the amount, the
.8 number of inspectors who would be available to, within 9
latitude, the number of inspectors who should witness the 10 licensee participation in an exercise.
' f'T 11 MR. IRWIN:
With respect to the extent of G
12 recources deployed by organizations responsible for 13 implementation of an off-site plan, in the absence of 14 specific guidance, what kind of judgment criteria or 15 judgmental or other kinds of criteria do you use?
16 WITNESS SCHWARTZ:
Again, I have to defer to 17 looking at the scenario and looking at the objectives which 18 is done by the Regional Assistance Committee, but to my mind, 19 l I know of no time that either FEMA or FEMA through the RAC or l
the NRC members through the RAC ever get into numbers and 20 I 21 resources that will be used in an exercise, that it alleges rg 22 bas been the evaluation of the objectives and the scenario, t>
l 4
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and whatever it took to implement that exercise was what the 2
government observed.
3 MR. IRWIN:
In other words, once one has 4
determined the objectives, then if the resources deployed i
h were sufficient to reasonably allow you to see whether the 5
1 l
6 objectives had been fulfilled, that's the test?
7 i Let me try it differently.
As I understand the 8
process, you set the objectives, then a scenario is agreed i
9 W upon to implement the objectives.
If the resources are t
O 10 sufficient to permit judgment of whether you fulfilled the l'
11 objectives of the exercise or whether you have the capability g
12 l of fulfill the objectives, then that amount of resources will 13 have been deemed to have been sufficient?
14 MS. LETSCHE:
Object to the form.
15 l MR. BORDENICK:
You may answer if you understand l
16 l the question.
If you don't understand, so indicate.
I 17 !!
WITNESS SCHWARTZ:
I understand the question, and l
18 '
what I believe is that the government does not get involved 19 in establishing whether or not in advance of the exercise the j
20 number of players who are participating in the exercise are 21.
adequate.
The government will provide their voice on that 4
22 issue when they complete the evaluation of the exercise, then l
l l
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you will know whether.it is sufficient or not.
2 MR. IRWIN:
Mr. Weiss, do you agree with that?
3' WITNESS WEISS:
Yes, I agree with that.
4 MR. IRWIN:
Do you have anything to add to that?
5 WITNESS WEISS:
No.
6 (Discussion off the record.)
7 MR. IRWIN:
Let's go back on the record.
We just 8
discussed the question of the number of personnel or the 9
amount of resources deployed in an exercise.
In terms of the 10 scope of areas-to be tested during an exercise, once again, 11 is there any absolute criterion or any other hard bright-line
' {}
12 requirement with respect to what is sufficient for a full 13 participation exercise, or does that vary from exercise to i
14 exercise?
Or can it vary from exercise to exercise?
I
{
15 MS. LETSCHE:
Object to the form.
16 WITNESS SCHWARTZ:
I would like you to repeat it i
i 17 and break it down into more than one question.
I 18 i MR. IRWIN:
Let's talk for a second about the i
19 l number of areas to be observed, presumably from within the 35 I
f or 36 general objectives available from guidance memos.
Is
{
20 21 there any hard-and-fast criterion or rule as to the number of s
22 them which must be observed during any given exercise, or can
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that vary from exercise to exercise?
2 WITNESS SCHWARTZ:
I'm sorry, I still don't 3
understand.
You switched from scenario development to 4
observation, and you have me confused.
5 MR. IRWIN:
Let's stick to development of the 6
exercise for a minute.
In terms of development of an 7
exercise, is there any specific number of objectives from 8
within the set of general objectives in Guidance Memo 17 or j
9 Guidance Memo EX-3 which must be observed for an exercise to 10 be considered a full participation exercice, or does it
{}
11 vary?
12 WITNESS SCHWARTZ:
I don't know of such a number.
13 WITNESS WEISS:
No.
s 14 MR. IRWIN:
Picking up on what you said a minute 15 ago, Mr. Schwartz, about decision, communication, protective 16 actions, is that the kind of determination that goes into 17 assessing whether the objectives chosen for an exercise are 18 sufficient to establish it as a full participation exercise 19 l or potentially a full participation exercise?
l 20 l MS. LETSCHE:
Object to the form.
l 21 l MR. BORDENICK:
You may answer if you understand r3 22 the question.
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WITNESS SCHWARTZ:
I'm still not sure, j
2 MR. IRWIN:
Let me try it from a different 3
approach.
You know that it is the intent of a' utility and 4
whatever other entities may be responsible for off-site 5
emergency' planning at a given plant to conduct a full 6
participation exercise.
How do you know that what's going 7
into that-exercise in. terms of objectives to be demonstrated 8
is going to be sufficient to establish it as a full 9
participation exercise?
How do you determine that?
10 WITNESS SCHWARTZ:
I know because it has been 11 reviewed by a committee that uses the criteria published --
12 the guidance, sorry, the guidance published by FEMA, and it 13 meets that guidance, and the NRC person is satisfied that it 14 meets our regulations, that the scope of that exercise 15 demonstrates or will demonstrate the integrated response of 16 that particular plan.
17 MR. IRWIN:
And so if you have -- strike that.
18 Let's look for a moment at the intensity of 19 observation of the resources deployed to meet objectives in 20 an exercise, and again we're talking about exercise design, 21 l
setting it up.
What's the process -- is there any 22 hard-and-fast line of criterion which tells you how many O
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. ~~g) 1 kinds of sample -- what kinds of samples you have to observe 2
or what size those samples have to be in order to assess 3
whether an objective has been fulfilled?
4 WITNESS SCHWARTZ:
Could you define what you mean 5
by " sample"?
6 MR. IRWIN:
Sure.
I will give you an example.
7-Let us suppose that in a given exercise, or in a given 8
emergency plan, it is contemplated that approximately 300 bus 9
routes will be run to evacuate members of the general 10 population if need be.
The exercise may call for deploying 11 in fact anywhere from zero to up to 300 of the buses to
{}
12 actually run those routes.
From within that number deployed, 13 FEMA and its agents will observe the performance of anywhere 14 from zero to whatever the end happens to be of the buses 15 actually deployed.
What I'm interested in is whether you 16 know of any hard-and-fast rule or criterion which says the 17 sample size must be of X size or greater, or any other rule by which sample size must be determined in order to be 10 !
19 ;
minimumly acceptable?
]
20 WITNESS SCHWARTZ:
I know of none in this area.
21 l WITNESS WEISS:
No.
N 22 !
MR. IRWIN:
Both of you know of none?
Do you know O.
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significant in size, using the term " statistically I
3 significant" as a term of art?
4 WITNESS SCHWARTZ:
I understand what you are 5
saying.
The only area that I know where you get into that --
6 FEMA has gotten into statistically significant sampling is 7
the example of the alert system.
That's all I know about 4
8 anything published.
9 MR. IRWIN:
With respect to any other kind of 10 sampling, you are not aware of the use of --
11 WITNESS SCHWARTZ:
I'm not aware of any.
(}
12 WITNESS WEISS:
No.
13 MR. IRWIN:
Mr. Weiss, you also agree with that?
14 WITNESS WEISS:
Yes.
15 MR. IRWIN:
Again, in the process of setting up 16 the sampling to be used in an exercise, is it the NRC's 17 '
practice to defer to the RAC process in deciding what are 18 appropriate sampling sizes to verify the implementation of l
objectives?
19 t
i 20 i WITNESS SCHWARTZ:
Yes.
21 l MR. IRWIN:
Let's turn to Appendix E to Part 50.
i 22 That's Exhibit 3.
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1 (Discussion of f the record.)
2 MR. IRWIN:
Let me ask you just a typographical 3
note, and I think I am aware of the answer.
If you look at 4
footnote 4 on page 512, footnote 4 to 10 CFR Appendix E, 5
Paragraph IV F.1.,
the third line in the second column of 6
that footnote refers to " capability to adequately access and 7
respond to."
Should that word " access" be " assess" as far as 8
you know or is that correct?
9 WITNESS SCHWARTZ:
I can't deal with it.
I'm 10
- sorry, f
(')
11 MR. IRWIN:
That's been one of my problems for a
()
12 couple of years.
13 WITNESS SCHWARTZ:
It is just one that I read 1
14 through all these years.
15 MR. IRWIN:
If the word were intended to mean l
I anything other than " assess," how would you define it?
16 1:
17 $
Do you have anything to add to that, Mr. Weiss?
O 18 WITNESS WEISS:
If I had to rewrite it, I would --
19 MR. IRWIN:
Just idle curiosity there.
20 WITNESS SCHWARTZ:
I would also say that we're not I
21 ;
too perfect in writing and transcribing this.
If you look 22 further on down in this same full paragraph, we have l
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(_s) 1 resources in sufficient "mumbers."
I think I can help you 1
2 with the interpretation of that one, though.
3 MR. IRWIN:
Let me ask you gentlemen a general 4
question.
In light of the criteria and process which we have 5
been discussing, do you consider the design of the Shoreham 6
exercise to have been consistent with the requirements of a 7
full participation exercise under 10 CFR Part 50, Appendix 8
E?
1 9
MS. LETSCHE:
Object to the form.
10 MR. BORDENICK:
You may answer if you understand 11 the question.
,/ }
12 WITNESS SCHWARTZ:
Yes.
13 WITNESS WEISS:
Yes.
I 14 MR. IRWIN:
Do you consider that the exercise as 15 actually conducted was consistent with the requirements of a ll 16 )
full participation exercise as described in 10 CFR Part 50, i
17 Appendix E?
W MS. LETSCHE:
Object to the form.
18 l 0
19 WITNESS WEISS:
Yes.
20 !
WITNESS SCHWARTZ:
Yes.
21 h (Discussion off the record.)
i 22 i MR. IRWIN:
Let me follow up on those two 1
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If you refer back to Part 50, Appendix E, once 2
again, at the bottom of page 512, paragraph 1, you see the 3
- sentence, "A full participation exercise which tests as much 4
of the licensee's state and local emergency plans as is 5
reasonably achievable without mandatory public 6
participation."
Do you see that phrase, gentlemen?
7 WITNESS SCHWARTZ:
Yes.
8 WITNESS WEISS:
Yes.
i 9
MR. IRWIN:
I take it from your answer to the two 10 previous questions that you would consider that the Shoreham 11 exercise included as much of the licensee's state and local
( '}
12 emergency plans as is reasonably achievable without mandatory 13 public participation?
i l
WITNESS SCHWARTZ:
Yes.
14 15 WITNESS WEISS:
Yes.
16 ;
MR. IRWIN:
If I could refer you to footnote 4 on 17 that page, and the definition of a fall participation k
18 }
exercise, the reference to that exercise requires that i
i 19 !
" appropriate off-site local and state authorities and 20 [
licensee personnel physically and actively take part in l
I i
21 !
testing their integrated capability to adequately access" --
i 1
or " assess" -
"and respond to an accident at a commercial 22 l
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nuclear power plant."
2 Do you see that sentence?
I take it from your 3
answers to the previous questions that you believe that 4
requirement also was fulfilled?
5 WITNESS SCHWARTZ:
Yes.
WITNESS WEISS:
- Yes, 6
f 7
MR. IRWIN:
Looking at the next sentence that 8
describes the characteristics of a full participation 9
exercise which states, " Full participation includes testing 10 of the major observable portions of the on-site and off-site
(~)
11 emergency plans"; that portion.
Do you believe that the V
12 Shoreham exercise tested the major observable portions of the 13 on-site and off-site emergency plans for Shoreham?
14 WITNESS SCHWARTZ:
Yes.
15 WITNESS WEISS:
Yes.
16 l MR. IRWIN:
Looking at the second half of that 17 sentence, that " mobilization of state local and licensee i
18 personnel and other resources in sufficient numbers to verify l
the capability to respond to the accident scenario"; do you 19
\\
20 see that requirement?
I take it you believe that that l
21 {
requirement also was fulfilled by the Shoreham exercise?
WITNESS SCHWARTZ:
I can't go that far.
There was 22 :
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not mobilization as we all know of state and local 2
personnel.
3 MR. IRWIN:
And that's your sole reservation 4
there?
5 WITNESS SCHWARTZ:
That's correct.
6 MR. IRWIN:
Is that the basis for your concern?
7 WITNESS WEISS:
That's my concern, that they did 8
not participate.
9 MR. IRWIN:
But for the absence of state and local 10 personnel, I take it you were satisfied that appropriate 11 numbers of personnel were mobilized and deployed to fulfill
(}
12 the -- to demonstrate a capability to respond to an accident 13 scenario?
14 WITNESS WEISS:
To demonstrate that the plan as 15 written could be implemented.
16 MR. IRWIN:
Okay, in addition to that, with the 17 exception of the deployment of state and local personnel, who 18 l refused to participate, in looking again at this last 19 sentence of footnote 4, do you believe that the exercise --
7 20 with respect to mobilization of everything but state and i
21 l local personnel, that the exercise required mobilization, I
22 l except for state and local personnel, of sufficient personnel 1
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1 and other resources in sufficient numbers to verify the 2
capability to respond to the accident scenario?
3 MS. LETSCHE:
Object to the form of the question.
4 MR. BORDENICK:
You can answer if you understand 5
it.
6 WITNESS WEISS:
Yes.
7 WITNESS SCHWARTZ:
Yes.
8 MR. IRWIN:
With respect to state and local 9
personnel, was their absence compensated for in any means in 10 the design of the exercise?
11 WITNESS WEISS:
Yes.
{}
12 MR. IRWIN:
What was that means?
13 WITNESS WEISS:
The plan that was developed by the 14 utility allowed for the presence of state and local officials 15 if they showed up or if they wanted to participate, and the 16 exercise was designed so that that portion or that capability 17 would be demonstrated in the exercise.
I 18 l MR. IRWIN:
And Mr. Weiss, did you participate --
19 !
I take it that the process you are referring to as translated 20 in the exercise was referred to as simulation of state and 21 local personnel?
WITNESS WEISS:
That's correct.
22
()
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Did you take part in the design of_the 2
function of state and local personnel?
3 WITNESS WEISS:
I did.
4 MR. IRWIN:
Do you consider yourself knowledgeable 5
in that area?
6 WITNESS WEISS:
Yes.
7 MR. IRWIN:
Could you describe in a little more 8
detail how that function was exercised, was conducted during 9
the exercise?
10 WITNESS WEISS:
It was conducted in such a way 11 that people simulated both the arrival of state and local
{}
12 representatives at the EOC and the local EOTF.
There were 13 also simulators at a control cell that represented officials 14 and who made phone calls or received phone calls from players 15 in the exercise and asked those questions.
They were 16 instructed, though, not to assume any decision-making or 17 response role, but merely to ask questions, ask for l
18 l clarifications, and where there was some difference of I
l 19 :
information, to ask for clarification.
I l
l 20 [
MR. IRWIN:
Gentlemen, let me show you a document l
)
21 consisting of a memorandum from Edward L. Jordan to James M.
i l
22 4 Taylor dated 3/18/86, entitled " Report of NRC Activities in f
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Shoreham Exercise."
2 (Deposition Exhibit 6 identified.)
3 MR. IRWIN:
When you have had an opportunity to 4
review it, please let me know.
5 Are you familiar with this?
6 WITNESS WEISS:
Yes.
7 MR. IRWIN:
Have you also seen this document 8
before, Mr. Schwartz?
l 9
WITNESS SCHWARTZ:
I have seen it, yes.
10 MR. IRWIN:
Mr. Weiss, I take it you are familiar
{
/~}
11 with this document?
1 i
12 WITNESS WEISS:
Yes.
13 MR. IRWIN:
Would you review the portion of the 14 document beginning at the middle of page 2 and really 15 continuing to the end of that page, and the paragraph 16 beginning "The NRC and FEMA officials involved in the 17 off-site control and simulation in this exercise performed j
ftheirtasks in a highly professional manner," and continuing 18 i
19 l for about 20 more lines.
i t
I MS. LETSCHE:
While they are doing that I want to 20 i
t' state my objection to this line of questioning.
I don't i
21 i i
l 22 think it is relevant to any of the admitted contentions in i
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1 Q this exercise proceeding.
I 2 l MR. BORDENICK:
The witnesses can answer to the 3
extent they can.
4 MR. IRWIN:
I will note this line of questioning 5
is intended to address the one caveat to the witnesses' l
l statement as to their answer about a full participation 6
i 7 l exercise; namely, the absence of state and local government 8
participation and how that absence was compensated for.
9 Mr. Weiss, amid the colloquy, have you had a 10 chance to review that paragraph?
11 WITNESS WEISS:
Yes.
(}
12 MR. IRWIN:
Does that paragraph in your view 13 !
accurately describe the functioning of the simulators during 14 that exercise?
h 15 l WITNESS WEISS:
Yes.
k 16 j (Discussion off the record.)
1 y
17 il MR. IRWIN:
I have no questions.
0 18 MR. BORDENICK:
I guess --
19 j MS. LETSCHE:
I have several.
Did you want to 20 take a break first or just -- I have a good deal of 21 questioning.
22 MR. DORDENICK:
How long is a good deal?
More i
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MS. LETSCHE:
Probably.
3 MR. BORDENICK:
Let's go on.
1 4
MS. LETSCHE:
Mr. Weiss, I want to go back to the 5
initial discussion Mr. Irwin had with you about your 6
background and experience.
I gather that your experience 7
with the NRC response that you mentioned earlier -- I forget 8
the term you used for it -- that is NRC responding with 9
respect to on-site portions of exercises; is that right?
10 WITNESS WEISS:
Well, it is with respect to i
11 responding to the on site portion of the exercise but the NRC
(}
12 is, of course, also concerned with what's going on on the 13 off-site portion; and one of our major concerns is always our 3
14 contact and interface with the state people and what i
l 15 activities they are conducting, so there is a close I
i 16 i relationship.
J 17 MS. LETSCHE:
You mentioned, however, that you i,
l 10 l were involved in, for instance, training NRC Staff people, I 19 think you said, with respect to the NRC response.
l WITNESS WEISS:
Yes.
20 i
i 21 MS. LETSCHE:
Does that involve off-site i
22 responses?
l i
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1 WITNESS WEISS:
Yes.
One of our concerns is 2
dealing with the state and locals, mostly state and locals, 3
and being assured that our regional people send liaisons to 4
the state and that the headquarters is aware of what's going 5
on there.
6 MS. LETSCHE:
Can you describe for me what the 7
training is that you have done of NRC Staff members with 8
respect to off-site responses to nuclear accidents?
9 WITNESS WEISS:
You want me to go into details of 10 the training or --
11 MS. LETSCHE:
This is something which you said you 12 had done, training these people for off-site responses.
I 13 wonder if you can describe it for me.
1 WITNESS WEISS:
In general, we do training of --
l 14 15 I'm particularly responsible for the liaison groups, the l
j governmental liaison team which has the responsibilities of 16 17 staying in touch with both the state government, both 18 coordinating what they are doing and exchanging information, 19 Congressional groups, public affairs; and also with regard to 20 i assuring that the regions have their government liaison people and they have made a combination and they understand 21 22 l what kind of positions they have to have on the response 1
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l be conducted and what their objectives are.
2 3
MS. LETSCHE:
You mentioned that you had been or 4
were familiar with or participated or observed or had some 5
involvement in, I think you said 15 to 20 commercial nuclear 6
power plant exercises during the past four or five years.
l 7
WITNESS WEISS:
Roughly.
W MS. LETSCHE:
Is it your testimony that all 15 or 8
q
]Il 20 of those commercial power plant exercises were full 9
4 10 participation exercises?
11 WITNESS WEISS:
No.
12 MS. LETSCllE About how many were?
13 '
WITNESS WEISS:
I'm not sure that --
14 l MS. LETScilE Just roughly.
15
't WITNESS WEISS:
At least half of them.
If not 16 l more.
17 k MS. LETScilE Of the ones that were full 10 j participation exercises, how many of them involved no i
19 )
participation by any governmental entity?
i 20 WITNESS WEISS:
None.
21 j
MS. LETScilEt Did any of them that you believe 22 were full participation exercises exclude the testing of O
1 i
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2 WITNESS WEISS:
Yes.
3 MS. LETSCilE How many?
4 WITNESS WEISS:
My recollection is most of them.
5 MS. LETSCHE:
Most of them did?
l 6
WITNESS WEISS:
Yes.
7 d MS. LETSCHE:
With respect to any plants for which f
there were what you believe were full participation exercises 8
l 9
which excluded the ingestion pathway response, did any of 10 those plants not have supplemental or remedial or additional 11 j exercises in which the ingestion pathway response was 12 tested?
13 WITNESS WEISS:
My participation was just in the il l
exercise, and I don't really -- am not aware of the follow-up 14 e
15 to those exercises, p
16 j MS. LETSCllE:
Okay, that's fine.
In any of the lt ll!
exercises of which you are familiar that you believe were 17 i
18 full participation exercises, did any of those exercises not 19 include the airing of at least a test message on an EVG 20 station?
21 i WITNESS WEISS No.
Did I get that one right?
1 22 The way -- would you reword it?
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1 MS. LETSCHE:
Did any of them not include the 2
airing of a test message?
3 WITNESS WEISS:
The answer is no, they didn't.
4 MS. LETSCHE:
To your recollection, did any of 5
those -- all these will be with respect to the full 6
participation ones that you refer to -- not include the 7
sounding of sirens?
8 WITNESS WEISS:
Not being there, my recollection 9
is that many of them did not have the sirens tested during 10 the exercise.
11 MS. LETSCHE:
But you were not there?
(}
12 WITNESS WEISS:
No, I wasn't.
13 MS. LETSCHE:
Were you at any of the exercises 14 that you referred to?
15 WITNESS WEISS:
Yes.
Physically located at the 16 scene, yes.
17 MS. LETSCHE:
At the ones you were present at, did any of them not include the sounding of sirens at least once 18 '
19 during the exercise?
20 :
WITNESS WEISS:
I do not recall.
l 21 MS. LETSCHE:
At any of the full participation l
exercises that you recall, Mr. Weiss, did any of them not 22 i O
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2 WITNESS WEISS:
No.
Could we go back?
When you 3
say "public information materials," do you mean public 4
information activities or are you talking about pamphlets?
5 MS. LETSCHE:
Pamphlets or other materials that 6
might have been disseminated.
7 WITNESS WEISS:
I was not involved in the material 8
portion, so I do not know that.
9 MS. LETSCHE:
Mr. Schwartz, just so you don't 10 think I'm forgetting you --
11 WITNESS SCHWARTZ:
Oh, I didn't think you were.
you indicated to Mr. Irwin that 12 MS. LETSCHE:
13 you were, I believe the term he used was " acquainted with,"
14 roughly 20 exercises.
Are those commercial nuclear power 15 I plant exercises you are referring to?
16 WITNESS SCHWARTZ:
That's correct.
17 MS. LETSCHE Do I have that right?
18 ]
WITNESS SCHWARTZ:
About 20.
It is hard over the 19 number of years --
20 MS. LETSCHE:
Of that group of exercises, how many 21 did you actually attend, roughly?
22 l WITNESS SCHWARTZ:
Probably around 15.
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MS. LETSCHE:
What was your role in attending 2
those?
WITNESS SCllWARTZ:
I was more of a management 3
l 4
observer.
i 1
5 l MS. LETSC11E :
What does that mean?
6 WITNESS SCilWARTZ:
We had a team out from our i
7 l
region observing the exercises.
It transcends my career here 8 i at NRC, detailed with the Federal Emergency Management Agency I
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and also pre-TMI when we were looking at exercises as well, 9
l at the participation, 10 il 11 l MS. LETSCllE t Let's talk about post-TMI.
I think
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f emergency planning before TMI was different than what we have 12 13 I now.
Post-TMI, is the number roughly correct that you
) attended 15exercisessincethen?
14 15 WITNESS SCllWARTZ:
Yes.
i 16 MS. LETScilE You attended all of those in this 1
17 l management team role?
10 l WITNESS SCllWARTZ:
Yes, either as an observer of l
19 l the FEMA observation of the exercise or of the NRC q
20
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observation of the exercise.
Involved in thrs management 21 l
critique at the end of the exercise.
I 22 MS. LETScilE s You actually were a FEMA observer at l
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Did I understand you right?
2 MS. LETSCHE:
No, I observed the FEMA 3
observation.
4 MS. LETSCHE:
And you observed the NRC observation 5
also?
6 WITNESS SCHWARTZ:
That's correct.
7 MS. LETSCHE:
You observed the observers?
8 WITNESS SCllWARTZ:
That's correct.
9 MS. LETSCllE I take it the NRC observers whom you 10 observed were reviewing on-site functions; is tilt correct?
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11 WITNESS SCHWARTZ:
That's right.
U 12 MS. LETSCHE:
What were the FEMA observers -- let 13 l me back up.
I 14 ilow many instances were there in which you were i
15 observing FEMA observers at an exercise?
h 16 ]
WITNESS SCllWARTZ:
Two or three.
I 17 )
MS. LETSCllE Do you remember what they were, 10 j which exercises?
19 )
WITNESS SCilWARTZ:
I don't remember.
They were i
20 l exercises in the time frame about 1900, 1981.
i 21 j
MS. LETSCllE Let's just see if you can remember a 22 little bit.
Dack in 1900 or 1901, do you recall what it was
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1 that the FEMA observers were reviewing, the ones that you 2
observed?
3 WITNESS SCHWARTZ:
Yes.
They were reviewing the 4
off-site portion of the response.
5 MS. LETSCHE:
You don't recall any more 6
specifically than that what portions of the response?
l' 7
WITNESS SCHWARTZ:
They were located in the state 8
emergency operations center.
They were located at the 9
command post.
They had various names in various locations, 10 but they were located in any location where there was a l
11 significant response by the off-site officials.
{}
12 MS. LETSCHE:
I take it that in those instances 13 the off-site officials were either state or other 14 governmental personnel?
t 15 WITNESS SCHWARTZ:
I don't know what you mean by 16 "other governmental personnel."
MG. LETSCHE:
Local, government, county officials,
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17 city and state officials?
l 10 19 WITNESS SCHWARTZ:
Yes.
MS. LETDCHE You did not attend the Shoreham 20 21 exercise; in that right?
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22 9 WITNEGO UCHWAHTZ:
That's correct.
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1 MS. LETSCHE:
And am I correct that you did not 2
review the Shoreham exercise scenario prior to its 3
finalization?
4 WITNESS SCHWARTZ:
I recall one time that I did 5
review some objectives for the exercise.
I can't remember 6
what that document was, but I don't remember reviewing -- I 7
don't think I ever had seen the scenario itself.
8 MS. LETSCHE:
And in your recollection of having 9
reviewed objectives, what did your review consist of?
10 WITNESS SCHWARTZ:
I believe there was about four 11 pages of bullets, and it went to what was to be exercised at 12 various locations, whether it be emergency operation 13 facilities, emergency operations center, field activities, i
14 simulation of public protective action, simulation of l
15 mobilization of bus drivers and things like that.
My review l
l l
16 consisted of looking at all of those areas with respect to i
17 how much was included in the exercise.
j 18 l MS. LETSCHE Did you in doing your review do
(
I 19 l anything other than read through those pages of bullets?
l 20 WITNESG GCllWARTZ:
No.
l MG. LETSCllE Have you ever reviewed the LILCO i
21 i
22 i plan for Shoreham?
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In the context of review, no.
2 MS. LETSCHE:
In response to some of Mr. Irwin's i
i 3
questions, you indicated that these exercises that you were i
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j 4
acquainted with you believed were full participation i
5 exercises.
I guess we're back to this roughly 20 or so that 1
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you believe were full participation exercises.
Now, did some l
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7 of those include exercises that took place prior to TMI?
l J
8 WITNESS SCHWARTZ:
Yes.
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9 MS. LETSCHE:
Roughly how many of the 20 exercises j
f 10 that you were acquainted with that you believe were full 5
11 participation exercises took place atter the appearance of
)
12 the Appendix E regulations and 50.47 (b)?
13 WITNESS SCHWARTZ:
Clearly the bulk of whatever i
14 number we're at.
I said 15 to 20.
I said about two or three l
15 while I was at PEMA, maybe one to two before and the bulk I
l 16 were after TMI.
k 17 (Discussion off the record.)
1 l
i 18 MS. LETSCHE I think we're talking roughly maybe l
4 l
19 i 10 to 15 after TMI, roughly.
1 i
i 20 :
WITNESS SCHWARTZ Yes.
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MS. LETJCHE:
Of that group -- and all these f
22 '
quantions will refer to that that you believe were full
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1 participation exercises -- to your recollection, did any of i
2 them not include participation by any state or local 3
governmental official?
4 WITNESS SCHWARTZ:
I want to make sure I answer I
5 this correctly.
As far as I am concerned they all included f
6 participation by state and local government authorities.
7 MS. LETSCHE:
To your recollection, did any of i
l 8
them, in these full participation exercises, exclude a 9
testing of ingestion pathway response?
1 10 WITNESS SCHWARTZ:
Yes.
i 11 MS. LETSCHE:
Do you know roughly how many?
[}
f 12 WITNESS SCHWARTZ:
I would say most of them a
j 13 excluded them.
14 MS. LETSdHE:
With respect to any of those plants i
15 for which you recall an exercise that excluded ingestion 16 pathway response, to your knowledge did any of those plants 1
17 not have either supplemental or remedial or additional i
18 i exercises which did include the ingestion pathway response?
j I
19 j WITNESS SCHWARTZ The answer is no.
Walt a i
li 20 j minute.
Repeat the question, please.
i f
21 MS. LETSCllE s Let me see if I can rephrase it.
I I
3 22 j don't remember exactly how I stated it.
I'm referring in the I
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1 question to the plants that had what you believe were full 2
participation exercises without ingestion pathway testing.
3 WITNESS SCHWARTZ:
I understand.
4 MS. LETSCHE:
To your knowledge, did all of those 5
plants at some point have an additional or a supplemental or 6
remedial exercise which did test the ingestion pathway 7
response?
8 WITNESS SCHWARTZ:
I do not have knowledge that 9
they had remedial exercises that tested the ingestion 10 pathway.
11 MS. LETSCHE:
Or any other kind of exercises,
{}
12 whether called remedial or not.
13 WITNESS SCHWARTZ:
Specific to ingestion pathway, 14 I don't know.
There may have been remedials for other 15 !
things.
16 MS. LETSCHE:
I just want you to understand my 17 question was not limited to remedial.
Eith?" an additional k
18 exercise, some kind of testing of the ingestion pathway I
I 19 t
response and you just don't know?
l 20 WITNESS SCHWARTZ I don't know.
21 MS. LETSCllEt That's fine.
i 22 l You indicated that your belief or general l
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as used in the NRC regulations was based on two things.
The 3
first you mentioned was discussions between and among the NRC 4
Staff and FEMA and the general public, and the establishment l'
5 of the emergency planning regulations.
Do you recall saying 6 k that?
O 7
WITNESS SCilWARTZ:
Yes.
8 MS. LETSCHE:
Can you describe for me what those 9 l discussions were, particularly with respect to the general 10 public that you referred to?
11 WITNESS SCilWARTZ:
During the time when the new 12 regulations were being put into place, we had workshops and j
public sessions in five locations around the country where we 13 I
]
had public participation and discussions with state and local 14 15 governments as well as members of the general public, and we g
N 16 j did that during the time that the rule was out for comment, s
17 ]
no at that time we had discussed various parts of the l
18 i regulations.
l MS. LETSCllE And can you explain for me how those 19 1
20 discussions contributed to your general understanding of the 21 l
concept of the full participation exercise as used in the NRC 22 regs?
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WITNESS SCHWARTZ:
I guess I was asked at that 2
time what was meant by a full participation exercise and I 3
described what my understanding of a full participation 4
exercise was to the individuals who were participating in 5
that meeting, and I had further discussions to sharpen my 6
understanding and their understanding of what full 7
participation meant.
8 MS. LETSCHE:
Mr. Schwartz, are 'you familiar with I
9 the FEMA term or guideline of a full-scale exercise?
Are you 10 familiar with that term?
11 I WITNESS SCHWARTZ:
I have heard the term, and I i
12 can't remember where it appears currently.
13 MS. LETSCHE:
I take it it is your understanding, I
14 l though, that FEMA in designing or reviewing exercises, 15 i scenarios, objectives or whatever, uses a term at least 16 equivalent to the full participation exercise term as used in
\\
17 !
the NRC regs; is that right?
1 18 WITNESS SCHWARTZ:
I can't point to it, but that's 19 my presumption, yes.
20 l MS. LETSCHE:
Now, you had referred to FEMA 21 j
Guidance Memorandum 17 and Mr. Irwin gave you a copy which p
22 was marked as Deposition Exhibit Number 4.
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WITNESS SCHWARTZ:
Right.
2 MS. LETSCHE:
Does that document refer anywhere to 3
full participation exercise?
4 WITNESS SCHWARTZ:
A quick review of the document, 5
I don't see the words " full participation exercise."
l 6
MS. LETSCHE:
Now, the guidance memorandum which 7
Mr. Irwin marked as Deposition Exhibit Number 5 is dated --
8 it is a draft dated August 15, 1986.
To your knowledge, has i
9 this ever been finalized or adopted by FEMA?
10 WITNESS SCHWARTZ:
The reason I'm thinking is 11 because I had recently seen a package of GMs that were sent
(}
4 12 up with a cover letter dated November 13, 1986, and I can't 13 recall whether EX-3 was in there in draft or final, so I 14 don't know whether it is-final or not, 15 ;
MS. LETSCHE:
From the date of this draft, I take j
16 it that Guidance Memorandum EX-3 would not have been used in L
17 l the preparatory activities for the Shoreham exercise; right?
l 18 WITNESS SCHWARTZ:
That's correct.
l MS. LETSCHE:
I believe you stated earlier that 19 20 the NRC relies upon the Regional Assistance Committee, which i
21 I is a FEMA body, in determining whether a proposed exercise l
l 1
22 l meets the requirements for a full participation exercise.
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2 WITNESS SCHWARTZ:
I think I said it differently.
3 NRC relies on FEMA to make the judgment and FEMA relies on 4
the Regional Assistance Committee.
5 MS. LETSCHE:
And you, I believe, said that you 6
understood that that in fact had taken place, that that 7
process was followed with respect to the February 13 Shoreham 8
exercise; is that right?
9 WITNESS SCHWARTZ:
I don't know.
10 WITNESS WEISS:
I said I did.
11 MS. LETSCHE:
Let me just stick with you for a
{}
12 minute and then I will get to you, Mr. Weiss.
I take it, 13 Mr. Schwartz, that you did not -- strike that.
Let me go to 14 you first, Mr. Weiss.
l 15 #
Who is the NRC representative on the Shoreham 16 RAC?
17 WITNESS WEISS:
Charles Amato, A-m-a-t-o.
18 MS. LETSCHE:
Did you, Mr. Weiss, attend any 19 shoreham RAC meetings at which the proposed objectives and 20 proposed scenario for the February 13 exercise were 21 !
discussed?
22 i WITNESS WEISS:
No.
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So I take it you don't knou from 2
personal knowledge whether there was any discussion at any 3
RAC meetings about whether or not those proposed objectives 4
or scenarios meet NRC requirements for full participation 5
exercise?
6 WITNESS WEISS:
I'm not aware of what went on at 7
those meetings.
8 MS. LETSCHE:
Are you familiar, Mr. Weiss, with 9
the term used by FEMA of a full scale exercise?
10 WITNESS WEISS:
I have heard it.
I have a general 11 understanding of what I think it means.
}
12 MS. LETSCHE:
Going back to you, Mr. Schwartz, you 13 said earlier when you were discussing with Mr. Irwin 14 different objectives, 35 objectives that were more important 15 and that whole discussion -- I will just refer to it that way 16
-- with him, and you talked about the idea that an exercise l
17 is intended to demonstrate an integrated capability to 18 l respond to an accident in a way that would protect the public l
l 19 health and safety.
I believe in that discussion, you 20 reference certain very important elements; decision-making, f
communication and protective actions were three you mentioned 21 l
fs 22 i that you said were sort of the basics that needed to be l
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1 covered; is that right?
2 WITNESS SCHWARTZ:
Yes.
3 MS. LETSCHE:
I take it you were saying that those 4
were basics that needed to be covered in order for an 5
exercise to be a full participation exercise; is that right?
6 WITNESS SCHWARTZ:
I think I indicated that those 7
were some of the ones that would need demonstration in an 8
exercise for it to be considered a full participation 9
exercise in demonstrating a plan.
10 MS. LETSCHE:
I assume you would agree with me 11 that you could have a demonstration of those basic or
(}
12 essential elements in an exercise that for other reasons 13 would not qualify as a full participation exercise.
Would 14 you agree with that statement?
15 WITNESS SCHWARTZ:
Can you repeat it one more 16 time, please?
17 MS. LETSCHE:
It is possible to have an exercise 18 which would include those basic elements of decision-making, 19 ;
communication and protective action recommendations, which 20 for other reasons would not qualify as a full participation l
exercise.
21 I
22 WITNESS SCHWARTZ:
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1 "for other reasons."
2 MS. LETSCHE:
Because of other things which might 3
not have been included or tested during the_ exercise.
4 WITNESS SCHWARTZ:
If you limit it to just the 5
elements that you described, I wouldn't consider it a full 6
participation exercise.
Because there are other things, and 7
if you look at the list of 35 elements, there are things that 8
ought to be in there, full participation exercises.
I'm 9
curious what you mean by "other."
10 MS. LETSCHE:
For instance, if you didn't have any 11 governmental participation, even if you supposedly tested
{}
12 decision-making or protective action recommendation 13 capabilities, communication capabilities, if you didn't have 14 any governmental participation, you wouldn't meet the 15 definition of a full participation exercise, any mobilization 16 of state or governmental personnel --
17 l WITNESS SCHWARTZ:
Is that in the sense of what 18 was agreed to in the demonstration of the plan under review, 19 full participation from functions that were carried out under 20 I the plan that was under review?
l 21 l MS. LETSCHE:
I'm not sure that was responsive to 22 my question.
Let me start again.
Are you familiar with the l
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term " partial participation exercise"?
2 WITNESS SCHWARTZ:
Yes.
3 MS. LETSCHE:
That's in the NRC Regs; right?
4 WITNESS SCHWARTZ:
Yes.
5 MS. LETSCHE:
According to Appendix E of Part 50, 6
10 CFR -- and I'm referring to footnote 5 on page 512 -- the 7
partial participation exercise means " appropriate off-site 8
authorities shall actively take part in the exercise 9
sufficient to test direction and control functions; i.e.,
10 protective action decision-making related to emergency 11 reaction levels, and communication capabilities among
{}
12 affected state and local authorities and the licensee."
13 I take it that if one had an exercise in which 14 there was state and local authority participation and which s
15 I included direction and control functions, it would not i
16 necessarily be a full participation exercise but in fact, 17 j
could be only a partial participation exercise; is that l
l l
18 !
right?
I 19 !
WITNESS SCHWARTZ:
The way you stated it, that is
(
20 l correct.
Yes.
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MS. LETSCHE:
I assume, Mr. Schwartz, you are A
22 l familiar with the decisions that have been rendered in the
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1 Shoreham licensing case by the Licensing Board and the Appeal 2
Board and the Commission?
3 WITNESS SCHWARTZ:
I can say I'm generally 4
familiar with those.
5 MS. LETSCHE:
I assume that you are aware of the 6
fact that there are many elements in the LILCO plan which 7
have been found to violate state law and as to which LILCO 8
does not have the legal authority to perform those 9
functions?
10 WITNESS SCHWARTZ:
That's correct.
11 MS. LETSCHE:
I assume you are aware of the fact
{}
12 that those functions include the making of protective action
[
13 recommendations and communication of those recommendations to 14 the public and other decision-making and police-power-type 15 functions; is that right?
16 MR. IRWIN:
May I note an objection on the grounds 17 of relevance.
The contingents of the local authority were 18 l proffered by Suffolk County and New York State and were I
19 l rejected by the Licensing Board.
20 l MS. LETSCHE:
I'm just following up on your h
l 21 l questions which are concerning Mr. Schwartz's understanding i
22 l of the full participation exercise and the failure of state 1
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2 MR. IRWIN:
I'm not objecting to questions of what 4
3
' was in or out of the exercise.
All lt'm saying, the question 4
of whether it was proscribed or not outside the law is 5
outside the scope of this proceeding.
6 MR. BORDENICK:
Whatever decision the Licensing 7
Board or Commission made speaks for themselves.
I don't kn'ow 8
the fruitfulness of the questions but you may continue.
i 9
MS. LETSCHE:
Do you remember my question?
10 WITNESS SCHWARTZ:
I'm sorry, I don't.
4
{
11 MS. LETSCHE:
Can you read it back, please?
12 (The reporter read the record as requested.)
13 WITNESS SCHWARTZ:
Yes.
I thought I answered that b
14 before.
15 MS. LETSCHE:
I think you did actually, but we l
16 have to let all of the lawyers say their piece here.
17 And I assume you are also aware, Mr. Schwartz, 18 that during the Shoreham exercise, those functions affected 19 by the legal authority issue were not performed by LILCO l
personnel during the exercise?
20 21 WITNESS SCHWARTZ:
That's right.
22 MS. LETSCHE:
And Mr. Weiss, I believe you said O
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1 earlier that the simulators of the state and local officials 2
at the exercise were instructed not to assume any 3
decision-making or response roles during that exercise; is 4
that right?
5 WITNESS WEISS:
That's right.
6 MS. LETSCHE:
Mr. Schwartz, what documents or 7
information concerning the results of the Shoreham exercise, 8
what happened during the exercise, have you reviewed?
9 WITNESS SCHWARTZ:
FEMA report of the exercise.
10 MS. LETSCHE:
Anything else?
11 WITNESS SCHWARTZ:
The document we were just shown
}
12 a couple of minutes ago.
13 MS. LETSCHE:
Deposition Exhibit 6?
14 WITNESS SCHWARTZ:
Yes.
Others perhaps, but principally the exdrcise report by FEMA.
(
15 k
16 MS. LETSt:HE :
Would you look for me at Deposition 17 Exhibit Number 3?
That's the excerpts, or all of Appendix E, i
l 18 and let's look at footnote number 4.
Famous footnote number I
l 19 4.
Can you t 11 me what local or state authorities or l
20 )
perso;mel phy ically or actively took part in February 13 l
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Shoreham exercise?
21 )
22 WITNESS SCHWARTZ:
I know of no state or local O
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1 authorities that physically actively took part.
2 MS. LETSCHE:
I assume you would agree with that, 3
Mr. Weiss?
4 WITNESS WEISS:
Yes.
5 MS. LETSCHE:
I take it you would both agree with 6
the fact that during that February 13 exercise, there was no 7
testing of the integrated capability of any state or local 8
authorities to adequately assess or respond to an accident at 9
the Shoreham plant?
10 WITNESS SCHWARTZ:
Yes, I would agree.
11 WITNESS WEISS:
Yes.
}
12 MS. LETSCHE:
You would agree also?
13 WITNESS WEISS:
Yes.
14 MS. LETSCHE:
I take it, Mr. Schwartz, that you 15 are aware of the fact that FEMA has stated that the Shoreham 16
-- that FEMA considers the Shoreham exercise to have been a 17 limited rather than a full exercise?
t i
18 :
WITNESS SCHWARTZ:
I'm not aware of that.
c I
19 i MS. LETSCHE:
Mr. Weiss, are you aware of that?
i 20 i WITNESS WEISS:
I'm not aware of that.
t I
21 MS. LETSCHE:
Could we take a five-minute break l
l g
22 i and review my notes?
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2 MS. LETSCHE:
Mr. Weiss, you were not an evaluator 3
at the Shoreham exercise, were you?
4 WITNESS WEISS:
I was not.
5 MS. LETSCHE:
Are either one of you aware of any 6
instances in which there has been litigation concerning 7
off-site emergency planning exercises and there was a 8
challenge as to whether or not the exercise was a full 9
participation exercise?
10 WITNESS SCHWARTZ:
I'm not aware of any.
11 WITNESS WEISS:
I'm not either.
}
12 MS. LETSCHE:
I don't have any other questions.
13 MR. ZAHNLEUTER:
Mr. Schwartz, I think you told 14 Ms. Letsche that the NRC relies on FEMA to make a judgment 15 and FEMA relies on the RAC.
Do you remember that?
16 WITNESS SCHWARTZ:
Yes.
17 MR. ZAHNLEUTER:
Could you explain what judgment 18 l you are referring to?
19 WITNESS SCHWARTZ:
The judgment with respect to 20 the scope and depth of an exercise.
h 21 l MR. ZAHNLEUTER:
What do you mean by " scope and I
e-22 depth"?
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WITNESS SCHWARTZ:
If an exercise is to be a full 2
participation exercise, and to meet certain objectives, then 3
we rely on the RAC to review those objectives and also to s
4 review the scenario to see, one, if it covers the areas to be 5
exercised; in other words, of the 35 exercise objectives from 6 $ the FEMA guidance, are they covering enough of those; and 7
also, does the scenario provide enough depth with respect to 8
challenging the responders to exercise that particular 9
element under the criteria.
10 MR. ZAHNLEUTER:
When you say you rely on FEMA, do 11 you automatically accept whatever judgment FEMA reaches?
j
)
12 WITNESS SCHWARTZ:
I would modify the statement 13 slightly.
Automatically accept, no.
I think, as I mentioned 14 earlier as part of the RAC process, that there's give and 15 take in a RAC between and among the various members, and NRC t
16 is a participant on a RAC.
Once that judgment is made, then l
NRC would accept.
17 l
18 l MR. ZAHNLEUTER:
Thank you.
I don't have any i
19 !
other questions.
20 MR. BORDENICK:
FEMA?
21 MR. CUMMING:
No questions.
b 22 MR. BORDENICK:
Done?
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1 MR. IRWIN:
I have just one question.
Gentlemen, 2
when Ms. Letsche asked you whether you were aware of any 3
state and/or county governmental participation in the 4
exercise for Shoreham on February 13 of last year, you all 5
answered that you were not aware of any participation.
When 6
you answered that question, did you have in mind either 7
Nassau County or the State of Connecticut in your statement 8
that there were no -- there was no participation by state or 9
local governments whatever?
10 WITNESS WEISS:
I guess I had to ignore that, 11 yes.
12 WITNESS SCHWARTZ:
I didn't consider that.
13 MR. IRWIN:
No further questions.
14 MS. LETSCHE:
To your knowledge, did either Nassau I
l County or the State of Connecticut participate in the 15 16 Shoreham exercise?
17 WITNESS SCHWARTZ:
I have no knowledge as to l
f whether they did or didn't.
18 i
19 l WITNESS WEISS:
I am not aware specifically of 20 l Nassau County, although I know facilities in Nassau County i
21 were utilized.
I don't know whether they were involved in rg 22 that.
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MS. LETSCHE:
What about Connecticut?
2 WITNESS WEISS:
Same thing with Connecticut.
3 MR. IRWIN:
I have no more questions.
4 MR. BORDENICK:
On Exhibits 2 and 3 which have 5
been marked for identification which Mr. Irwin gave to you, 6
they both indicate, 1-1-86 edition, have there been any 7
changes to either 10 CFR 50.47 or Appendix E, Part 556(e),
8 1/1/86?
9 WITNESS SCHWARTZ:
I'm not familiar with any.
10 Wait a minute.
4 4
~S 11 WITNESS WEISS:
Not to my knowledge.
(O 12 WITNESS SCHWARTZ:
No.
13 MR. BORDENICK:
Same answer, Mr. Weiss?
14 WITNESS WEISS:
Same.
I 15 MR. BORDENICK:
Mr. Schwartz, I wonder if you I
16 could clarify or elaborate on a response you gave to 17 Ms. Letsche regarding your review of the LILCO plan.
She 18 l asked whether or not you had reviewed the plan and I have 1
I 19 i forgotten your answer.
Is there anything you want to add to 20 I your previous answer -- or she talked about context, and in 21 my mind I don't know whether you answered the question as to l
22 l what context you reviewed the plan in.
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1 MS. LETSCHE:
Let me note my objection to that i
2 question.
3 WITNESS SCHWARTZ:
I'm familiar with the plan.
4 I'm familiar with the reviews that were done on the plan but 5
I have not personally reviewed the whole plan myself.
6 MR. BORDENICK:
Is it part of your professional 7
responsibility with the NRC to review verbatim utility or 8
other plans?
9 WITNESS SCHWARTZ:
No, it is not.
10 MR. BORDENICK:
No further questions.
4 11 (Whereupon, at 12:10 p.m.,
the depositions were 12 concluded.)
l 13 14 15 1
16 17 1
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73 CERTIFICATE OF NOTARY PUBLIC & REPORTER OV I,
KATHIE S.
WELLER the officer before whom the foregoing deposition was taken, do hereby certify that the witness whose testimony appears in the foregoing deposition was duly sworn by me; that the testimony of said witness was taken in shorthand and thereafter reduced to typewriting by me or under my direction; that said deposition is a true record of the testimony given by said witness; that I am neither counsel
- for, related to, nor employed by any of the parties to the action in which this deposition was taken;
- and, further, that I am not m
a relative or employee of any attorney or counsel employed by the parties
- hereto, nor financially or otherwise interested in the outcome of this action.
1 f
3bjaE
/
Notary Public in and for the State of Maryland My Commission Expires 7"[' h [
O
lI linton NUREG-Of FEMA-REI Rev.1 L;. 4 as
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Criteria for Preparation and Evaluation of Radiological Emergency Response Plans an Preparedness in Support of Nuclear Power Plants U.S. Nuclear Regulatory Federal Emergency Managen Commission Agency
~
1 9",
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J O N.
Exercises and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and mai6tain key skills, and deficiencies identified as a result of exercises or drills are (will be) correct 6d.
Applicability and Cross Evaluation Criteria Reference to Plans Licensee State Local 1.a.
An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and organizations. The emergency preparedness exercise shall simulate C) g'"ical releases which would require response by
- r'*"c' '" "' '" "' "*d' ' -
offsite authorities.
Exercises shall be conducted as set forth in NRC and FEMA rules.
X X
X b.
An exercise shall include mobilization of State and local personnel and resources adequate to verify the capability to respond to an accident scenario requiring response. The organization shall provide for a critique of the annual exercise by Federal and State observers / evaluators. The scenario should be varied from year to year such that all major elements of the plans and preparedness organiza-tions are tested within a five-year period.
Each organization should make provisions to l.
start an exercise between 6:00 p.m. and mid-night, and another between midnight and i
6:00 a.m. once every six years.
Exercises should be conducted under various weather conditions.
Some exercises should be i
unannounced.
X X
X l
1O l
l l
l
t U,_.
N.
Exercises and Drills (continued)
Applicability and Cross Evaluation Criteria Reference to Plans I
Licensee State Local 2.
A drill is a supervisec instruction period aimed at testing, developing and maintaining skills in a particular operation. A drill is often a component of an exercise. A drill shall be supervised and evaluated by a qualified drill instructor.
Each organiza-i tion shall conduct drills, in addition to the annual exercise at the frequencies indicated below:
a.
Comunication Drills Comunications with State and local governments within the plume exposure pathway Emergency Planning Zone shall be tested monthly. Com-munications with Federal emergency response p/
organizations and States within the ingestion n
pathway shall be tested quarterly. Comuni-cations between the nuclear facility, State and local emergency operations centers, and field assessment teams shall be tested annually. Comunication drills shall also include the aspect of understanding the content of messages.
X X
X b.
Fire Drills Fire drills shall be conducted in accordance with the plant (nuclear facility) technical specifications.
X c.
Medical Emergency Drills A medical emergency drill involving a simulated contaminated individual which contains provisions for participation by the local support services agencies (i.e., ambulance and offsite medical treatment facility) shall be conducted annually. The offsite portions of the medical drill may be performed as part c.,
of the required annual exercise.
X X
Q
4 O N.
Exercises and Drills (continued)
Applicability and Cross Evaluation Criteria Reference to Plans Licensee State Local d.
Radiological Monitoring Drills Plant environs and radiological monitoring drills (onsite and offsite) shall be conducted annually. These drills shall include collec-tion and analysis of all sample media (e.g.,
water, vegetation, soil and air), and pro-visions for communications and record keeping.
The State drills need not be at each site.
Where appropriate, local organizations shall participate.
X X
X e.
Health Physics Drills (1) Health Physics drills shall be conducted semi-annually which involve O
response to aad anaissis of. simuiated elevated airborne and liquid samples and direct radiation measurements in the environment. The State drills need not be at each site.
X X
(2) Analysis of inplant liquid samples with actual elevated radiation levels including use of the post-accident sampling system shall be included in Health Physics drills by licensees annually.
X 3.
Each organization shall describe how exercises and drills are to be carried out to allow free play for decisionmaking and to meet the following objectives. Pending the develop-ment of exercise scenarios and exercise evalua-tion guidance by NRC and FEMA the scenarios for use in exercises and drills shall include but not be limited to, the following:
a.
The basic objective (s) of each drill and exercise and appropriate evaluation criteria; X
X X
, O N.
Exercises and Drills (continued)
Applicability and Cross Evaluation Criteria Reference to Plans Licensee State Local b.
Thedate(s),timeperiod, place (s)and participating organizations; X
X X
c.
The simulated events; X
X X
l d.
A time schedule of real and simulated initiating events; X
X X
e.
A narrative sunnary describing the conduct of the exercises or drills to include such things as simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing, deployment of radiological monitoring teams, and public information activities; and X
X X
f s
f.
A description of the arrangements for and advance materials to be provided to official observers.
X X
X 4.
Official observers from Federal, State or local governments will observe, evaluate, and critique the required exercises. A critique shall be scheduled at the conclu-sion of the exercise to evaluate the ability of organizations to respond as called for in the plan. The critique shall be cor. ducted as soon as practicable after the exercise, and a formal evaluation should result from the critique.
X X
X 5.
Each organization shall establish means for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, l
and for assigning responsibility for implementing corrective actions.
Each organization shall establish management control used to ensure that corrective actions are implemented.
X X
X i O
g
{ 50.47 10 CFR Ch. I (1 134 Ediq fuel, excluding the cladding surround-9 50.47 Emergency plans.
ing the plenum solume, were to react-
<an 1) Except as provideo i (4) Coolable geometry Calcula* ed graph ad) of this section. no o %
changes in core geometry shall e license for a nuclear po%er reacto [8 such that the core remains amenaole be issued unless a finding is rnad to coolmg.
NRC that there is reasonable D
< 5) Long-temt cooling. Af ter any cal-ance that adequate protectise culated successf ul initial operation of ures can and will be taken in the the ECCS. the calculated core temper of a radiological emergency
%t ature shall be maintained at an ac-
<2) The NRC will base its find:
ceptably low s alue and decay heat a review of the Federal Eme shall be remos ed for the extended Management Agency [FEMAl fin [#I period of time required by t he long' and determinations as to w heth" la ed radioact ivit y remaining in the State and local emergency plan 3 W
core adequate and whether there is re tc) As used in this section. i l) Loss-able assurance that they can be t of-coolant accidents ( LOCA s) are by mented. and on the NRC asacss[
pothetical accidents that would result to w hether the applicant's on3 as from the lou of reactor coolant, at a emergency plans are adequate an rate in excess of the capability of the whether there is reasonable assu reactor coolant makeup system. from that they can be implementc<
breaks in pipes in the reactor coolant FEMA finding will primarily be pressure boundary up to and including on a review of the plans. Any oth, g i
a breat equivalent in size to the formation already available to P may be considered in assessing wg%
double-ended rupt ure of the largest pipe m the reactor coolant system.
er there is reasonaWie assurance that
( 2) An evaluation model is the calcu-the plans cart be tmplemented In lational framework for evaluating the NRC licensfug' proceeding a behavior of the reactor system during finding will constitute a r*buttag, a postulated loss-of coolant accident presurnption on questions of %
r LOCA ) It includes one or more com-and implementation capability.
puter programs and all other informa-(b) The onsite and. excepa as Duom tion necessary for application of the edin paragraph (d) of this sectiost off.
calculational framewcrk to a specific site emergency response plans fasen LOCA, such as m.thematical modela clear power reactoFaa muste meet the used, assumptions included in the pro-following standards; grams. procedure for treating the pro-(1) Primary responsibilities for emar-gram input and output information.
gency response by the nuclear facility specification of those portions of anal-licensee and by State and local organt.
ysis not included in computer p ro-zations within the Emergency Plar grams values of parameters. and all ning Zones have been assigned, the other information necessary to specify emergency responsibilities of the van-the calculational procedure.
ous supporting organizat.lons have (d) The requirementa of this section been specifically established, and eact$
are in addition to any cther require-principal response osaanization has ments applicable to ECCS set forth in staff to respond and to augment its this part. The criteria set fort h in I
initial response on a continuous baan paragraph (b), with cooling perform-(2) On shift facility licensee respon ance calculated in accordance with an sib 111tles for emergency response are acceptable evaluation model, are in unambiguously
- defined, adequa's implementation of the general re-staffing to provide initial facility aca qutrementa with respect to ECCS cool-dent response in key functional areu i
ing performance design set fort h in is maintatned at all times, timely aug this part, including in particular Crite-mentation of response capabilities a rion 35 of Appendix A.
available and the interf aces amora
( 39 FR 1002. Jan 4 1974, as amended at 39 various onsite response activities and lit 27121 Juiy 25 1974 40 FR 8789 Mar 3.
of fsite support and response actmtles d
19751 are specified 454 i
1
- DEPOS W N EXHistT 1
' )
1u
e s 50.47 10 CFR Ch.1 (1-186 E(q fuel. excludmg the cladding surround ll 50 47 Emergeno plans.
ing the plenum solume. were to react
.a"1 Except a.s p ros ided graph < d i of this section no o'n U"4
<4i Coola ble geo met ry Calcula* rd license for a nuclear power teap, at*t changes in core geometry 3 hall e
such that the core remains amenaole be ssued unless a fmding is rn U
to cooling-NRC that t here is reasonable D
c 5 > Lorig-term cooling Af ter any cal-ance t hat adequat e protectne culated successful mitial operation of ures can and wiH be taken in the. N the ECCS the calculated core temper of a radiological emergenc) ature shall be maintained at an ac-2 ' The NRC a dl base its findtn l
ceptably low s alue and deca y heat a res iew of the Federal Erner shall be remot ed for the extended Managemer't Agency (FEMA) find [
period of time required bs the long and de te rminations as to
% het i n ed radioac t is it y remaining m the State and local emergency Plansh core adequate and w hether there is reg
<ci As used in this section < l ' Loss-able assurance that they can be a "
y of coolant accidents < LOCA s > are hy-mented. and on t he NRC assess pot hetical accidents t hat w ould result as to whether the apphcant's on
~
f rom the loss of reactor coolant at a emergency plans are adequate
\\-
an rate m excess of the capability of t F-w hether t here is reasonable assuran reactor coolant makeup system. f rt i.
t hat they can be implemented 4
breaks in pipes in the reactor coolant FEMA finding will primartly be %
pressure boundary up to and meluding on a review of the plans. Any ot.hw g i
a break equivalent m size to the formation already available to pggg double ended rupt ure of the la gest may be considered in assessing Whew pipe in the reactor coolant system-er there is reasonaUle assurana agg i 21 An es aluation model is the calcu-the plans can be tmplemented. In g lational framework for evaluating the NRC licensing proceeding, a FWA behavior of the reactor system during finding W.ll constitute a rebut %
a postulated loss-of coolant accident presumption on questions of g
,LOCAi It includes one or more com-and implementation capability puter programs and all other informa-(b) The onsite and, except as psom i
tion necessary for application of the ed in paragraph i d) of this sectaos agg.
calculational framework to a speelfic site emergency response plans foam LOCA, such as mathematical models clear power reactoras must. meet the used. assumptions included in the pro-following standards.
grams, procedure for treating the pro-t 1) Primary responsibilities for emar-gram input and output information.
gency response by the nuclear facility specification of those portions of anal-licensee and by State and local organ!
y sts not meluded in computer p ro-zations within the Emergency Plac grams. values of parameters, and all ning Zones have been assigned. the other information necessary to specif y emergency responalbilities of the van-the calculational procedure ous supporting organlaations have
< di The requirements of this section been specifically established. and eact$
are in addition to any other require-principal response organization has j
ments applicable to ECCS set forth in staff to respond and to augment :ts t his part The criterta set foi t h in initial response on a continuous tiasia I
paragraph ( b t with coolmg per f o rm-
<2) On-shif t faculty licensee respot ance calculated in accordance with an sibilities for emergency response e acceptable es aluation model, are in unambiguously de fined, adequa'>
implementation of the general re.
staf fing to provide initial f actht) Am 1
quirements with respect to ECCS cool ~ dent response m key functional arau l
mg per f ormance design set f ort h in is maintained at all times timet) as this part. including m particular Crite' mentation of response capabilities 3 rion 35 of Appendix A available and the interfaces amo r.g
( 39 tm t002 J an 4 1974. as amended at 39 s arious onsite response activities ad FH 27121 Jul) 25 1974 to FH 8789 Mar 3 of fsite support and response actml.cs 19751 are specified N r 454 I
- ogpostT1oM Ex HistT 1
)
E
idition)
Nuclear Regulatory Commission
@50A7
< 3 ' Arrangements for requesting and
'10' A range of prot ectis e actioru ef f ect n els using assist ance resources hat e "een deseloped for t he paume e s hat e been made arrangements to at posure pat hw as EPZ for emergenes commodate State and local staf f at the w orkers and the public Guidelines for acenser s near site Emergencs Opt r the choice of protectn e actions during at io n.s Fac1h t s has e been made and an emergency consistent with Federal
,p ot her o r ganuat o ms capable of aug guldant e are des eloped and in plac e ment ing the planned responw hat e and protectat actions for the inges tion exposure pat hw as EPZ appropr:
been ide m ified at e to t he locale has e been deseloped 4 ' A at andard emergencs c la.s.sif ica
' II ' Means for cont roll:ng radiologi
- Jon and act ;on les el scheme t he bases of w hich incude f ac;11t s ss stem and cai exposures in an emergencs, are es t
e f fluer;! parameters is m use % the t abhshed for emergem s workers The nuclear f a( this acensee and State and means f or controlling radiological ex posures shall include exposure guide e ar, local res po nse plans call for reliance en information prosided b) farthry h hnes consistent with EPA Emergencs re aso n tm ib Worker and Lif esasing Act a it y Pro ce ruces for de t e rmina t ions of mini erg tect n e Action Guides mum mitial of fsite response measures onsit e
< 12 > Arrang;nent,s are made f or medi
! 5 ' Procedures hat e been established cal sers ices for contamir.ated injured te and for notification by the heensee of surance inda lduals State and local response organizations 13, General plans for recovery and it e e
i and for notification of emergency per reentry are des eloped ther in sonnel b) all organizations. t he con
<14) Periodic exercises are i will be,
VEMA tent of init.&i and followup messages conducted to evaluate major portions w het h to res po nse organizations and the of emergeno response capabilities
,ce t hat pubhc h as been established. and periodic drills are t will be ' conducted in any me arn to proside early notification t desel p and maintain ke> skills, and FEM A and clear instruction to the populace def tetencies identified a.s a result of ex
>uttable within the plume exposure pat hw ay eretses or drills are < will be > corrected leq uar).
Emergency Planning Zone has e been U
"O est ablish ed sponse training is p ros ided to those prosid i
i6) Provisions exist f or prompt com who may be called on to assist in an ion off munications among principal response emergency for nu organizations to emergency personnel 164 Res ponsibilit ies f or plan desel eet IhC and to the public opment and resicw and f or distribu (7) Inf ormation is made as allable to tion of emergency plans are estab J ir emer the pubhc on a periodic basis on ho*
lished and planners are properls
' f acilit s thes will be notified and w hat t heir t rained organ untial actions should be in an emer 4 c n 1 ' Failure to meet t he applicable i s Plan gencs ie g hstening to a local broad standards set f orth in paragraph. b of l
ed. the cast station and remaining indoors '
t his section may result in the Commis he sari the principal points of contact w it h sion declining to issue an operating h t he news media f o, dissemination of ce nse hom es er t he applicant will hat e h a ',
nd cat)h, inf ormation during an emergency i nn an opport unit y to demonst r ate to t he on h a^
cluding the physical location or loca satisf action of the Co mmissio n t hat
",nt it "
tions i are established in ads ance and deficiencies in the plan 3 are not signif is ti a.s i" procedures f or coordinated dissemina trant f or the plant in question t hat re5P""
tion of laf ormation to t he public are adeq u a t e interim co m pe nsat in g ac nse ar est ablis h ed tions hase be en or w ill be !anen 4"4 "" (,
<8 Adequat e emergenes f acilltles promptly or that t here are ot her com and equipment to support the emer pelling re a. sons to permit plam oper genes response are prosided and main at ton a
M" tained
<2-Generally the plume e x pos u re i96 Adequate methods s y ste mt and pathway EPZ for nuclear power plants t
equipment f or asacs. sing and monitor shall conatst of an area about 10 miles mg act ual or potential of fatte conac
' 16 km ' in radius and the ingestion quences of a radiological emergency pat hw as EPZ shall conatst of an area
^ '
g.,
condition are in use about 50 miles < 80 km ' in radiu3 Tne 455
y 7r 4
A Nudear R ui 10 CFR Ch.1 (1-1-46 Edition) 4 50.48 orotec' or exact s tle and configurar am of the
'ection program for the f aciht y ; den d
p' 2
EPLs surrounding a particular nuc! ear tif y t he various positions within the a
.N, ru power reactor shall be determmed in censee s organization t hat are respon protectim si
' relation to local *mergenes respo rtse sibile f or the program. state t he au t he st at!
thorttles that are delegated to each of
';on e' needs and capabQtgs as t hev are af ifected bs such condit;ons as demogra tilese positions to implement t hose re before A; j
phy t opog raph y land c haracte.stics.
sponsibilities, and outime the plans l
, a; pose w
access routes and i u risdict ional for fire protection, fire detection and pubmhed 2
bo u n d a rie s The size of ' he EPZs also 3uppression capability. and hmitation j
g s p e, ' t of fire damage The plan shall also de urcs cc.
g mas be determmed on a case bs ca.se a r pow '
7 b a.s i s t<>r e cooled nuciear reac t o rs sc ri be specific features necessar s m I
pr;or h,
4 and for reat t ors w it h an aut horued implement the program described abose such as administralise cont rob
'he appm 5
pow er let H irss t han 250 MW ' hermai 4
The plans for the ingestion pat hw ay and personnel requirements for fire 4xg7g.
g g
presention and manual fire suppres lg.he m shah f ocus on sucn actions ;ts are ap ston activities, automatic and manual III J and propriate to prot ect t he f ood mgestion
- 1) operated fire detection arid suppres
,, A;;
g pathwas sion systems, and t he means to ;trnit req u ired 6
di Not a it hst andmg ihe require.
fire damage to structures, systems or Appendix ments of paragraphs. a! and b, of t his com ponents important to safety so M ted by M
section no NHC or FE M A res tew.
t hat the capability to safely shut town co m ple t ec f mdings. or determinations concernmg t he plant is ensured '
t, Th<
I the 3 tate of of fsite emergenes pre N
paredness or the adequacy of a'nd ca
' b > Appendix R to this part estab-t hat into hshes fire protection features regtured tis e contr pability to implement St ate and local to satisfy Criterton 3 of Appendix A to t rammg.
i of fsite emergency plans are required this part with respect to certain gener 30 da> s a:
prior to issuance of an operating h I
ic issues for nuclear power plants 11 section an cense a u t h o rizin g only fuel loadmg censed to operate prior to January 1.
- 2) Tb T
snd or low pow er o pe rat io ns iup to 1979 Except for the requirements of t hat into M of the rated power : Insof ar a.s Sections III.G. III.J. and III O the tions t ha' emergency plannmg and preparedness pros tstons of Appendix R to this part appros al requirements are concerned, a hcense shall not be applicable to nuclear implemen 1
I aut horizmg fuel loading and or lo w.
power plants licensed to operate prior t he ef fer' 1
power operation may be issued af ter a to January 1.1979. to the extent that Appendix finding is made by the NRC that the
<3) Th(
E fire protection features proposed or state of o nsit e emergency prepared implemented by the licensee has e gxcept fo ness pros ides reasonabic assurance been accepted by the NRC staf f as sat approval 5
t hat adequate protectis e measures can 1sfying the provtstona of Appendix A section. t 7
and will be taken m t he esent of a ra.
3 to Branch Technical Position BTP modificat dioicgical eme rgenc y The NRC w ill APCSB 9 5 l
- reflected in staf f fire base t his finding on its a.ssessment of the applicant s e me r g e nc y plans g3gg y
aga nst the pert ment c andarcis in
' nasic fire protecuan guidance for n 4ch ed in f our <
Suppi h
paragraph ' b ! of this,ection and Ap ar power planta :s contained in t w o NRC document 8 f iun Need.
I pendix E of t his part Branch T ec hnical Poaltion A u xillary r ion date<
Samp'
{
Sec 161 b and a IN b L 83 703 68 Pos er Cons mion System Branch HTP Stat 948 42 l' S C 2201' we 201 as APCSB 9 5 i Guideilnes for Ptre Protec May 12 19
-E l
amended Pub t. 93 438 88 Stat 12 4 2. Pu b t ion for N uclear Poser Planta for new g,
L. 94 79 89 St at 413 42 t' S C 5841 p.anta docketed af ter J uly 1,
1976 da ted mn a. Re.
g
' 45 Vit 55409 Aug 8 1980 as amended at 47 May 1976 m am y FR 30215 Jul> 13 1982 47 Fil 40537 Sept A p pendix A to BTP APCSB 95i m
j
- 5,982 49 VR 27736 Ju.s 6 1984 50 FR Guidelines for Pire Prwertior for N!n eat y g; 7
19124 Mas H 1985}
Pow er Planta Doc k et ed Prior to los gy, 1
197H far plan ts ' h at w e re..pe r a ?. n g g
p 1 der s arious st ages ot tes4gn < ir onM g e p, y 4 50 4 m Fire protection F "d ;
'[. 6 a Eac h ope ra t in g nuclear pow er Q
9 plant shall hate a fire protection plan gg y, %,, 4 3
t hat satisfies Crtterion 3 < >f Appendix
. arification and gmdance a:t h
'et 4 r,
}
A to t his part This fire prot ec t ion
'o permebte uternat a m to sat ah W r,,
)
,e plan shall 1escribe t he os erall fire pro m
s 1
456 gn a
"l i
]
E
?
c
^
i G
10 CFR Ch.1 (1-1-86 Edition' Nuclear Re
_3 Part 50. App. E E
g k
'e er' F
JI Ace: < Anis WH!cH apt Ne w t s F.ewrc ar'
' e r a t; e n e t ;m n ao
'd'"
an'
' nara.a.
..t..
a'...n3
~mn**
gLc e n,",
an Ewititrs
.ne
===nd A A ppiica tio rts '
co'ist ac ti' n pel:
.49 FR 35753 Sept 2 1984 u amenden v
^'
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7
% FR 18853 Ma) 3 1985!
[
M 1 Ev i ma te ;' -' ns t % : n:n < m t3 The.n ga4 a
f ormat un :nat A ni nermai.s De requ. red APPENDI X D - [ Rewr\\ ed)
.y m.
appucant3 A ha n are ne A.y t ormed e nt.t.e3 r
A ni not m!f er n si < >pe f r om ' h at reg oired
.f APPENDIX E EMEP0EN( Y PU N NING w t est ab n 3 h e d
.r g an a a t.o n.3 Au ord mga ap imm
.)
.bmit es'; mat e3 a.s de PNEPAFEDNES5 FOR PFoDtcnoN sND p p y3
[
i-
[
p 6 an t.s
,to +
l,
< r.hed a nii, ', n'ao ched > r g an d ai n 'ns l' rILIZ A TION E WII ITIb i
_ s ns %n n
.mn The ep..
4-
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1
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de n' < f s e
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y
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- + 4L. a
+
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- s
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pas
'he
- 3 e,
i
'he
! In-
,d u c t.o n pnd at
.,f ng
'te fu. is j
(( F t.e Prei;minan Saf e's Ana.%, Re pt r*
]
y amoun!
e..n'a.: ed
, m e a<
A.t h +
a spect u eac h somrce t.e app.i. at ion snuu.d Ill The Fmat Saf et Ana.) w Repor g; %
d Jes< r :De.n 1et ad ' he appucant3.eg a; and IV Content of Emergent Pmns E
financia; relat mnships wit h ;ts st oc a hoiders V 1mplementing Procedures f t' e P'e 3
t
< orporate af filiates or others such as !!
i INTuoDtW!om nai.
'o n '
k nan ( tai mst :t ut ions upon A h;ch t he appit ant
.3 rea tng for f ;n anc ial assistance If e
Each appitcant f or a construction perm.'
W ^[
'he su u r( es of fand3 rehed apon.nclude a re p red M 150 34< a to :nclude
.n 'he I
parent c ompames Jr Jther corporate af f u preliminary safet) anal > sis report a tsc us
^'
{
ates inf ormation s u ppor t the f inanciai
,lon of prehm nar) plans for coping Ann i
M q
'apabiot) a f e ac h s s h compan) or af f'. hat e emergencies Each apphcant f or an operal y
to m ee t as comm f ments to the appncant
- ng ace nse is required bs 150 34 b
'o n
.E r
should be w t f ort h :n t he appilcation T h is clude in the final safety analysis r e po r'
_E h
-6
.nf ormat;un should be of the same amd and ph f or coping wit h emergencies
^$
Y M
e scope a.s w ou.d be required.f the parent Th is a p pe ndi x establishes mintmum e
I*
\\' "*. 'r ompanies or af f d.ates were in f act t he ap quirements for emergenc) plans for de.n
- p..c an t ()rdinarns
.t w ;!! be necessar) t hat attaining an acceptable s' ate of emergenc) reparedness These plans shall be de copies of agreements or c o n t r ac ts among
~
the comparues be wut)mitted cribed generally In the preliminars safet:
not ed ear.;er ;n t his appendix. an appal analists report and submitted as part of t r.e
' ' f.
A3
(
['
j cant A hich is a newo f ormed ent it ) w ill final safety analy sts report
)y normaic not be :n a posit;un to subm;t the The potential radiological ha.zards to t he uzat ot a i
h public associated with the operation of re g, g r
asua) !) pes of ba.ance sheets and,ncome statements refiertmg t he resuits of prior op search and test reactors and fuel f aciuties a g
e ra t ions The appin act shmd hom es er in censed ander 10 CFR Parts 50 and 70 in
((((
fy,
9 r
==
Nde m
's appocation a statement of ;ta s olse considerations dif ferent t han those as g
asseta. Lab 1! ties and apit ai st ruct ~ re a.s of socihted wit h nuclear pow er reactors Conse h
'he date of t ne app D ation
- uently
'he size of Emergene) P? annin g
%nes EPZ.s ' for f ac u lt ies other thar
,Il A N N 4 L F.I N 4 N c 41 ST 4 rtM ENT E
f L
Eas h t older of a construction permit for a
h f or pos er reactors are disi med.
~-
t K
=
produ tion or a.!izat;on 'ac n;t) of a type W E M U A 5 20 i 78 Oli Ptann;rg
-si described m 150 21 b or i 50 22 or a testmg Basis for the Des etopme n t of State and b
factht)
.3 required by 6 50 7 b ' to file e ta Local Gos ernment Radio;ogicaa Em er g enc s Response Plans m Support of Light W ater b
ann ual f in ancial re po rt with the Comints sion at t he time of tsauance thereof This re.
Nuclear Power Planta December 1978 The
]
]
5 autrement does not app!) to heensees or size of the EPZa for a nucl ear power piant
=
holders of construction permits for medical shad be dete rmined m reistion
'o oc a.
9
[
and researt t. reactors emergene) response needs and capabi;ities 9
r as ne) are af f ected by such 'onditions a3 g
I,s ado t Ti o M 41 INronwarlom demographs opographs.and c haract em 2
' he ( 'omm Lssion ma) f rom f jme ' o rne es acce's roij t es and. '.r'5dic' ;ona. ho u nd 8
The uze of ' he EPh 4.so ma+ De 1e u4 j
5 e<1.est
'he appucant ahether an es'ab ar;es ere ned m a a.se bs case n as.s
',r g ar sne i organizavn mr new o rermed eru,
. suom:t additiona; or more detai ed nror
< mied
,uc. ear eact o rs and n-r e ac t o rs y
sP2 FM ' han D' 4
h m at ion res pec t !n g. ts f.nanc;a: arrange w ;t h an au f t.orized POn er.e l
7, T,ents "nore det ai.ed inf ormal;on r esper t ;ng MW therma;
( }ene ra. ; s e i "Le e s pd is f' nam.a6 gr"a n g e m e n ta %Dd statas
')f wure pat h% a) EP7 '
n4. ear p wer pian'5
[g,1,,
n, M f ne f, n n.n! :rmation s deemed neces 2
+.
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M -
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q
, DEPOSITION i
~
EXHIBIT c
s
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i 1
L e
t
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m
_ 86 Edition)
Nuclear Regulatory Commission Part 50, App. E
- f*"'
4e ea.
r am1 tre 1egree
'c A h v r.
i.n
- ns 'e
- n d;..d.a r 'i
s rear
C e
er sf s
mer ! a<
':ta-fr; 4
c.q s e i r.~
! Ill !\\ and V a0 ne F
Pr wns he m a tle r e m e r g + ra s as e*
b i i
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,,u, en, y,
,,,me C
s a e !ac ir is a,a. -
w.
ure 1ar a resm J. e nse 1 +
es
%A - o 4ro rg
e am'+
parag:aphs p
p7,,;s;gns <<
3, ra m. r.g progran-fo r
aar ar
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f* r se ad f
4,gg, rp, e m n(, gj; n g is,
.al.
i o A
u wr L'
e
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io c,
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gr aat n an 4 +
<Ae NHl' s
,s an e me rgeni
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e S'a',
a'd
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s1'.
,rrerge g
.t!.
.t 1t
' r '.. Ap (i A pre, m. r.a r ana s * *
!.ar rtiN '
e, e
<,r e
ss..am+
e i
'e
'.me and mean3 De em pan ed the i
'i e
se
,.la He ficat;on of State and uca gosernments i
H'
r.
a r.d t h e p u b. :c.
'he e s en' of an emergen
" H e f >p p ; r st ! % 4 p 3 MarrT3 Ast;ist' A n m. ear po w e r p.an t a n. n nt cal.
N'"*I r'
pe irm a prenmmars anai s sis of t h e t im e Pr.
r
~ars saf, 's Ata.-
R e po r
- rey a red to n ai ua*e s ance sectors and da
+
.s
'a.:
wr a t f > rma':or t ara es w J hm t he plume exposure pat t.w as s.n. p c i b, c p rop' ned e me F P; for t rans en' and permanen' po;..a e
P '
c
,,ar.
.r bo' t.
onsa+ area 3 arm 'he
' ons noting major im ped ime n's int
k F P/a A,'r
' ai des 1g r.
featore s
+
e acuation or taning of protect n e act ions ep hs as a.
and we ios at ion wah r e s pe' H A prelimmar) anab sia re f;ec t in g the r
u war
< nsafera'm ns h acc e ss roh'es sur need to ans lude f acihtles s s s t erns and h r rsn operat M4 WW mn distr:butwn3 t att.se met hods for identif sing t he degree of ser) l
$g 34 e gg !g
.na!
s re po r '
. sa m3 wt.ona! bo unda ries f or t he ousness and potentia; scope of radiologicai F I% m ! ne ca.se of n ac, ear pow er react ors conseq ue nces of emergency si t uat ions l
m.n:m a,
e4e. e t he means os w hich t he st andards wit hin and outside the sit e boundar) in i Sn 47 b w u. De met gg ng,,
p cluding capabilities for dose projection A3 a mir.im urn
'he folioning :t ems shal.,
,, r e m e,. g g 7, s us t n g real t!rne meteorniogicai information v e v n bed sha.
be 1e and for dispatch of radiolog1 cal momtoring A
()
de offsd rg n r
r
- m:nar s e f e-teams wit hin the EP2s and a preliminary
< p.r d w :t h emergene.es and t he mearu f or anaivsts re flec t in g i t.e rose of the onsite
' cat ion a the m ent of an emergencs t ec t.r.p a. su pport center and of the near I
pe rmru a.s.s. g ned r t the emergency orga o
'an ht y m usm
[
(U "
,7C.
mg in f orm ation recom m end:ng p rot ect is e H
ont yrs and arrangements made and fu ac t io n and dis.se m:r a t in g mf ormat ion to FM amenf ed 4.'?
' ( pr a S t a t e-and Federa.
4h' P"
d' e rn tn e r. ' a. age i.es wt'*
r espo nsi bi h '
[LI
't '
oping w ir r eme rgencies Inc.a t;ng iden II THr FIN 4: S4rr*v AN AL YSIS REPf1RT r a' a m
he pr.nr:pa; agem es
(
Prrit er ( d e mea.s d res t o be I& Ken m1t hln The F1 " a. Saf e' > Ana.s u3 R e pe r' sha;.
^
e s1f e bo u n d a r s and alt h;n each FPZtc
( ontam t he p.ans for, opmg w a h emergen Lrmec' hea!!h and safet s in !? e es en' of at
' es The p;ans sta;. be an express on of 'he
- a. rlden t p rt >< ed ir e s bs w hic h t hese trea5 os era.. i 4,,
r a e p'
? operata'n 'hes shL i d" n a re t o be carr:ed < >u t eg t n t h e c a.se o f sc r:be ne me n t.a e.emen adsance
- g p, y l
g,4.,
f j 4r e s ac antlut. w h ti a u t h O riles 'he e s a' p;an r.. '. g ' h a t r,ase bec on3ide reil and t ee now 'o o. b m s - be nonf:ed and y
3.,.,,
prm :sou 'r e r as e neen mas o < upe w o n s
'ed h ow t h e + t ac uat ion a ti, be 'ar
- ,g7 3,,
emerge'
.ata>ns Ire p.a'.s w r a... ra i
' a n.1 e e M per t e s j respi>nMe ofiff
,,;9 g
,'e* ifs r
r m a!.()r 4 bot
'he e mergPn's "e
- i. ' r a ' * -
sgo e
ese an emergencs
,3, ppor' r.g 'irg an ua! < n.s in i 9 g,,
F.4+
e*
'fe f at
' ne p n 's de'!
e g,.,
genc,n J h a' F IIP C
- Ed-e erge rs' a.d and lev i gg,7
,f,j,g, pn a aje os. r a n<,
n >rd:r a t
l
,g, t
'..t',
4r 1 '
emergent s ' r a ns po rt.
,q, g
pg 7 p p p,, r, p g g n., p g.
4.'
l
! ara.
'he. ice n see w
4 m
aci.r..,
mw r n,.
greater t nar De mans "bmmd m s o a o d'
e "a
'a..
' ' F3. s t 'I ar area 4C I P ' ' '
'hP *'* P i
'd %
I *
d4 e nn rad usand* + r
[V u
'he Emeyp s Rann.7 b ' n e 's a
.g aas F l'/
s'a,.
UMis
.lf af EN' M-
"I PI' 2'
..aao v
- nm rad.a n' ra'e t ha'
'e c. an3 ros
- eau mab a e 1
- S
, je
,h De
. s eil a.*
s.a f a!' Ce bEI EdPN *EI#
b
p'R
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- 0
'tr, esear c'ar s'
i
'A'.
be 'aKer
' e er 4'
m t
a '
s e
ea.
net-noonse p at emerger 509 A
W
b Y
y S
a w
Part 50, App. E 10 CFR Ch.1 (1-1-86 Edition)
Nuclec
=-
w R
'L W WNTnT >r EM EN N 5 P: *ss ar:se Ut her persona A.'h sper;a.
.a..
'a
-_"N 6'
4 EIMA 9
c h a.3 co r.s.. ' an 'a A hn are - t 7'
rhe apput ant s emerger
.an snad ons s uss contain but not n eces.sa r:i s ne ef i
pmy ees of 'he. cendre and who ma) e
=- -
=
m aWo mMU e r r u m -r y
M'
.nf ormation needed to demon,t ra'e e
- v. p..
\\~
6
'had aM be Men %M h e,pec:a.
.aa
' r n s oA : e ar.cc w it h t he eiernent.s se' at ons of t hese persons shad be W
-. be g
organizat:an f or coping 4 :'n rrLr im emer
}
La
,,)
gencies a.s3e ssm e n t ac t io n t-
. a',on of 6 A dev r!pt.un of t he. oc a l A'e wr t
e g
.ces ' u be pros :ded,n wpport n' e
ers emergenes organization of.: <.s' r proce
,e 3 e me rge nt o r g an;za t :o n g
M J u res e me r ge ne ) fac !.e s.i n 1 y a pment
~ Iden t if:ca. ion o f and a.ast anc e - s pe. '
y i '
'ra.ntng m o n t am.ng emerge s
repared e "mer ed f rom appropriate State. oc al ar.d F +
][
a e ss and rero s e r )
In ad t:"
genes m po nse S a ns. n rr.. ea m in tppi:
L agencies A d h r espon.st b:. t.es
,p r g j'
T ar.t ran. ear puAer et Le r ;t '. n g A.' h emergenc +s
]'
cen e mai. onta.n
't.r n s' ed 'i 8 IJe n t. f m a' m r.
' ' ne S'at e an 4
- a r 1,
,,f f:rtai3 respon3f w ' o r ;'. a n n. n g :..r e
lescr:ced :n ; $0 47 r-and* * ^
'a.
ng and controihng appr pr a'+
pr r
~ g
_3 e A '
t 1e m < - trate cm puant g
war ac t io ns.nc.admg es acuat ;ons Ate ne es
-Y
.at ed again3t h.ose 3' and a r ap; cant sary w
pow er reat tor o pe r a t. n g e
.me re sna.i a so pros ide an ana.3 3
- . ired 'o es ac uat e andft;r ' ax
- a ' ner pro B Assessme'It Ac. 'u g
w-s (n.
Jis
' e< t. s e a4 t :o ns for sarn th a T h e m e an.s t o De used f o r J e t e r m ra g ' e j]"
e s; pat n A a)
'ance3 A '. h m ' h e piume
- U
- ##' d FP/ for r a n.31e n ' and po pma
,,d i
t he :mpact of the release of radioac' ', e rta 3
' e rials shau be desc r t Ded.ncludmg emer 4
-d.
gene) acticn les els t hat are 'o be used as 4 mg o '
'T
-rtteria for determmmg 'he need f or :
N U
og eation and partictpation Jf.ocal and Sta:e The.rganlat ion f or
.c ai e rn e r g e nc.es sha.! tn ad the Commission. and other Feder M
agencies dI ^
3 A s. tm t.es
.ng def.n:t.on M author '
al agencies and the emergency action.es ea
' ne h and bites < d.nda lduaa t hat are to be ased f or determmmg w hen u
Ik c e nsee s emergenc) r g a:' as' c1 the and what type of protectis e meas ures W
M' mean, f or notification of
,ais in should be considered withm and out. side 'he
- ^F"d 1
t he es ent of an emergent ) S pr aa 'he site boundar) to protect hesith and saf ets
'3"
"^
follow;ng shail be mcluded The emergenc) action les els shall be based A descript.on of t he r.orma1 piant oper on in plant conditions and inst rumentat:or
'dI*"
at mg orgamzation in addition to onsite and of fsite man. tor ng bs 'he q
J A destr:ption of the uns e emergenc)
These emergency action lesels sha.! be 1s I"
d re3pt :n.se o r g an trat ion A J n a ' ' a. ed disc us cussed and agreed on by the apphrant an.
'i""#
State and local gos ernmental au t ho rn.es g.
- wur a A 4t hor:t ies responsiD., '.e s a.d datles and approved by NRC They shan Cso be of the
- d;. ;duai s w h4 A-
' au c h ar ge res tewed with the State and ;oca gm e-
~
F"U N
darmg an emergenc) mental authorttles on an annua. bast 3
.me y
h P; ant st af f emergen - mc
.t s
_g
h A ut h or:t ies respons m ind J atles
('
Actit atton of Emergency Orga itza ri.,
g un an o nsit e emergenc
' t:nat or w hc
'M m:
- s ge if nfor The entire spectrum of emergencs ona.
- i.n
,h a. L he 'n c harge of t '
- sponsibie tions that ms ob e t he alerting or av '. at. g r
-N mat:on wit h of f site ao
e for c oo rdin a t in g and mp.,
e
.ng affsite o f progressn ely larger segments o f ' he S.'a.
ed 5:
emergency measures emergenc) organ 12ation shag be descr: bed of 3
a 3 A cescription. b) posit and ' mction The communication steps to be taxen le as t o be perf ormed. of t he.lcensee 3 neadquar alert or actts ate emergenc) personnel under i
t ers personnel w ho all; be sen' ' < ' he p; ant each class of emergenc) sha;! be Jes(r bec site to augment t he onsite emergenc) orga Emergency action leseis based not on.'
anstte and offsite radiation monitor:ng -
~E_
niz.a t ion 7
e-4 Identification. b) pos.t.on and f unction formation but also on readmgs f rorn a 1
'u be pe rf ormed of persorw A t h m t he 11 number of sensors that indicate a potent.a.
g ensee organ 11ation w ho wi.
De respons;bie emergenc) suc h as t he pressa re.n 'or'a.r
'or mammg of f site dose prt ec e ns and a ment and the response of 'ne Emergen
=
ed II descr:ption of how t hese pro;rct:ons w!il be Ccre Cooitng System f or not ficat.o a 3
-3 i'
made and the results ' ransm tt ed to State site agenctes shall be 1e sc r:Ded Pe and iocal aut horttles NRC and ot her ap-ence but not t he detalis of a menade 4.
propriate gosernmenta; entities t hentication scheme shai! De noted f or s.cr
_w.
5 Ident:fication b) pos:t en and f unct:on agencies The emergenc) a.sses 1e f red
'o be performed. of ot her emp.os ees of t he sh all include 1-notification of n as.a.
i tce nsee atth special Juamf :c a' ;o ns for esen s 2 ' alert 3 ute area emergenn copmg with emergency -onde ons ' hat may and 4'
generai emergency These ' aues 510 4
y p
7 kE 3
l'
'. y..
4 l.
l l
tt
f (1-1-86 Edition)
Nudear Regulatory Commission Part 50, App. E NT H F (i % 54 wte
,r, r e a:::.3,
- me a. a..
t i
'FM4 HII ao.e S'a an y a. got ernme n t.t.
a.-
an, s
,, n' A ra t, o j,
.1 sat'
.a*.i os r W: ' re ta r - a uei s r.
,ar s air i r.e-r s
i 1
i 1
+
S'a e dr.J w a. off 4'
4'.
t I.
s i
i u
i s.
.a-A.
.a.-4.
t' err re Anet e
- i. am s at e
'M
'a'.
%\\^
e ir ~
,'af.t 5
ts
' e e,
s
."ad.i
,' ag r a m a:.
1 l'
it Ik et [
Ie i
T '. ft..
"o m 4.F A '
e
.g p
' ate g: *
'.mr
- a a; <
es i
w s
I,,
i.i.
.1
<,'a f
E'
'F n, Fca e, as: E;,pmen:
i wa, y 1*
A.'
'n'EPL AM d e >
- u. a..
r ad a N
- P" t
De Jes
.De ear w mg y 7.oya
,,r e ; e r g e
> + ' :.t
'te p.. b.
w ' *;. n t+
mer inc:alng pat t w a s EPZ o f bau e m e r i Wipmen' at r t -- e w mon
- s pi.
e a
g. ant ng i ormat mn suct. as 'ne morn t or ;n g
+ an
'.mes reymred f or pub..
. Egmpment det e rmm.ng ' he magm r
t 4
.i J P F prcif e t-ac t ior' 3 p;an r ade o,
and for i r r oasis a.s3ess m g tta i
a'
,< c ge e r a..n h 'rma'.i e
lmpac o, the reebe
' radioat ' se mate r a.
an e,
e r ad. a'.
ar.a a a. ' ' o '. r e e n 's n m n '
i.
- ,g W
< a.
naJ< as'
-a'.
s nat w.
- Fac.u ties and supr iies at t he sne f or h J
,n a na.
. rma' :o:
ed 1*
er "ons ammattor. af ons:te inda: duals
,4 a:. + me rg e S gns r.e r meb 4 Facthtles ar1 med: cal supphes at the
,g p-4'
, r d,<
d.33e m a.a' e t-ar.
s
..a.3
.A M f,a,
,he a me e x p<'
site for approg. lat e emergency firs t aid
.h.
e
'o s' t a t,
t reat men' I
<t u.t 1
- a ' " A a ', W appropriate.nf ormation F ede' r a mems for t he sert ices of phy si q
a, '
2 A
.1 be ne.pfm
.f an acc der o( ( i rs 3 and ot her medical personne. quah fied
[,
' [,' '.
r '
A e
+r st:a.. h aie the capab;:
na a a M ememncies on s;te
+W
'.be S'aie and o n a.
gute Arrangemen t s
' rans po rt a t.o n t
'.4 age n. :es w P r' n 15 m;nv es af'er de t
cont am ' nat ed ired mdn ;a aae f rom 'he i
ra
' hat tra State.oca.
<,f t;c:a s 5
Yg an emergencs The :leen3ee sna.
to spenfiran ldentif wd t reatrier ! fa I
,' y ties outa:de ' he sp e boundars
,[^
' 4.
+ rapab!.
i. max e a p'.bn< not :f.
^ Arrangemen's 'c r t reattnen t of md:s id t
1r s (
,htmpt.
On be:ng mf armed ias.nf ured in wpport of acensec act a p.es e
<ensee..!
r emergencs cond;'ior,
'I.4-
,R *
<>n the sne at 'reatment f acih t ies outside
{? e H. F.1 r M r 1982 each nur ear peu er re app o a:,
arc t he sit e boundary e.see sham de monM ra' e ' hat ad 8 A heensee onsite t ec h nic a.
suppor'
' T t.m a. t i i r ,e
' rn e ' a.
, 'a'.+
and ph s sica. mean.s hat e been center and a acensee neat Site e m e Tg e nc :.
sna,. a.s
,.,t 0 ned
'or a.ert mg and p roi hg e AN n
d'!
e
' ne pagat g r n ne Ope rat ;ons far
's f rt m w h;ch ef fert n e d, a
ann aa; bam
'Te
>w os.re pat hw as E'PZ The foa rection ca-be gner and ef fect n e co nt ro per ad :n lo CFN So $4 s 2 'or tr,e can be exercised d m-r.g an emergenes emergenci p.an de!1cienc:es 9 At e a.st o r.e ons1. e ind one of f s;te com
,, irgy municat toru ss st em etch si stem sha!. hat e
.if eme rger; i.n d LL app.
< the ;n;f ;a. ;nst a!.at mr
+
a backup power source ert mg.v o
'a'ing pubu< nia,f rat ion sy st em that te e g m e' 's
' he 'na.
. red bs Februars 1 1982 The f our mont h Al; commun a at.s p.ans s ha..
have ar sha.. De 3 e sc r beil
- P*d *;. app 1'
< rorrect ior o'
defic en rangements f or emergencles including tities and aiternates f or t hose m. 61arge at bott.
' ps he 'nArn 1er' 'ied darmg the.n t' a. Inst a.iat ion
<s pe r s<. n n e..nder es.,ng g.he promp' ps.b.n n . f n a ends the comman cat.on arks and *he R
' s "ms a-we R.-
' r's ae de f ;r enr;e, pr;mgrs and hat-g ip mearu s 1)inm inica sf;a.
De IP s ~
D ' l
'>n w he re c >nsist e r.t w.t h ' ne f'a ni 4(>r b a.,se:1 '
e Teil e-eaf'e The les gr
,,t ec e
.htu no ' cation ss urem
'he g o \\ e rnr!. r ' a.
agencs ' t.e se a r r an g e i
<ir c,
UI ddf ca.: rgs
'n' r*
4.
e
' ;g ; ' t.,.. A p a b l. ' ' \\
eMe r '.a. ; \\
T # I'I '
- E '
Proi s 'or 'f or comm'ar':ca' i;ns w it t' cet l'd b
e
'a.
n )' ' c a'
.,f ete r
.f,d.ca'e 4 ' i tiguous State ;ocai g ?\\ ernmer.
w.
+
'A I
A
+ e s p(n r pg:e w gs i r t's,
A a n,.
e ge 3f p.Jme e X pOs re pa' h 1, a s FPZ Su on
\\
Y U
)z
+'g'f~
r n' a'
a' a p a r.. ' '. A r a;. g e ' e n r.
mun: cat;ons st a. be 'es ed m c b Pro \\ lSlon f or cornm,
ta'<,n3 w ;' e Fed s
,a',it
.,fite bl,r w,,
t' s. '
l e gr e, ne '!
e eta.
emergenc\\
Tes po rJe. )r g af. la tions d '
me na' Sig'e and,o( g, 5
,1 4 mevag' S 'c t.
?ornm inicat i.;ru s s st e ms
- shal, be f
4,;
'ed '
4 tr e 41 ha' a s
.a' < t n
- u sta t es!"d ann Jaal k es es i t' f I
- a m
4, i
te er., e
,g.
r d
Prn \\,s.ttr
' ;r r o rr,m ar. r a' ifins aft'. i t n g a g!.
i' i
f.e
, e' a r ic w e r e ac','r O r*
't
'e greg e tt e r g e' I e '
.L p r' e
i e
s e e
i enr\\
I hese
. a# '
51'
^
Part 50, App. E 10 CFR Ch.1 (1-1-86 Edition)
Nudear Re near site emergency operations f ar ind
.oc al emergency plans as
.s reason ab a pr amon g the n uc ; car f acility tru pr apa; ac r.ie s able without mandatory pubhc par cr fner State and local emergency operat.ons <en t acipation shall oe conducted f or each s;'e at Eact 3 ters and the field assessment ' eams Such A hic h a power reactor is located for w h;ch
.e pat n A i commurucations systems shall be 'ested an the f.rst operating ;icense for that site :s g3 e p ar.
E nually
.ssued after July 13 1982 This e x ernse
, pa n a a i
d Pros:sions for communications bs the shan be c ond ucted w it hin ' y ear be f ore '"
- cars hrensee w it h NRC H eadq u art e rs and
'h*
.ssuance of the first operat:ng itcense
.r
[ fer,
a p p ro p riat e NRC Regional Of fice
<>per f ti! power and prior to operation abos e 5c wai gos er-ations Center f rom t he nuclear pow er ear of rated power of the first reactor and snau e x pm rr pa i
ror cont rol room t he onsit e t e( r mra.
3 0
.nc'ade partic: pat:on by each State and in
.a.
- se p(. rt cen t e r and t he near s.te emergenr s op
- oc ai gus ernment withm the plume expo c au er. n a
" h Rem-d r
naJ pat h w ay EPZ and each State w it h1n crat :nns f ac:ht > Sucn commuracat:
i e be ' rs'ed mont h:>
t he :ngestion exposure pathw a) EPZ ne -merge 7g,
. Each acensee at eac h site shad annuad)
.est ed dar.
exercise :ts emergency plan
, hat NRC 3
The program t o proside f o
- 1:
1 Each i;censee at each site shall exernse
~annot fmd
+
d" A ;t h of fsite aut horities such that t he State auate prote mg of employees and exercising drills of 'adiat:on emergen<
m ar.,
'o and local gosernment emergene) plans for t he esent t ensure that employees of he
'ere are each operating reactor site are exercised bl e xtent of S' f amiliar with t heir specific en
- v ' s ennially. with full or partial participation '
edtai exer sponse duties and ' 2 ; the part.c:pa t.
n by States and iocal gos ernments within the nat appro; the t r ain m g and drills bs e ner u rsons plume ex posure pat hw ay EPZ State and been 'anen w nose assist ance may be needed
'h" loc al gos ernments that hase f ully par'ic:
. bran not pr esent of a radiativn emergenc) n a.. Cr w cated m a jolnt exeretse since October aes sc r: bed This shaa melude a dem
<f 1982. are elig:ble to fully part:cipate
.n i Al! 'rt specialized.n.t iai t raining an2 +
,1 ' '
emergency preparedness exercises on a D;en
..de f or -
r t rainmg programs to be pros + 4
'. ; a i f requency The :esel of p a rt :c: pa n c'r.
- s Aean s
the f ollow mg categories of "me i er snail be as follows on An-
=
- s. m ne l a A State shall at lea.st partiaH) p art:c.
are. den g
t a Dir ec t o rs and or c ou rin a t pate m eacn of fstte exercise at each s;te (A Ei I
plant emergency organizat.on b A State shall full > part:c: pat e.n at b Pe rso n n e t r e s po nsibie A
Ss eaat one of fsite exercise es er) 2 years i>rry s t,...
,e ss m e n t.ncluding ontro rm.
per
, h ears 11. States
. pe emerge '
t c
At least once esery I
A ihm the piume exposure pat hw a>
E P2 Aret and Radiological monitoring team, s
f or a gisen site must fully participate m an pues are m d Fire control teams f re Dr;gade, of fsite excretse for that site This exerr se scr: bed I
Repair and damage cont ro; cam, e
must also invon e f ull participation bs loca.
f First aid and rescue teams g Medical support personnei gos e rnments withm the plume e x posure path w ay EPZ
[
h Licensee s h eadq u a rt e rs gp per gg,,,,
d Partial participation by a loca! gosern I
sonnel 3.,
Security personnel ment during an of fstte excretse for a site.s w
d 9e i
In addition a radiologma;
>r:r ' at.on acceptable only w hen the local gasernmen co u.d be res i
'rammg program shad be made as o.at.e %
l iocal sen ices personnel. e g
.oca.
mergen V I.
censee personnel phy stcau) and ac t:s e.)
cy sen ices Cn d Defense loca;.a A rn'orce take part m testmg their mtegrated capact:
Na :ess tt ment personnel. ;ocai news med.a peruns it y to adequately access and respond to an i!ed 13auani The plan shall describe pros s en, t or ' he accident at a comme rcial nuclear po w er
- r. ear pow conduct of emergency prepared wer l
ctses a.s fonow s Exercises shaJ 'ev
- ade plant Full participation meludes testmg n ortear ma' t he major obaen able portions of the onsite 1et a.:ed r-quacy of timmg and content o f.m p.ement and of fsite emergency plans and mobtal.a emergenes mg procedures and methods test emergenes tion f State. Local and l censee personne Admint3t ra equipment and communications n e t w orks and other resources m sufficient mumben g;ona:
<lf' rest the public notification sy s'em and to s erify the capabihty to respond to the ac Par 20 < '
ensare t hat emergenc> orgamzat;on ;'erson cident scenario
^e
-e
o ne! are f amiliar wit h t heir dut;es i A full participat:en
- e x e r nse Ar^h Part:ai participation w hen used in con N,
-ar P r DC
- unction w;th emergencs preparedness exer
' e s t.s a.S m uc h of the :icensee State and
';ses f or a particular site means appropna9 ert' of f s;te author;t.es sna.. actis ei) t axe par "
' Use of site specific sim u:at ors < > r mp the exercise suf fic:ent to test direction and
=
ers is acceptable for any exercise
'o n t rol f unctions. i e a protec se ac t -
m' T
PuH participa t io n w hen u sed
'on decision making re;ated to emergency act.cr n<o
+
junction with emergency preparedness, ser
.es eis and b-commun: ation capabi, t.es Pw
.o a:
cises for a particular site mean, app ar am on g af fect ed State and.ocai ac.t hor:tas
('
r of f site.ocai and State aut hor: t :e, ed and the.icensee
. in e 512 i
f Nw *
- m aman w w m w w - urunww wmmr -n-mem -- --
=s o
l l
r t-J I
-86 Edition)
Nuclear Regulatory Comenission Part 50, App. F i s reasonabl>
u fully participating in a biennial exercise (Secs. 161b.. i.. and o.. Pub. L. 83-703: 68 pubhc par.
at another site.
Stat. 948 (42 U.S.C. 2201); sec. 201. as s
j
.r w h ute at ic) Each State withm any mgestion expo.
amended. Pub. L.93-438. 88 Etat.1242. Pub.
l rd t o e a hirh sure pathway EPZ shall exercise its plans L. 94-79 (42 U.S.C. 5841))
H.C u'"
is and preparedness related to ingestion expo-f 45 FR 55410. Aug.19.1980; 46 FR 28839.
I*
' w ense sare pathway measures at least once every 5 May 29.1981, as amended at 46 FR 63032.
'* r 1he nars Dec. 30.1981; 47 FR 30236. July 13.1982: 47 1
l I
for W Licensees shall enable any State or FR 57671. Dec. 28. 7982; 49 FR 27736. July l
5 meal gosernmerit located ulthm the plume 6.19841
! a;.
n;:osure pathway EPZ to participate m
)
l i
C4 annual exercises when requested by such APPENDIX F-POLICY REI.ATING TO THE f
i
- su State or local government.
SITING OF Ft:EI. REPROCESSING PLANTS
- ' ' ^
4 Remedial exercises will be required if AND RELATED WASTE MANAGEMENT FA-e l' me emergency plan is not satisfactorily CILITIES k
v'
- C tested durmg the biennial exercise. such that NRC. in consultation w ith FEMA.
I
)
. hail e wrcise canr.ot fmd reasonable assurance that ade-
- 1. Public health and safety considerations l
lat v t.r State quate protective measures can be taken in relating to licensed fuel reprocessing plants j
' ics plam for the event to a radiological emergency. The do not require that such facilities be located iE eurciwd bi-extent of State and local participation in re-on land owned and controlled by the Feder-i earticipation
- medial exercises must be sufficient to show al Government. Such plants, including the ts. within the that appropriate co:Tirttive measures have facilities for the temporary storage of high-been taken regarding the elements of the level radioactive wastes, may be located on L State and i
plan not properly tested in the previous ex-privately owned property.
ful artici-i e
er 1.
ercises-
- 2. A fuel reprocessmg plant's intentory of at te in
- 5. All training. including exeretses, shall high level liquid radioactive wastes will be ses on a bien.
provide for formal critiques in order to iden-limited to that produced in the prior 5 I
I participat ton tify seak or deficient areas that need cor-years. (Por the purpose of this statement of i
rection Any weaknesses or deficiencies that policy. "high level liquid radioactive wastes" tially partici.
are identified shall be corrected.
means those aqueous wastes resulting from rach site.
the operation cf the first cycle solvent ex-icipate in at C SfaUlurtning Emergency Preparedness traction system or equivalent, and the con-t 2 years.
Prosisions to be employed to ensure that centrated wastes from subsequent extrac-i rs. all States he emergency plan. its implementing proce.
tion cycles or equivalent. In a facility for re-athway EPZ tres. and emergency equipment and sup.
processing irradiated reactor fuels.) High-l acapate in an E!:es are mamtamed up to date shall be de-level 11guld radioactive wastes shall be con-i This exercise scribed verted to a dry solid as required to comply
{
tion by local with this inventory limitation. and placed in l
ne exposure H. Recorery a sealed container pmr to transfer to a Fed-crlierta to be used to determine s hen, fol-eral repository in a shipping cask meeting W govern-log the requirements of 10 CFR Part 71. The sojhg an accident, reentry of the faci'ity dry solid shall be chemically, thermally, and for a site is be appropriate or when opetation gos ernment egd be resumed shall be described.
radiol)tical;y stable to the extent that the equilit raum pressure in the scaled container E
and actig eb V Nummo Puoces will no; exceed the safe operating pressure for that container during the pertod from ated capabil-No less than 180 days prior to the sched-cannmg through a nJnt:num of 90 days spond to an g
uled issuanae of an operating Ilcense for a after receipt (transfer of physical custody)
)
Delear power teactor or a license to possess at the Federal repository. All of these high.
. clear powef i
tudes testing i
nuclear trerta! one copy cf the applicant's level radioactive wastes shall be transferred l
of the on3tte detaded impletnenting procedures for its to a Federal repository no later than 10
)
nd mobiliza-emergercy pikn shall be submitted to the years follov!ng separation of fission prod-ee personnel Administrator of the appropriate NRC Re-ucts from the irradiated fuel. Upon receipt.
nt mumbers onal Office. meetfled in Appendix D of the Federal repository will assume perma-nd to the ac-art 20 of this chapter and two copies are to nent custody of these radioactive waste ma-
- g. sent to the Occument Control Desk. U.S.
terials although industry will pay the Fed-used in con-aclear Regulatory Commission. Washing-eral Government a charge which together g
edness exer-on. DC 20555. Lhensees who are authorized with interest on unexpended balances will appropriate M operate a nuclear power facility shall be designed to defray all costs of disposal ttske part in i
54r: tit One copy of any changes to the and perpetual surveillance. the Department lirection an Mergency plan or procedures to the Ad-of Energy will take title to the radioactive
?cti action m:nistrator of the appropriate NRC Region-saste material upor transfer to a Federal U
lee. specified m AppcMix D.10 CFR repository. Before retirement of the reproc-de II'#3 p rt M, and two copies to the Document c
essing pimt from operational status and authorittes Coutrok Desk withm 30 days of such before termination of licensing pursuant to hanges 150.82. transfer of all such mastes to a Fed-l I
513 i
I
\\
i k Cuidance Memorandum 17, Revision 1 Z073S9 O
Technological Hazards CONDUCTING PRE-EXERCISE AND FOST-EXER *ISE ACTIVITIES Furpose This Guidance Memorandus provides guidelines for conducting pre-exercise and post-exercise activities.
Background
Under 44 CFR 350, it is the responsibility of a State and its local governments to conduct joint exercises as a condition of initial and The continued Federal Emergency Management Agency (FEMA) approval.
original Guidance Memorandus (GM) 17. dated January 8,1981, provided procedural guidance intended to improve the conduct of exercises and to establish greater uniformity among the FEMA Regions in this activity.
While progress has been made, there is still such diversity among Regions This revision is a further ef f ort in the quality of exercises conducted.
It at achieving uniformity in preparing for and conducting exercises.
supercedes the January 8,1981, GM 17.
It is to be used in conjunction with the August 5,1983, memorandum free Dave Mel.oughlin entitled
" Procedural Policy on Radiological Emergency Preparedness Plan Reviews,e Exercise Observations and Evaluations, and Interim Findings" in all joint l
exercises required by the Nuclear Regulatory. Commission (NRC) and FEMA regulations.
~
l Cuidance I.
Pre-exercise Activity Fast experience has shown that joint exercises must be planned i
In order to ensure considerably in advance and each step scheduled.
optimum results, the following milestones should be met, at a sinimum.
More frequent contacts are at the discretion of the Region.
These silestones are predicated on adherence to the biennial exercise If, for any reason, exercises will be more frequent, the silestone NOTE:
frequency.
dates shown in parentheses should be used.
mil.ESTONES FOR EEERCISE PREFARATION 3e Later Than the Der Prior to Exercise State and licensee jointly develop and 120 days submit exercise objectives to FEMA and (75)
NRC Regional Offices.
FEMA and NRC Regional Offices complete 105 days reviews of objectives and extent of play (60) after meeting with licensee / State, if necessary.
2 DEPOSITIO98 EXHIBIT M.
I
-..-,.--,,,,,,-,,,----,----,,-_,-,.-c---
,-,,,---,.._,-,-,,-,,,,.-n,
__,,_-,,.,_,,,a
, ~, _.,
.,,.--_,,--<~,~.-m
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207390 State and licensee submit exercise 90 days scenario to Fy.MA and NRC Regions (45)
O-for review.
FEMA and NRC Regions contact or meet 60 days with State and licensee to discuss (35) modifications and complete the scenario.
Controller's meeting to develop 40 days coordination of exercise.
(30)
FEMA and NRC Regions develop specific 30 days post-exercise activity schedule (25) with the State and advise FEMA and NRC Headquarters.
optional - The RAC Chairman and NRC 15 days team leader meet to develop observer (15) action plan (where stationed, how many from each organisation, what to look for).
All Federal observers, both onsite 1 day and offsite, aset in the exercise (1) area to finalise assignments and receive instructions.
Whenever an exercise is scheduled the Region should immediately assure construction of a time line based on the above and aske it available to the State, NRC Region, and FEMA Headquarters. Where a plant is located on a Regional boundary, the Region in which the plant is actually located is considered the lead Region for purposes of schedul,ing and coordination.
Establishing the time line is the responsibility of the lead Region.
Adhering to the time line should permit ample time to review and negotiate
- However, any changes to the exercise objectives and the exercise scenario.
should delays occur which may affeet the scheduled exercise date, the Regional Director must so advise the State, the utility, the NRC Region, The FEMA Regional Office should aske every effort l
and FEMA Needquarters.
to rectify slips in the timetable to avoid rescheduling the exercise date.
The besie objectives for the exercise should be taken from the list The objectives have been developed to generally of 36 in Attachment I.
1, correspond to the observable elements of NUREG-0654/ FEMA-REP-1, Rev.
as well as the modules contained in the Wular Forest for Uniformity of Radiological Energency Preparedness Exercise Observations and Evaluations."
Objectives should be chosen to test a major portion of energency response Objectives related to deficiencies of record scheduled for capabilities.
In addition, correction from the previous emereise should be included.
each of the 36 objectives should be tested at least once within a five-year period.
O 1
Z07391
-3.-
O The objectives for each exercise must be reviewed by both the FEMA Once and NRC Regional Offices before specific scenarios are written.
reviewed, the State and licensee will develop a scenario for submission which will include, at a minimus:
a full schedule of all events.
all dosimetry and monitored values to be supplied to the monitoring teams, all release data from the plant, calculations of offsite dose, and a
applicable esteorological data.
FEMA and NRC Regions will cocedinate review of the scenario and notify If necessary, a the State and licensee of any necessary modifications.If agreement cannot be meeting to discuss modifications should be held.
reached, FEMA and NRC Headquarters assistance should be sought.
II.
Post-exercise Meetings Three audience groups are to be involved in post-exercise meetings:
l l
A.
O I
obse rvers,
exercise participants, and public/sedia.
In The approach to each audience's meeting will usually vary.
addition, the timing and intent of the meetings may very depending upon l
whether the esercise is conducted in advance of FEMA ~350" approval
(* qualifying exercise") or for continued ~350* approval.
The following chart illustrates post-emercise meeting requirements for qualifying exercises and exercises for continued FENA approval.
B.
Guidance on each type of meeting follows.
l l
ODNTINUED-AF?t0 VAL SERCTSE On MIFT1WC UERCISE Observer Debriefing Observer Debriefing tuercise Ferticipsets taercise Participants Briefing Briefing Meeting Public Meeting
)
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207392.
1.
Observer Debriefing (for qualifying and continued-approval exercises).
Immediately following the exercise, the RAC Chairman s.
should convene the FEMA and RAC evaluators to debrief them and to consolidate their observations and comments. The separate observer debriefing is not specified under 44 CFR 350 but should be incorporated as standard procedure. During this same period, the NRC team leader should patellel this process with the NRC observers.
b.
As soon as possible af ter their independent debriefings, the RAC Chairman and the NRC team leader should meet to coordinate and arraage Federal participation in the joint exercise participant's briefing.
2.
Exercise Participants' Briefing (for qualifying ami continued-approval exercises).
Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the completion of an emarcise, a s.
briefing involving the exercise participants and Federal observers should be held to discuss the preliminary results of the exercise. This briefing should be held in accordance with 44 CFR 350.9(a) and (d).
b.
A recommended agenda to be used is as follows:
Review of onsite actions by NRC, e
J Licensee presents their views (clarifying questions or comments),
Review of offsite actions by RAC Chairman, I
State and locals present their views (clarifying questions or comments),
1 Review of Federal response (if applicable) by RAC Chairman, and Opportunity for clarifying questions or comments by licensee, State, and locals.
The presentations should each be a brief, integrated c.
overview covering the highlights of the exercise. The most important deficiencies observed must be included and appropriate commendation for good performance can be included. Bowever, the RAC Chairusa aust ge, t
indicate whether the state er local preparedmeos is adequate er fandequate.
3.
Meeting For Contissed FEMA Approvell Esercisee.
Fe11 ewing an esercise fer coatimmed FEMA approval, a eseting a.
involving enarcise perticipants, representatives from the NRC and other appropriate Federal agencies and the public and the esdia should be held in asser'dsace with 44 CFR 350.9(e) in the vicinity of the nuclear peuer facility. At the O
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esercise participants' briefing.
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207393
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_ I b.
The public and media may attend the meeting as observers.
Howeveg, at the discretion of the Regional Director, written questions from the public and media may be submitted at or after the meeting for consideration in the exercise evaluation. Also, the Regional Director may further use his/her discretion to solicit and respond to oral questions and comments during this meeting. Under no circumstances should it be indicated whether State or local preparedness is adequate or inadequate.
During the meeting, the RAC Chairman should offer an c.
oveiview of the exercise and should provide his/her observations. Comments l'
from the RAC members and FEMA observers may be solicited at the discretion of the RAC Chairman.
4.
Fublic Meeting.
4 Prior to the submission by the Regional Director of the a.
evaluation of the plan and exercise to FEMA Headquarters, a public meeting in accordance with 44 CFR 350.10 should be held in the vicinity of the nuclear power facility. Exercise participants, representatives from the NRC, and other appropriate Federal, State, and local agencies should attend.
b.
The meeting should acquaint members of the public with appropriate State and local energency plans, the results of the exercise and indicate actions on corrective esasures, answer any questions about '.
FF.MA's review and evaluation, and receive suggestions from the public for improvement or changes.
For situations in which a public meeting has been held c.
during the 350 approval process and prior to both the qualifying exercise j
and the ef fective date (October 28, 1983) of the final rule, 44 CFR 350, the requirement for conducting a public meeting under 350.10 will be considered by FEMA to have been met if a " briefing" was held for the l
initial, qualifying exercise.
S. "Neetinas" for exercises conducted durina 350 approval process.
l:
Requirements in 44 CFR 350 do not address the conduct of "seetings" for esercises j
held af ter the initial, qualifying exercise and before the completion of the i
For such exercises, a meeting as described in 350.9(e) 350 approval process.
{
should be held even though the context of this meeting in the rule is for esercises conducted for continued FEMA approval. FINA's evaluation of such "interia" exercises is an integral part of our overall 350 approval process; therefore, an opportunity should be provided to the esercise participants, the public, media, and other Federal agenciae to discuse the perforesace of the esercise and our preliminary evaluaties.
i 1
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i 07394 ATTACHMENT
. GM 17 0
CORRESPONDING NUREG-0654 PART(S) of FORM OBJECTIVE E.1, E.2 EOC Sec. I 1.
Demonstrate ability to mobilize EOF Sec. I stff and activate facilities MEDI A Sec. I prospely.
RELOC Sec. I E Sec. I A.2.a.
EOC Sec. I I
2". Demonstrate ability to fully A. 4 EOF Sec. I staff facilities and maintain MEDIA Sec. I staffing around the clock.
RELOC Sec. I A.1. 4,
IOC sec. II 3.
Demonstrate ability to make A.2. a decisions and to coordinate energency activities.
C.3.a, EOC Sec. III Demonstrate adequacy of f acilities M.2, 4
EOF Sec. II and displays to support energency MEDIA Sec. II H.3 operations.
F EOC Sec. IV 5.
Demonstrate ability to communicate EOF Sec. III with all appropriate locations, MEDI A Sec. III organizations, and field personnel.
RELOC Sec. III J_A, Sec. I, II E Sec. IV E.2. I.8 Demonstrate ability to mobilize 3 Sec. I 6.
and deploy field monitoring teams in a timely fashion.
I.8, I.11 7.
Demonstrate appropriate equipaant 3 Sec. II, III and procedures for deteretning ambient radiation levels.
I.9 Demonstrate appropriate equipment 3 Sec. II, III RADLAS Sec. I,11 8.
and procedures for esasurement of airborne radioiodine concentrations as low as 10-7 uC1/CC in the presence of noble gases.
I.8 Demonstrate appropriate equipment 3 Sec. II, III RADLA8 Sec. I, II 9.
and precedures for collection and transport of semples of soil, vegetation, snow, water, and silk.
C. 3 IADLAS Sec. I, II
- 10. Demonstrate appropriate lab operation functions for measuring and analyzing all types of O
samples.
6
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C...lSPONDING
?" *(3) of FORM NUREG-06 54 OBJECTIVE
'O b
EOC Sec. V I.10. J.10.
as.
ad, 11. Demonstrate ability to project EOF Sec. XI i
dosage to the public via plume esposure, bead on plant and field data, and to determine appropriate protective measures, based on PAC's, available shelter, evacuation time estimmtes, and all other appropriate f actors.
- 12. Demonstrate ability to project IOC Sec. V I.10. J.11 dosage to the public via ingestion EOF Sec. VI pathway exposure, based on plant and field data, and to determine appropriate protective sensures, based on PAG's and other relevant factors.
- 13. Demonstrate ability to implement EOC Sec. VII.C J.9, J.11 protective actions for ingestion pathway hazards.
- 14. Demonstrate ability to alert the IOC Sec. VI E.6 public within the 10-mile EPZ, and
))i Sec. III disseminate an initial instructional message, within 15 minutes.
E.5
- 15. Demonstrate ability to formulate
,FSC Sec. VI and distribute appropriate instructions to the public, in a timely fashion.
- 16. Demonstrate the organizationci EOC Sec. VII. A J. 9, J.10 ability and resources necessary F3 Sec. I to manage an orderly evacuacion of all ce part of the plume EPZ.
- 17. Demonsteste the organizational EOC Sec. VII. A J.10.K ability and resources necessary Fj( Sec. I to deal with impediments to evacuation, as inclement weather or traffic obstructions.
l
- 18. Demonstrate the organization 1 EOC Sec. VII. A J.10.j ability and resources necessary J05 Sec. I to control access to an evacuated area.
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Z07396 ATTACHMENT I GM 17 CORRESPONDING FART (S) of FORM NUREC-0654 OBJgCTIVs
- 19. Demonstrate the organisational EOC Sec. VII, 5 J.10.4
)
ability and resources necessary H Sec. II.B to of f act an orderly evacuation of mobility-impaired individuals within the plume EFZ.
l
- 20. Demonstrate the organisational EOC Sec. VII.B J.9 J.10 3 l ability and resources necessary
& Sec. II.A to ef fect an orderly evacuation of schools within the plume EFZ.
_QC,Sec. VIII K.3.a. b
- 21. Demonstrate ability to continuously C
sonitor and control emergency H Sec. IV worker exposure.
3 Sec. V
- 22. Demonstrate the ability to make the EOC Sec. V J.10.f decision, based on predetermined EOF Sec. VI criteria, whether to issue KI to l
energency workers and/or the general population.
- 23. Demonstrate the ability to supply EOC Sec. VIII J.10.e and administer KI, once the decision 3 Sec. IV has been made to do so.
g Sec. V J.2
- 24. Demonstrace ability to effect an g Sec. VII.B orderly evacuation of onsite personnel.
G.3.a
- 25. Demonstrate ability to brief the g Sec. IX media in a clear, accurate and MEDIA Sec. IV C.A.a timely esaner.
E Sec. IV C.4.b
- 26. Demonstrate ability to provide E Sec. IX j
advance coordination of information MEDIA Sec. IV j
released.
t c.4.c j
- 27. Demonstrate ability to establish g Sec. II i
j and operate rumor control in a M Sec. VI coordinated fashion.
4 J.12
- 28. Demonstrate adequacy of procedures M Sec. II for registration and radiological l
sonitoring of evacuees.
- 29. Demonstrate adequacy of facilities RELOC Sec. III J.10.h for mass care of evacuees.
O.=~
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1
A_-
6 ATTACHMENT I 207397 O
GM 17 CORRESPONDING *p 7
(
OBJECTIVE PART(S) of PORM NUREC-0654 DECON all K.5.a. b
- 30. Demonstrate adequate equipment and procedures for decontamination of emergency workers, equipment and vehicles.
- 31. Demonstrate adequacy of ambulance MEDIC Sec. III L.4 facilities and procedures for l
handling contaminated individuals.
- 32. Demonstrate adequacy of hospital MEDIC Sec. II L.1 facilities and procedures for handling contaminated individuals.
- 33. Demonstrate ability to identify (to be developed)
C.1.a. b need for, request, and obtain Federal assistance.
- 34. Demonstrate ability to relocate to (to be developed)
H.2, H.3 and operate the alternate 10F/EOC.
e
- 35. Demonstrate ability to estimate EOC Sec. V M.4 O
EOF Sec. VI total population exposure.
M.1
- 36. Demonstrate ability to determine EOC Sec. X and implement appropriate sessures for controlled recovery and reentry.
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O DRAFT DRAFT DRAFT DRAFT DRAFT DRAFT DRAFT DRAFT DRAFT DRAFT 8/15/86 Guidance Memorandum EX-3 CONDUCTING PRE-EXERCISE ACTIVITIES AND POST-EXERCISE MEETINGS Purpose This Guidance Memorandum (GM) provides guidelines for conducting pre-exercise activities and post-exercise meetings in support of the Federal Emergency Management Agency's (FEMA) Radiological Emergency Preparedness (REP)
- Program.
Backcround Under 44 CFR 350, it[a the responsibility of a State and its local governments to conduct joint exercises as a condition of initial and continued FEMA approval.
The predecessor
(])
Guidance Memorandum (GM) 17, dated January 8,1981, provided procedural guidance intended to improve the conduct of exercises and to establish greater uniformity among the FEMA Regions in this activity.
While progress has been made, there is still diversity among Regions in the uniformity and quality of exercises conducted.
This revision is a further effort at achieving greater uniformity in preparing for and conducting exercises.
It supersedes the January 8, 1981, GM 17.
Guidelines I.
Pre-exercise Activity Past experience has shown that joint exercises must be planned considerably in advance and each step scheduled.
In order to ensure optimum results, the following milestones should be met, at a minimum.
These milestones are predicated on the biennial exercise frequency; if exercises are conducted more frequently than biennially, the milestone time f rames placed in parentheses should be used.
MILESTONES IDE EXERCISE QBSERVATION AHD EVALUATION No Later Than O
nav= "ri=' u rei -
120 days State and licensee jointi 2 capos #
"[
1
- meew- --wwewe NWww+
W rrw- - - - - - - >, -, - - - - - - - - - - -
e (75) develop and submit exercise O
objectives to FEMA and NRC Regional Offices.
105 days FEMA and NRC Regional Offices (60) complete reviews of objectives and extent of p/ state,1 flay after meeting with licensee necessary.
'90 days state and licensee submit (45) exercise scenario to FEMA l
and NRC Regions for review.
60 days FEMA and NRC Regions contact or (35) meet with State and licensee to discuss modifications and complete the scenario.
40 days Controller's meeting to develop (30) coordination of exercise.
30 days FEMA and NRC Regions develop (25) specific post exercise activity schedule for debriefings and e
meetings with the State.
15 days (Optional) The RAC Chairman and NRC team leader meet to develop observer action plan (where i
stationed, how many from each organization, what to look for).
I day All Federal observers, both onsite and offsite, meet in the exercise area to receive l
assignments and instructions.
Whenever an exercine is scheduled, the Region should promptly assure construction of a time line based on the above milestones and make it available to the state, Regional l
Assistance Committee (RAC) Members, NRC Region, and FEMA l
Headquarters.
Where a plant is located on a Regional I
boundary, the Region in which the plant is actually located is considered the lead Region for purposes of scheduling, coordination and establishing the time line.
Adhering to the i
time line should permit ample time to review and negotiate any changes to the exercise objectives and the exercise scenario.
Howevet, should delays occur which may affect the scheduled exercise date, the Regiora1 Director shall'so advise the state, the NRC Region, the RAC Members, and FEMA Headquarters.
The FEMA Regional Office should make every (O
effort to rectify slippage in the timetable to avoid rescheduling the exercise date.
2 l
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The basic objectives for the exercise should be taken from the list of 35 in section III.
The objectives have been i
i developed to generally correspond to the observable elements of NUREG-0654/ FEMA-REP-1, as well as the the modules contained in the " Modular Format for Uniformity of Radiological Emergency Preparedness Exercise Observations and Evalua tions."
The objectives should be selected in order to test a significant portion of the emergency response capabilities.
The selection of objectives should also ensure that all major elements of the plans and preparedness organizations are tested at least once every six years as set forth in GM PR-1.
some objectives, because of their fundamental nature to emergency response, are to be included in each biennial exercise.
This set of exercise objectives is to be referred to as the " core objectives."
These core objectives are listed in section III (Emergency Objectives) as group A.
1 The objectives for each exercise shall be reviewed by both the FEMA and NRC Regional Of fices before specific scenarios i
are written.
Once reviewed, the state and licensee shall 1
develop a scenario for submission which will include, at a minimum:
?
The exercise objectives,
- O The da te (s), elme pe riod, p1 ace (s >,
i participating organizations and extent of State participation (i.e., full or partial),
A time schedule of all key events, Identification of simulated events and i
activities, l
A chronological narrative of exercise events and activities, Appropriate radiological off site release data with appropriate values for dose calculations, dosimetry and field monitoring and meteorological data.
l l
FEMA and NRC Regions will coordinate review of the scenario and notify the state and licensee of any necessary modifications.
If necessary, a meeting to discuss modifications should be held.
If agreement cannot be reached, FEMA and NRC Headquarters assistance should be sought.
II.
Post-exercise Debriefinas and Meetinas A.
Three audience groups may be involved in I
post-exercise meetings:
3
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observers / evaluators,
(
exercise participants, and public/ media.
The timing and intent of the meetings may vary depending upon whether the exercise is conducted in advance of FEMA 350 approval (qualifying exercise), for continued 350 approval or i
after a remedial exercise.
B.
The following chart illustrates post exercise meeting requirements for qualifying exercises and exercises for continued FEMA approval.
i OUALIFYING EXERCISE CONTINUED APPROVAL EXERCISE i
Observer / Evaluator Observer / Evaluator Debriefing Debriefing Observer / Evaluator Observer / Evaluator Exit Interviews Exit Interviews Exercise Participants' Exercise Participants' Briefing Briefing
, ()
Public Meeting Meeting to which public and' media are invited.
x C.
Guidance on each type of debriefing / meeting follows.
i 1.
Observer / Evaluator Debriefina Jf2I aualifyina add continued aceroval exercisen)
)
a.
Observer /Evaluato,I Debriefinar Immediately following the conduct of the exercise, an exercise t
observer / evaluator debriefing should be held at assigned observer locations, as appropriate, to briefly provide a preliminary assessment of the exercise participants' strengths and weaknesses.
No attempt should be made to categorize exercise performance inadequacies as l
" deficiencies
- or " areas requiring corrective actions."
Also, no indication of a " bottom line" finding should be made as to whether State or local preparedness is adequate.
The observer / evaluator debriefing is not specified under 44 CFR 350, but should be incorporated as standard procedure.
b.
Observer / Evaluator 3211 Interviewan soon after the exercise, the RAC Chairman should effect exit interviews for all observers / evaluators.
These interviews O
may be conducted by team leaders selected by the RAC r
chairman.
The purpose of these interviews is to debrief the ix observers / evaluators to secure accurate and complete
{
4 l
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1
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information per their assignments prior to their departure.
Exit interviews are'not specified under 44 CFR 350, but should be incorporated as standard procedure.
During this same period, the NRC team leader will conduct a prallel meeting with the NRC observers / evaluators of onsite performance in the esercise.
- c. As soon as possible af ter their independent debriefings, the RAC Chairman and the NRC team leader should meet to coordinate and arrange for Federal participation in the joint exercise participants' briefing.
I
- d. If exercise inadequacies are indicated, the RAC Chairman shall report same to FEMA Readquarters by telephone, per GM EX-1.
Following the RAC Chairman's telephone contact with FEMA Headquarters, this debriefing can serve as the initial step in the consultation process required in GM EX-1.
2.
Exercise Particioants' Briefina J12I aualifyino And continued-anoroval exercises) a.
Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the completion of an exercise, a briefing involving the exercise participants, RAC Chairman, NRC representative and other RAC members and O
Federal observers / evaluators, as appropriate, should be held to discuss the preliminary results of the exercise.
This briefing should be held in accordance with 44 CFR 350.9(a) and (d).
1 b.
Recommended agenda to be used is as follows:
Review of onsite actions presented by NRC, I
Licensee presents their views (clarifying questions or comments),
Review of offsite actions by RAC Chairman, State and local governments present their views (clarifying questions or comments),
Review of Federal response (if applicable) by RAC Chairman, and Opportunity for clarifying questions or comments by licensee, State and local governments.
I c.The presentations should be a brief, O
integrated overview covering the highlights of the esercise.
Included in the presentation should be a commendation for good performance, where appropriate, and a preliminary assessment of the participants' strengths and weaknesses.
At 5
I
()
this stage, no attempt should be made to categorise exercise performance inadequacies as " deficiencies" or " areas i
i requiring corrective actions."
Also, no indication of a "botton line" finding should be made as to whether state or i
local preparedness is adequate.
- d. As soon as possible af ter this briefing, the RAC Chairman, through the consultation process, should provide the state with a tentative identification of the exercise inadequacies, if any, by classification, i.e.
j
" deficiencies" and " areas requir:,ng corrective actions."
Again, no indication of a " bottom line" finding should be made as to whether state or local preparedness is adequate.
- 3. Public Meetino ll2X oualifyina exercises) a.
Prior to the submission by the Regional Director of the evaluation of the plan and exercise to FEMA i
Headquarters, a public meeting in accordance with 44 CFR 350.10 should be held as soon as possible after the exercise l-in the vicinity of the nuclear power facility.
Exercise participants, representatives from the NRC and other i
l appropriate Federal, State and local agencies should attend.
1
- b. The meeting should acquaint members of the o
i A
public with appropriate State and local emergency plans and j
U the results of the exercise, including strengths and weaknes-ses observed.
The meeting should also answer any questions i
)
about FEMA's review and evaluation, and receive suggestions j
f rom the public for improvements or changes.
- c. During this Public Meeting an assessment of the exercise participants' performance should be made.
The timing of the Public Meeting with relation to the post-exercise evaluation procedures will dictate the degree to which the RAC Chairman can address the exercise participants' performance.
When the consultation process has progressed to the point of agreement on the degrees of inadequacies in the exercise participants' performance, these inadequacies can be discussed in their proper categorisation, i.e.,
i i
" deficiencies" and areas requiring corrective actions."
When an agreement on the inadequacies in the exercise participants' performance has not been reached, discussions should be more general, i.e., in terms of strengths and weaknesses.
Whether a "botton line" finding is made will also depend on the status of the post-exercise evaluation process.
- d. For situations in which a Public Meeting has been held during the 350 approval process and, thereafter, a O
plan amendment la submitted which significantly changes the context or nature of the planning (e.g., a change in the r
emergency planning none that results ln the inclusion of i
additional jurisdictions), the FEMA Regional Director shall 6
e O
determine whether the amendment necessitates holding another public meeting.
4.
3331133 f.gz continued fgM Annroval Exarcians a.
Following an exercise for continued FEMA approval, a meeting involving exercise participants, representatives from the NRC, other appropriate Federal agencies, the public and the media should be held in accordance with 44 CFR 350.9(<e) in the vicinity of the nuclear power facility.
At the discretion of the Regional Director, this meeting may be combined with the exercise pa rticipants briefing.
- b. The public and media may attend the meeting as observers.
However, at the discretion of the Regional Director, written questions from the public and media may be submitted at or af ter the meeting for consideration in the exercise evaluation.
Also, the Regional Director may further use his/her discretion to solicit and respond to oral questions and comments during this meeting.
Under no circumstances should it be indicated whether State or local preparedness is adequate or inadequate.
- c. During the meeting, the RAC Chairman should offer an overview of the exercise and should provide his/her
({)
observations.
Comments f rom the RAC members and FEMA observers may be solicited at the discretion of the RAC Chairman.
- 5. "Meetinas" 1,gI exercises conducted durinn l1Q amoroval procena Requirements in 44 CFR 350 do not address the conduct of
" meetings" for exercises, held af ter the initial, qualifying exercise but before the completion of the 350 approval process.
For such exercises, a meeting as described in 350.9(e) should be held (the context of this meeting in the rule is for exercises conducted for continued FEMA approval).
FEMA's evaluation of such " interim
- esercises is an integral part of our overall 350 approval process; therefore, an opportunity should be provided to the exercise participants, the public, media, and other Federal agencies to discuss the performance of the exercise and the preliminary evaluation.
6.
'Meetinas' 31131 remedial exercises Af ter remedial exercises required under 44 CFR 350.9(a) and 9 (c) (5), it is necessary to hold a debriefing (item 2 above) and may be necessary to hold a meeting (item 3 above).
Because remedial actions may vary from remedial esercises (O
involving many organlaations to drills involving only one or two organizations, discretion is given to the Regional Director to determine the need to convene a meeting to which s
7 n
e
(])
the public and media are invited, in accordance with 44 CFR 350.9 (e).
III.
Exerclae Obiectives The following list of 35 exercise objectives is to be incorporated into the design of radiological emergency preparedness exercises.
These objectives are presented in two groups.
Group A, numbers 1 - 13, are core objectives that are to be demonstrated in each biennial exercise.
Group B, numbers 14 - 35, are to be included in at least one exercise during a six-year period per guidance provided in GM PR-1.
CBQQI A - SQEE OBJECTIVEB CORRES PONDING OBJECTIVE PARTfS) QI MODULAR FORMAT NUREG-0654 1.
Demonstrate ability EQC Sec. I E.1.,
to mobilize and EQI sec. I E.2.
activate facilities HInla Sec. I promptly.
RELOC Sec. I In Sec. I 2.
Demonstrate ability EQC Sec. II A.I.d.,
O to make decisions and A. 2.a. "
to coordinate emergency activities.
3.
Demonstrate adequacy IQC Sec. III G.3.a,H.3.
of facilities and HEQIA sec. II displays to support emergency operations.
4.
Demonstrate ability EQC Sec. IV F.
to communicate with IQI Sec. III all appropriate MEDIA Sec. III locations, organ-RELCC Sec. III izations and field IA Sec. I,II personnel.
15 Sec. IV 5.
Demonstrate ability IQC Sec. V I.10.,
to project field data IQI Scc. XI J.10.m.
and to determine approp-riate protective measures, based on PAG's, available shelter, evacuation time estimates and all other appropriate factors.
()
6.
Demonstrate ability EQC Sec. VII.A J.9.,
to implement protective IA Sec. I J.10.g.
actions for plume 8
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e
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pathway hasards.
I 7.
Demonstrate ability EQC sec. VI E.6.
to alert the public Z& sec. III within the 10-mile EPs and disseminate an initial instructional message within 15 minutes.
8.
Demonstrate ability EQC sec. VI E.5.
to formulate and distribute appropriate instructions to the public in a timely fashion.
9.
Demonstrate the EQC sec. VII.A J.10.R.
organizational ZA sec. I ability and resources necessary to deal with impediments to evacuation, including weather or traffic obstructions.
- 10. Demonstrate ability EQC Sec. VIII R.3.a.b.
to continuously ZA sec. IV O
monitor and control I5 sec. Y l
emergency worker exposure.
- 11. Demonstrate ability EQC sec. IX G.3.a.,
i to brief the media in HERIA sec. IV G.4.a.
a clear, accurate and EQI sec. IV 1
timely manner.
j
- 12. Demonstrate ability to EQC sec. IX G.4.b.
i provide advance MEDIA sec. IV i
coordination of infor-mation released.
1 i
- 13. remonstrate the ability EQC sec. V J.10.e.
l to make the decision, EQC sec. VIII J.10.f.
based on predetermined EQZ sec. VI criteria, to supply ZA sec. IV and administer RI to Z3 sec. V 1
emergency workers.
SEQ 2Z A - DIREE DaJECTIVES
- 14. Demonstrate the ability EQC sec. V J. 10.e.
to make the decision, EQZ Sec. VI J.10.f.
I based on predetermined EQC sec. VIII i
criteria, whether to ZA sec. IV issue KI to the general Z3 sec. V population, and supply j
9
C) and administer KI, once j
the decision has been
(
made to do so.
- 15. Demonstrate the ability EQC Sec. VIII J.10.e.
to supply and adminis-I& sec. IV ter KI, once the Z5 Sec. V decision has been made to do so.
- 16. Demonstrate ability EQZ Sec. II G.4.c.
to establish and HEDIA sec. VI operate rumor control in a coordinated fashion.
- 17. Demonstrate ability EQC Sec. I A.2.a.,
to fully staff EQI Sec. I A.4.
facilities and maintain HEDIA Sec. I staffing around the EELQG sec. I clock.
i
- 18. Demonstrate ability IM Sec. I E.2.,
to mobilize and deploy I.S.
' n field monitoring teams U
in a timely fashion.
t
- 19. Demonstrate appropriate IM Sec. II, III I.S.,
equipment and procedures I.11.
for determining ambient radiation levels.
- 20. Demonstrate appropriate IM Sec. II, III I.9.
equipment and procedures RADLAB Sec. I, II for the measurement of airborne radiciodine as10-grationsaslow concen uCi/cc in the presence of noble gases.
l
- 21. Demonstrate appropriate Is sec. II, III I.S.
equipment and procedures RADLAB Sec. I, II for collection and j
transport of samples of soil, vegetation, snow, j
water and milk.
l
- 22. Demonstrate appropriate B&DL&B Sec. I, C.3.
O lab operation functions Sec. II for measuring and analysing all types of f
samples.
i 1 10
()
- 23. Demonstrate ability to EQC sec. V I.10.,
project dosage to the J.11.
public via ingestion
.g pathway esposure, based on plant and field data, and to determine approp-riate protective measures, based on PAG's and other relevant factors.
- 24. Demonstrate ability to EQC Sec. VII.C J.9.,
implement protective J.11.
actions for ingestion pathway hazards.
- 25. Demonstrate the organ-EQC sec. VII.A J.10.j.
izational ability and IA sec. I resources necessary to control access to an evacuated area.
- 26. Demonstrate the organ-EQC Sec. VII.B J.10.d.
Izational ability and IA sec. II.B resources necessary to effect an orderly evac-untion within the plume O
EPZ of these groups:
transit-dependent, special needs and institutionalized.
- 27. Demonstrate the organ-EQC Sec. VII.B.
J.9.,
izational ability and IA Sec. II.A.
J.10.g.
resources necessary to effect an orderly evac-untion of schools within the plume EPI.
- 28. Demonstrate adequacy EILQC Sec. II J.12.
l of procedures for the registration and i
radiological monitoring of evacuees.
- 29. Demonstrate adequacy EELQC Sec. III J.10.h.
of facilities for mass care of evacuees.
- 30. Demonstrate adequate DECQ3 all K 5.a.b.
equipment and procedures for decontamination of
()
emergency workers, equip-ment, and vehicles.
{
11 i
I O
- 31. Demonstrate adequacy of HEDig Sec. III L.4.
ambulance facilities and
(
and procedures for handling contaminated, injured and esposed individuals.
- 32. Demonstrate adequacy of HEDIC Sec. II L.l.
hospital facilities and procedures for handling contaminated, injured and exposed individuals.
- 33. Demonstrate ability to To se Developed C.1.a.b.
Identify need for, request, and obtain Federal assistance.
- 34. Demonstrate ability to EQQ Sec. V M.4.
estimate total EQI Sec. VI population exposure.
35.* Demonstrate ability to EQC Sec. X M.l.
determine and implement appropriate measures for controlled recovery and reentry.
O 1
12
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.a ase,.
/
UNITED STATES NUCLEAR REGULATORY COMMISSION
- b. O '-)-
gi waswiwarow.o.c.aoses
, k.....
(
l l00 (a, MEMORANDUM FOR:
James M. Taylor, Director Office of Inspection and Enforcement FROM:
Edward L. Jordan, Ofrector Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
SUBJECT:
REPORT OF NRC ACTIVITIES IN SHOREHAM EXERCISE Enclosed for your information is a report of the NRC activities related to the Shoreham exercise which was conducted on February 13, 1986.
The report focuses primarily on those aspects of NRC's support to FEMA in conducting the, offsite portion of the exercise.
The onsite observation was conducted in the O
4 same manner as other licensee exercises.
Edward L. Jordan, Director Olvision of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
Enclosure:
As stated O
2 DesnoglTION EXHIBIT 1
k i '
,n 00G
( x, out PARTICIPATION ffi THE FEB9UARY 13, 1986 EXERCISE
(_)
AT tee S10RFPAM tiljCl.E AR POWER STATION NkC staff earticipateo in noth the onsite and offsite choses of the February 13, 19 P.6, exerci9e at the Shorenam iduclear Power Station. A chronology outlining the events (fncusec primarily on NRC suoport to FLv&) leanir." uo to the exercise is Fnclosure 1.
4ftC @ SITE huAll>ATION:
The evelustinn of the licensee Ptsponse to the scenario events was conoucted in the same vannae as ione et other full-scale exercises.
This asoact of the exercisa was managed ny 'JPC Recion I ano involveo atent onservers ('.RC
<I, 4RC Pos enc PL) wno evaluated the licensee response ac* inns ano facilities.
Initial indications are that the licensee performac wall ann it is not expecte3 that there will be any serious netietencies in tne eenort ceinq creoared oy PAC NI.
FEVA 0FFFITL t V ALU A T T.TJ :
Since suffol<
County ens *** York State had refused to participate in enereency clanning, LILCD eevelooed a clan for Snoreham which provided that the lae0 role for offsita o?*esencv ra9ponse is administereo Oy a
/~S LILCO sanasered ornanizatier cettee tne Local Eeerceacy Resoonse (I) necanitatinn
( L ? 4 f.' ).
Since FL *' A is responsible for evaluatina tne aftsite rassen9e te canioloodcet emeriencias, PE*A, in this
- exercise, evalueteo the LEkC rasoons* canonilities. At the request of FEP'A, NPC proviceO 9urrort in concuattee car **in tasks unicue to this Particular exercise.
la a
9ermal auercise, relevant State and local government personnel act as offsite controllers. Too controllers in this exercise were not S* ate or local amoloveest instead fAC, in support of FFMA, provideo the fellowina contenllers:
.u nee of Controllers Location / activity 1
LC80 F. mar 1cney dos Center 1
Date'iouce Stagino Aras 1
Diverheno.9teging Area 1
8 art Jeffeeson Staning Aree 2
Prouwnaven Monitorino Teams in
- aceitten, to test iYLCO's response to ad hoc govarnmental participetion in on ectual eaersancy, niculators
(* $4C and 3 AEuA) were proviaen to test LILCn/t(RD's eMility to respond to the presence of and questions from varicus County ano State officials. (A cetailed description of each of the simulator essionments is Enclosure 2.)
Throuah tne use of ninulators, FEMA was able to evaluate LILCO's cacacility (1) to accomodate t%e presence of dtate ano local officials, O (2) to suonort tmose officials u11ng the resources avail 4 ele throuch w-
T 007 LERO, and (3) to provide those governmental officials with sufficient
/~')
performino these simulations, information to carry out their State and County responsioilities. In
(_
elRC and FEWA staff did not oerform any
. actions r e.s e r v e c to State and local governments. As per instructions, they 010 not assume any commend and control authority, and did not interact with Pembers of the public so as to lead anyone to believe that they were actually State or County officials.
In
- addition, "RC situlators eid not plav any of the 1*cisionmaking oositions.
These Suffolk County and State cositions which were represented by the simulators and t%e facilities wnera they ware locateo are listed below!
Facility Position Simulateo LE45 Fa.aroency Oos Center occuty county Executive (FE*A)
County Health Dept. Tech. Liaison County Punlic Information Officer State Health Dept. Tech. Liaison LILC6 E?*ryancy stes Facilitv County He91th Oept. Tech. Liaison State Health Dept. Tech. Liaison County 84areeney nos Certer County Executive (FEdA)
( F r.' A Control Cell)
County Health Oeot. Tech. Liaisoo other County Oecartment Liaisons Stita iavenerry oos center State Health Commisssioner (FE>A)
(fr A Centrol Celli State health Dept. Tech. Liaison in orcer tn *ssure t9at tne aroune rules for the simuletion defe followee and eacn i n.1 t v i fo d i simuletinq State or County officials at
/~'
the LECJ FIC, LILCn CJF, and t *e FP A Control Cell strincently follo=ec
(
enate instructicas, a contaellar *,es 4ssigned to each location (3
'*C inetviduals)
'o,ivclu9tv51r fncus on this asuect of the evorcise, eacn
(
sf tnesa enntrollers had conaidecabla encerience in crevious exercises anc enc 5 es, mean intimetalv involvac in the planning effort for t r. e strulatina ene'ien of tha exerci9e.
TFa f.wC eng cPe individuals involved in the offsite control ann siaulation in
- ris exercise (Enclosure 3) performed their tasks in a hi-nly orefe951oa41 menner.
- hee, necessary, they used accropriete Juccen.ent in t*rfo*inc tnair tasks anii essurino that the exercise was cennoctec in tae -anner in whien it wcs desinnec.
Tne loos of tnase inaividuale, alano aith soae observations certainino to the manner in
.nic*
fney cam *urten thair tesks, unae provt.1ed to FE?'A shortly efter tra conclusion of tne aparcise.
Tney will be utilizen by t* e Af' A evelv4 toes ia the fornal FO 4 ewaluetion which is exoectec to ca availecle APaut siv wa***
oftae tha anaccige. Deelf-inerv inaire'io-e fror Sb e are enat the LE M **sonnme was panorally acanueta, aut tnat FC"1 will Itkely idantify evficionetas related to tna fellewina er*49 ia tna fin al reLort to the *.DCI
- tenarant nel4vs in LL40 resoonsa to injected tedffic (Frenitents
.1urino the 91*ulated evecuattnm.
}efietancies in some rus drivers performance in timely enn accureta route completice.
0*fictencies in perfor*ence of some oarsonnel in nerfortina ecuta elert functions.
O etae e'
e ENCLOSU;E 1 SHORdHAr EXERCISE CHRON0 LOGY i
00d June 20, 1988 NUC requested FEMA to "... schedule as full an exercise
/~
of the LILCO Local Emeraency
Response
Organization
(_)T (LCPO) olen as is feasible at the present time..."
Oct. 49, 1989 FFMA stateo that an exercise of the LERO olen could be conducted.
- Newever, cue to tne reluctance of State and local officiels to particioste, FEdA proposed two options for conductine the exercise.
"nv.
17, 1965 NPC informed FE'dA that an exarcise should on conducted consistent with the soproach outlinec in your Option 2"
4.a. simulation of State and local onvernment participation.
'ov.
lu,1945 0FFEk Director, F Us v a n =c e r, IAR 9ennch Chief 6eiss) ano a staf f n ariber wet with FE 4A manacetent.in i staff to discuss the r9pnee in whien Nhc would suoncet FEva in conductino offsite centrol functions.
'4 c v. ?t, 14a5 Ih? staff member (r.aisst attendeo a e.eetinu hele in FEMA
<!! offices in snich tne RAC Chairman oresented LILCO staff with a
proposed set of exercise ocjectives-for comment, in ancitio9 to the offsite technical parameters for develootro the
- scenario, i.e.
wind cirections, offsite doreg et particular cistances, etc.'The meetipo
.ms also attenced by FCIA Hascouerters and Pepionel enunsel clus '4r reaional staff (enato).
e c.
3-4, for$ ids 4 ranch Chief and a steff aeroer (4'eiss) attenoee a i
lerne-scale LILCO urill of t.ota the ansite ann LEko resnonse olens in oecea to 64(n a cetter scoreciation of the any in whic%
the LEG 1 clan Soerates Ano an undarstandino of how the er4ded exercise can bast be contenileo ano tne offmite officials simulatec in a realistic aanner.
Gae. 11, 19t*
ire staff mamner D.aiss) and 4C al r eca l v sd contes of a dr6ft of the LILLO awercise scenario.
dec.
I',
14.58 106 staff r..e + > c r D.eiss) met witn tae 8 P..t JAC C* air-se ano T'M A to oiscuss tha int =1 ration of the FE/A Evaluation rian an, tna uffsite control Plan to uncerstand the nu* oar ane ewpart19e of t9a Ner. wnic%
would oe usen in the conteel of the ottsite portion of the creded e=*rcise.
J6n.
4, 14A.
OFFEP
- Directer, IPd
- ranch Cnief ane staff (*aiss) met t
.ith FE9A Associete wirector, State end Local Proorams O
para 2 ^
f T
00J support and staff to review the 3taff plannino for the
(~g control of th* nf.fsite nortion of the -Shoreham exercise.
(_)
In the
- meetina, tnere was agreement, regardino the simulator postions far wnich FEMA kould prnvide 'an inoividual.
Final cecisions concerning the soecific ansionment of incividuel controllers and si*ualtors were to be determfned after revica.of the control plan with the FEMA 94C Chairtan.
Jan.14-15,199o l eil staff
(^eiss and Sakenas) is to meet witn the FEMA 4AC Chairman and otner Fr*A -support to review and finalize the draft Conteo1 Plan anc make assionments for the remainitio t9sks to implement t >.'e C o n t r o l plan and assure that all logistic matters y, ave eeen adcressen.
Jon. 18, 14t$
AC RI orovicec consalidaten *RC Eom<nhat s to LILCO on the scenario for tna it.oranea eveecise.
Jan.;?, 1946 The General Counsels o f 'U C a ic F E* A sen* a letter to the Suffolk County Eracutive indicatino a desire foe the County to particioate, lavico out the anencies' concerns about the effec
- of the l **gi s l a t i on and describina-how the
- exercise, particular1v the simulation of County officials woutc 09 concucted.
Jan. 21, t m. a The EDO sent %cCY-e6-73 to tne Co.v.vissioners informing te
- of the current status cf the crocosee enereise at e
shorena*.
4 t
Jan. 23, 14b' an initial eriefia*.
of
- ne
.HC ens F D' A nffsite controllers was conducta: to inften these inciviouals of the backcrourc of tr.is evercise. geneca,1 oescriotion of how tne offsite control, includino simulation, will oe concucted, toeistic a r r e n o e t e n t: s,
traininn eno leoal enneerns. Those cresent et the PNC Oper a t ions C4n t er or carticipating vie tea taleconferenca network were:
E. Jorsan, IE
". nion", OGC E. Cncistenbury, ELD L. sers, HT1 6.
Derkins, IF
- r.. u ro.n, 4v
- 1. Weiss, IE
- t.. G o o +e n, RII
.l. kimes, IE
. '. Thoras, FE:A
' '. dawwins, Ir S.
Senwartz, IE F.. Seinstein, IE
". Lancau, $7 E. Dooolak, le
- t.. -nlling, aw 9
Meew, te E.
illians, IE 4
Kowieswi, *Ewa
- c..onoven, PEvA Jan. 2d, 19e8 The Departmeat of austice sant a letter to tha Suffolk County Executive wnica descrioed the concerns of tne Feoeral Government witn resnect to the recent county lecislation reosedina tne conduct of exercises.
The latter in.1(catec that if the County did not take action to allow tne awarrise en re conductect' leoal action
- av O
ha tawan.
occo 3 T
Did 7s Jan. 30, 1936 Presidins Officer of tne Suffolk County Leoislature
\\
resoonded to the 1/24/46 00J 1etter indicatina that the County leoislature would not ce in a position to act on LILCO's suomission until February 7.
Jan 31, 1986 00J sent a eletter to the Presiding Officer of the Suffolk Countv Lcoissature indicating tnat if the County did not resolve this matter ny 2/3/80, they would seek "immediete Junicial calief."
Fee.
3, 1796 Sutfoix County cualisked a full-oage letter to President eiescan in tha wwshinoten Post. The letter recuested tne President to i r. t o r v a n e in this matter a n 'J stop the eWerCise.
Feb.
4, 1996 DnJ commencer action ensinst Suffnik County and th*
County Fzecutive in 6 estern isistrict Court of New York seeking a ce=14e.inary injunction restraining the County from enforcine local 13w 2-Sc.
Feb. 10, 19e6 The Court Jracten ene neeliminary i nj un c t i on.
Feb.11-12,1986 Trainino ela s orevisen for all ottsita controllers, evaluatnes aau situlators eacticicatino in the Shoreham exercise.
(
-m Fen. 13, 1006 The Srorens-exarcis.-.as enneucte.1 as nianned.
t)
- ee.
14, loAA All..oC en) F'<a sic.ulatoa eno offsite controller loas are notem
.are provised t e F F.
- A for their use in the oevelocmert of t ri a FE M evaluation escort.
Feb. 15, 19dA FF"a conducter a ruhlic cri*iove of the exercise.
Farruarv P1, 19an l
O I
i
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i r
Oli ENCLOSijRE 2
(, SIMULATOR INFORMATION 1.
The following assumptions apply to all simulators State roles to be simulated will, as much as possible, be o
consistent with New York State plans for other nuclear power plants and the manner in which State personnel have participated in other exercise.
Suffolk County roles to be simuisted will, as much as possible, e
c be consistent with the manner in which other counties have 1
participated in other New York facility exercises and the New York State Plan.
e For the punose of this exercise, simulators representing state and local personnel will not assume a response posture, e.g., M ALL TIMES, SIMULATORS WILL ALLOW THE LERO STAFF
\\
TO DIRECT ALL RESPONSE EFFORTS.
1 2.
Following are specific simvlator assignments:
i a.
SUFFOLK bUNTY SIMULATORS:
1.
HEALTil DEPARTMENT REPRESENTATIVE AT THE LILCO EOF. An individual simulating a Suffolk County y
technical representative (Health Department) will arrive at the Shoreham Emergency Operations Facility (EOF) just after the declaration of a Site Area Emergercy (about 45 minutes). That individual will act as a liaison between LILCO and the Suffolk County Health Commissioner and should periodically brief tne County health representative at the Suffolk County EOC to keep him informed of the progress of the emergency. The 5
.[ ).
da-...~---.---.----------
~ ' -
' ~ ' - ' " ~ ~ ~ ~ ' " ~ ~
' ~ ~ ~ ~
c
ene CI; objective for the individual playing this role is to obtain timely information from LILCO, e.g., LILCO's ability to provide Suffolk County (through this individual) with appropriate information, and to determine if there is adequate space and logistical support for Suffolk County respresentative. In carrying out this role, the Individual should contact the County Health Department repre-sentative in the LERO EOC to determine if the information being obtained there is consistent with the data being given to him at the EOF. This individual should also contact the County Health Department representative at the FEMA control cell. This individual should not infer that Suffolk County would be taking over t
any command and control functions or accident assess-O ment responsibilities.
(
2.
COUNTY EXECUTIVE REPRESENTATIVE AT LERO EOC. An individual simulating a Suffolk County IIalson to the County Executive will arrive at the Shoreham EOC in Brentwood just after the declaration of a Site Area Emergency (about 45 minutes). That individual will act as a liaison principally between the LERO Director of Local Response and the County Executive.
The individual l
i simulating the liaison for County Executive should i
periodically brief the County Executive (simulator at the FEMA control cell) to keep him informed of the progress of the emergency and the LERO considerations for protective actions. The objective for this individual is to l
i 01J w
test the ability of LERO to allow Suffolk County to become involved in the deliberations with regard to making < protective action recommendations and implementing those recommendations: e.g., by keeping the County Executive representative informed in a timely manner of the assessment of the situation, progress of the emergency response, and the status of implementation actions. This individual should not infer that Suffolk County would be taking over any command and ebhtrol functions or decisionmaking responsibilities but rather he should ask the County be briefed on any major LERO decisions:
e.g., the liaison simulator should insist that before taking any major actions affecting the public (i.e.,
sounding the sirens, recommending protective actions to the public, etc.) the Director of Local Response should call the County Executive (simulator at the FEMA control cell) to brief him of the contemplated protective actions.
3.
HEALTH DEPARTMENT REPRESENTATIVE AT THE LERO EOC. An individual simulating a Suffolk County technical representative (Health Department) will arrive at the LERO EOC in Brentwood just after the declaration of a Site Area Emergency (about 45 minutes).
That individual will act as a liaison between the LERO Health Services Coordinator and his staff and the Suffolk County Health Commissioner and should periodically brief the Health Department representative at the Suffolk County O
EOC (FEMA control cell) to keep him informed of the
T 014 O
I status of the accident assessment and the protective actions recommendation being consider?d by LERO. The objective'for the individual playing this role is to obtain timely information from Radiation Health Coordinator (LERO) and to determine if there is adequate space and logistical support for Suffolk County representatives. In carrying out this role, the individual should contact the County Health Department representative in the Shoreham EOF to determine if the information being I
obtained there is consistent with the data being given to him at the LERO EOC.
He should also contact the County Sealth Department representative (the FEMA e
i control cell). This individual should not infer that Suffolk County would be taking over any command and control
(
aspect part of the accident assessment function. Note, this individual should, shortly after arrival, also inform the LERO Evacuation Coordinator that any information or issues which he feels would be of interest or concern to the Suffolk County Police should be communicated to the County Police representative (simulator) at the FEMA control cell.
4.
SUFFOLK COUNTY PUBLIC AFFAIRS OFFICE REPRE-SENTATIVE. An individual simulating a representative of.
l the Suffolk County public affairs office will arrive at the LERO EOC in Brentwood just after the declaration of a Site Area Emergency (about 45 minutes). That individual O
should go to the office of the LERO Coordinator of Publie l
T o,e~)
r Information and be the pub!!c affairs liaison between the Suffolk County EOC and the LERO EOC. (Note,4 State PIO will*not be simulated at the LERO EOC.)
The objective for this individual is to test the ability of the LERO public affairs group to coordinate the development and release of press releases and EBS messages with County officials. This individual shoulti not infer that Suffolk County would be taking over any responsibility from LERO in the public information area. Rather, the County would like to review any information that is being released to the public and attend any discussion (s) regarding preparation of the same. This individual should t
keep the Suffolk City Liaison (at LERO EOC) and the County Executive (at FEMA control cell) briefed on.all major items and developments.
5.
COUNTY EXECUTIVE AND COUNTY
RESPONSE
DEPARTMENTS AT COUNTY EOC (FEMA Control Cell). Three individuals will simulate (FEMA control cell)
Suffolk County officials at the FEMA control cell: i.e.,1) the County Executive; 2) County Health Officer; and 3) other County Departments, as necessary. Other than the RECS calls to actual Suffolk County locations, the rest of the telephone communication between LILCO/LERO facilities and Suffolk County staff, will be made to these
{
individuals. These individuals will respond in a manner which is, as much as possible, consistent with this exercises' ground rules, e.g., Suffolk County will not take t
1 7
Oh O
~l over any command / control, accident assessment, decision q
making, or implementation functions. These individuals will questibn any information or decisions provided in a 1
deliberate, professional and responsible manner.
The simulators will not be limited to only responding to calls placed to them but can place calls to the LERO EOC/LILCO EOF in keeping with their objectives. When the simulators do not feel that they possess sufficient information, such further information should be requested and where it is felt that the rationale for particular recommendations are not clear, further explanations should be sought.
e The County Executive representative at the LERO EOC will insist that the Director of Local Response call the County Executive (at the FEMA control cell) whenever he i
is to take any major actions affecting the public. When the Director of Local Response calls, the County Executive should not infer that he is assuming i
responsibility for such a decision or approving such a decision.
Rather, the County Executive (simulator) should only comment on the decision or basis for the decision, ask for clarification or suggest further areas l
needing consideration. The simulator should not create a situation where his request may/will delay a LERO protective action decision.
O
,.,,---,._-,,-n.,_
,. + -, -..,,,,
,.m.
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,,,,_w.__
,,-,,,_,,,,_m,n,-n-,..,_,_.,,,n,
e T
017 b.
STATE SIMULATORS:
~
1.
STATE HEALTH DEPARTMENT REPRESENTATIVE AT LILCO EOF.
An individual simulating a technical representative of the State Health Department will arrive at the Shoreham EOF after the declaration of a Site Area Emergency (about 90 minutes). That individual will act as a IIalson between LILCO and the State Health Depart-ment and should periodically brief the State Health repre-sentative at the FEMA control cell to keep him informed of the progress of the emerTency response c.nd accident
~
assessment.' The objective for this individual is to obtain timely information and to determine if there is adequate space and logistical support for the State representa-O tives.
This individuai shouid also contaet the State I
representative at the LERO EOC to determine if the information available to each representative is consistent. The individual should not infer that the State would be taking over any accident assessment responsibilities.
2.
STATE HEALTH DEPARTMENT REPRESENTATIVE AT LERO EOC.
An Individual simulating a State Health Department representative will arrive at the LERO EOC in Brentwood after the declaration of a Site Area Emergency (about 90 minutes). That individual will act as a !!alson between the LERO Health Services Coordinator and his staff and the Commissioner of Health or his designee in Albany and should periodically brief the State
T Old
- O Health representative at the FEMA control cell to keep
(
him informed of the progress of the emergency response i
(seeldent adsessment) and the protective recommendation actions being considered by LERO. The objective for the individual playing this role is to test the ability of the LERO to provide timely information and to determine if there is adequate space and logistical support for state representatives. In carrying out this role, the individual should contact the State Health Department representa-tive in the LILCO EOF to determine if the information being obtained there is consistent with the data being given to him at the LERO EOC. The individual should-not
~
e infer that the State would be taking over any accident O
assessment responsibilities. The individual should insist
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that before taking any major actions affecting the public, i.e.,
sounding the sirens. recommending protective actions, etc., the Director of Local Response should call the State Commissioner of Health (simulator) to inform him of these actions.
j 3.
COMMISSIONER OF HEALTH OR DESIGNEE AT ALBANY EOC (FEMA Control Cell). An individual will simulate the Commissioner of Health or his designee at the FEMA control cell. That individual will respond in a t
manner which is, as much as possible, consistent with this exercise's ground rules, e.g., the State will not take over l
any command / control, accident assessment, decision
' O making or implementation functions.
The individual l
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should request appropriate accident assessment informa-tion, determine rationale for actual or proposed protective 8 actions and question any of these actions, as appropriate, in a deliberate, professional and responsible manner. In that capacity, the individual will respond to all calls from LILCO/LERO and initiate calls to further these objectives. This individual should not infer that the State would be taking over any Accident Assessment functions and/or decisionmaking responsibilities but rather ask that they be allowed to review any major LERO protective action recommendations, actions, etc.
4.
STATE D2PARTMENT OF HEALTH AT THE STATE EOC t
IN ALBANY (FEMA Control Cell). An individual will simulate a Health Department technical representative located at the FEMA control cell. This individual will be the !!alson between the State Health representatives) at the LERO EOC and the LILCO EOF and the State
)
Commissioner of Health. If the information provided by these Health Department representatives differ significantly, this should be pointed out to these representatives so that they can ask additional questions l
to find out the basis for any differences. This individual i
should also confer with the Health Commissioner (simulator) to compare information being provided so that the Health Commissioner (simulator) can bring up any i
differences or discrepancies during his discussions with i O the Radiological Health Coordinator. Before the Health i
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representative (s) arrive at the LERO EOC and the LILCO I
EOF, this individual should call these emergency response facilities 2 inform the staff that State Health Depart-ment representatives will be arriving and to request briefings, etc. If a LILCO player at the LILCO EOF or the LERO EOC should call the State EOC to confer with an individual from a New York State agency other than the Health Department, this individual should response to the inquiry and inform the Senior Controller at the FEMA control cell. This individual should not infer that any State agency would be taking over any accident assess-ment function and/or decisionmaking responsibilities.
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I ENCLOSURE 3 SHOREHAM EXERCISE CONTROLLERS n
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.C"ATION RCLE NUNCER NAME LERO EOC GENID*
'9' TROLLER 1
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CCrJC'/AN, FEMA e
CCNTER CC?;TFCLLER 1
K. PM KINS,NRC/:2 DEP. COUNTY EXEC.
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THOMAS, FEMA /SLF7
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L. KERS,NRC/RIII C0ur' HEAL H REP 1
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