ML20213E617
| ML20213E617 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/04/1986 |
| From: | Mark Miller, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SUFFOLK COUNTY, NY |
| To: | Federal Emergency Management Agency |
| References | |
| CON-#486-1446 OL-5, NUDOCS 8611130231 | |
| Download: ML20213E617 (43) | |
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4 RELATED CORRESPONDEN_CA 00CKETED USNRC November 4, 1986 UNITED STATES OF AMERICA
'86 NO 10 P4 :23 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina NddEd
~
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON'S FIRST REQUEST FOR ADMISSIONS AND SECOND SET OF INTERROGATORIES DIRECTED TO FEMA I.
DEFINITIONS FOR USE IN ANSWERING REOUESTS FOR ADMISSIONS A.
As used herein " FEMA" means the Federal Emergency Management Agency and its staff, any division or section or region thereof, any staff member thereof, or any agent, consultant, contractor, technical advisor, employee, or representative (including but not limited to attorneys and accountants and their employees and agents) of FEMA, including representatives of other federal agencies or contractors who acted as federal evaluators, controllers, or simulators during the Exercise (see definition B below).
8611130231 061104 PDR ADOCK 05000322 PDR g
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B.
The term " Exercise" refers to the exercise of the LILCO Offsite Emergency Plan for Shoreham conducted by FEMA on February 13, 1986, and includes activities at the LILCO EOF and the
" Medical Drill" held on February 9, 1986.
C.
The term "LILCO" or "LILCO personnel" means Long Island Lighting Company, any affiliate, agent, employee, consultant, contractor, technical adviser, representative (including, without limitation, attorneys and accountants and their respective agents and employees), or other person acting for or on behalf of LILCO, or at LILCO's direction or control, or in concert with LILCO or assisting LILCO.
D.
The term "LERO" means Local Emergency Response Organization.
E.
The term " Plan" or "LILCO Plan" means LILCO's " Local Offsite Emergency Response Plan" for Shoreham.
II.
REQUEST FOR ADMISSIONS Pursuant to 10 CFR S2.742, FEMA is hereby requested by Suffolk County, the State of New York, and the Town of Southampton to admit the following facts:
7 1.
That FEMA conducted the Exercise.
2.
That 38 Federal evaluators, who were coordinated by the FEMA Region II RAC Chairman, were assigned to evaluate LERO and LILCO activities during the Exercise.
3.
That the report, dated April 17, 1986, entitled " Post Exercise Assessment - February 13, 1986, Exercise of the Local Emergency Response Organization (LERO), as specified in the LILCO Transition Plan for the Shoreham Nuclear Power Station at Shoreham, New York" (the " FEMA Report"),
constitutes FEMA's evaluation of what was done during the course of the Exercise.
4.
That the contents of the FEMA Report are based upon evaluations made by Federal evaluators during the Exercise.
5.
That the Exercise was not a " full participation exercise" as defined in 10 CFR Part 50, Appendix E S IV.F.1.
6.
That the LILCO siren system was not activated, tested or evaluated by FEMA during the Exercise.
7.
That the LILCO Emergency Broadcast System ("EBS") was not activated or tested or evaluated by FEMA during the Exercise.
o 8.
That WALK Radio did not participate in the Exercise.
9.
That during the Exercise FEMA did not evaluate notification or emergency communication capabilities of WALK Radio or WALK Radio personnel.
10.
That during the Exercise FEMA did not review or evaluate the implementation by WALK Radio personnel of procedures re-lating to operation of the LILCO EBS system, or communica-tions or interactions between WALK Radio personnel and LERO personnel.
11.
That none of the other radio stations relied upon by LILCO to broadcast EBS messages during a Shoreham emergency (i.e.,
WBLI, WCTO, WGLI, WGSM, WLIM, WLIX, WLNG, WRCN, WRHD, WRIV) participated in the Exercise.
12.
That the water portion of the 10-mile EPC (i.e.,
the Long Island Sound) constitutes nearly 50 percent of the physical area of the plume EPZ.
13.
That during the Exercise FEMA did not observe U.S. Coast Guard personnel perform any public notification, protective action communication, waterborne traffic control, or access control functions on the water portion of the Shoreham EPZ.,
14.
That during the Exercise FEMA did not evaluate the capabil-ity of the U.S.
Coast Guard to notify waterborne traffic in the Shoreham EPZ of the existence of a Shoreham emergency.
15.
That during the Exercise FEMA did not evaluate the capabil-ity of the U.S.
Coast Guard to issue or communicate pro-tective action recommendations to the public on the water portion of the Shoreham EPZ during a Shoreham emergency.
16.
That during the Exercise FEMA did not evaluate the capabil-ity of the U.S. Coast Guard to provide timely commercial and private vessel traffic control or access control on the water portion of the Shoreham EPZ during a Shoreham emer-gency.
17.-
That during the Exercise FEMA did not observe any personnel perform or take any actions on beaches, in parks, or on the water portion of the Shoreham EPZ.
18.
That during the Exercise FEMA did not evaluate or review the adequacy of materials proposed by LILCO to be public education materials or designed to disseminate information to the public on a periodic basis. -
19.
That during the Exercise FEMA did not evaluate or review the adequacy of LILCO's procedures for the dissemination of information concerning Shoreham to the public on a periodic basis.
20.
That during the Exercise FEMA did not observe, review'or evaluate any activities at the Suffolk Infirmary, or the St.
Charles or John T. Mather Hospitals.
21.
That during the Exercise FEMA did not review or evaluate procedures for the evacuation of patients from the Suffolk Infirmary, or the Central Suffolk, St. Charles, or John T.
Mather Hospitals.
22.
That during the Exercise FEMA did not evaluate the capability of implementing an evacuation of patients from the Suffolk Infirmary, or the Central Suffolk, St. Charles, or John T. Mather Hospitals.
23.
That no officials or personnel from the Suffolk Infirmary or the St. Charles or John T.
Mather Hospitals participated in the Exercise.
24.
That during the Exercise FEMA did not review or evaluate procedures for the sheltering of school children in schools during a Shoreham emergency. - -
25.
That during the Exercise FEMA did not evaluate the resources or capabilities of school officials to implement the protective action of sheltering school children in schools in the event of a Shoreham emergency.
26.
That during the Exercise FEMA did not observe any demonstration of LILCO's organizational ability to effect an early dismissal of school children within the Shoreham EPZ.
27.
That no school districts inside or outside the 10-mile EPZ, or officials from such districts, except the Shoreha'a Wading River School District, participated in the Exercise.
28.
That during the Exercise FEMA did not review or evaluate procedures approved by school or school district officials for the evacuation of school children during a Shoreham emergency, except for those of the Shoreham Wading River School District.
29.
That during the Exercise FEMA did not evaluate the capabil-ity of schools or school districts to implement an evacua-tion of school children during a Shoreham emergency, except for the Shoreham Wading River School District.
30.
That during the Exercise FEMA did not observe or evaluate the implementation of procedures for determining, issuing, or implementing protective action recommendations for the ingestion pathway EPZ, except for LERO recommendations to shelter dairy animals within the 10-mile EPZ and to place them on stored feed.
31.
That during the Exercise LERO personnel made no protective action recommendations for the ingestion pathway EPZ beyond the 10-mile zone.
32.
That during the Exercise LERO personnel made no protective action recommendations concerning drinking water, fruits, vegetables or other food chain items or animals, except for dairy animals within the 10-mile zone.
33.
That the State of Connecticut lies within the Shoreham 50-mile ingestion pathway EPZ.
34.
That participation by the State of Connecticut is required for the implementation of ingestion pathway protective actions in the portion of the Shoreham 50-mile EPZ which lies within the State of Connecticut.
35.
That FEMA has not reviewed any State of Connecticut plan for response to a Shoreham emergency. -
36.
That during the Exercise FEMA did not evaluate the resources or capability of the State of Connecticut to determine, issue, or implement ingestion pathway protective action recommendations in the event of a Shoreham emergency.
37.
That during the Exercise FEMA did not review or evaluate procedures, resources, or capabilities to perform radio-logical monitoring and decontamination of evacuees from special facilities (such as hospitals, nursing / adult homes, or handicapped facilities), who, under the LILCO Plan, are to be evacuated to special reception centers.
38.
That during the Exercise FEMA did not review or evaluate the availability, accessibility or adequacy of the congregate care center facilities identified by LILCO in the Plan as exercised (Revision 6), since the two facilities involved in the Exercise are not among those identified in LILCO's Plan.
39.
That during the Exercise FEMA did not review or evaluate procedures or activities required to implement recovery and
^
re-entry following a Shoreham emergency...
l 40.
That during the exercise, FEMA did not observe LILCO/LERO personnel contact or communicate with officials from any schools, hospitals, nursing / adult homes, or special facilities, except Central Suffolk Hospital and the Shoreham Wading River School District.
41.
That Marketing Evaluations, Inc. did not participate in the Exercise.
42.
That school bus drivers did not participate in the Exercise, except for some from the Shoreham Wading River School District.
43.
That no officials from nursing homes or adult homes located in the 10-mile Shoreham EPZ participated in the Exercise.
44.
That no officials from hospitals, nursing homes, or similar facilities outside the 10-mile EPZ participated in the Exercise.
45.
That during the Exercise FEMA observed or evaluated the performance of only one ambulance driver and only one ambulette driver. -.
46.
That during the Exercise the ambulance and ambulette drivers observed or evaluated by FEMA drove only one evacuation run each.
47.
That during the Exercise the one ambulance run observed by FEMA went to Our Lady of Perpetual Help Convent.
48.
That during the Exercise FEMA did not observe or evaluate the availability or adequacy of the VA Hospital in Northport to serve as a reception center for evacuees from the Our Lady of Perpetual Help Convent.
49.
That during the Exercise FEMA did not review or determine whether the officials responsible for the health and care of the residents of Our Lady of Perpetual Help Convent had agreed to or approved the proposal that such residents would be evacuated and relocated to the VA Hospital in Northport.
50.
That during the Exercise the one ambulette run observed by FEMA went to the United Cerebral Palsy Residence in Ridge.
51.
That during the Exercise FEMA did not observe or evaluate the availability or adequacy of the United Cerebral Palsy Residence in Stony Brook to serve as a reception center for evacuees from the United Cerebral Palsy Residence in Ridge..
52.
That during the Exercise FEMA did not review or determine whether the officials responsible for the health and care of the residents of the United Cerebral Palsy Residence in Ridge had agreed to or approved the proposal that such residents would be evacuated and relocated to the United Cerebral Palsy Residence in Stony Brook.
53.
That during the Exercise FEMA did not review or evaluate whether the evacuation of the residents of the United Cerebral Palsy Residence in Ridge was an appropriate protective action, given the accident in the Exercise scenario.
54.
That during the Exercise FEMA did not review or evaluate 1
whether the evacuation of the residents of Our Lady of Perpetual Health Convent was an appropriate protective action, given the accident in the Exercise scenario.
55.
That during the Exercise FEMA did not observe or evaluate Nassau County resources or capabilities.
1 56.
That during the Exercise FEMA did not observe or evaluate LILCO traffic guides performing any of the traffic guidance or control activities assigned to them in the LILCO Plan.
1 _
57.
That under the LILCO Plan 60 route alert drivers are expected to be available in the event of a Shoreham emergency.
58.
That during the Exercise FEMA observed or evaluated only three route alert drivers perform route alerting functions.
59.
That during the Exercise FEMA did not observe or evaluate LILCO's ability to notify the ambulatory deaf of an emergency at Shoreham.
60.
That, in evaluating LILCO's ability to effect an evacuation of the transit-dependent general population during the Exercise, FEMA observed only eight bus drivers retrieve buses from bus yards.
61.
That, in evaluating LILCO's ability to effect an evacuation of the transit-dependent general population during the Exercise, FEMA observed eight bus drivers each drive only one pre-designated evacuation route in the EPZ.
62.
That during the Exercise FEMA did not observe any school bus drivers from the Shoreham Wading River School District drive any evacuation routes..
63.
That during the Exercise FEMA observed a total of 27 Traffic Control Points.
64.
That during the Exercise FEMA observed or evaluated a total of 32 traffic guides at Traffic Control Points.
65.
That during the Exercise FEMA was unable to evaluate the timeliness of Traffic Control Point set-up with respect to any of the 10 Traffic Control Points within the jurisdiction of the Port Jefferson Staging Area.
66.
That only two impediments to evacuation were simulated during the Exercise.
67.
That FEMA was unable to observe LILCO's response to the fuel truck impediment during the Exercise, because of LILCO's delay in responding to the impediment.
68.
That at least two hours elapsed during the Exercise before LERO's Transportation Support Coordinator was informed that a bus evacuation rout'e was blocked by the gravel truck impediment..
69.
That during the Exercise there was a delay of at least 45 minutes between LILCO's attempt to verify the fuel truck impediment and the dispatch of a route spotter from the Port Jefferson Staging Area.
70.
That during the Exercise appropriate personnel and equipment were not dispatched by LILCO to remove the simulated gravel truck impediment.
71.
That during the Exercise FEMA observed that LERO personnel at the EOC failed to communicate essential and critical information made known to them via the two free play traffic impediment messages to the LERO personnel expected to respond to the impediments (e.o.,
that the gravel truck impediment involved a gravel truck and three cars, and, with respect to the fuel truck impediment, that the fuel truck was leaking and that both shoulders of the road were blocked).
72.
That during the Exercise FEMA did not review or observe or evaluate the existence, operability, or adequacy of the tone alert radios relied upon by LILCO in its Plan.
73.
That FEMA's evaluation of the Exercise, and its conclusions concerning the results of the Exercise, were based on an assumption, stated in Revision 6 of the LILCO Plan, that the,
Nassau Veterans Memorial Coliseum is available for use by LILCO as a reception center for the registration and radiological monitoring and decontamination of evacuees and vehicles.
74.
That during the Exercise FEMA observed that there were no procedures in existence for the notification of the Long Island Railroad in the event of a Shoreham emergency.
75.
That during the Exercise FEMA observed that procedures for the notification of the Federal Aviation Administration in the event of a Shoreham emergency were inadequate.
76.
That during the Exercise FEMA did not observe or review or evaluate the availability, location, accessibility or adequacy of reception centers for school children evacuated from schools in the EPZ, other than the Shoreham Wading River School District.
77.
That during the Exercise an " Unusual Event" was declared by LILCO at 5:40 a.m.
78.
That during the Exercise an " Alert" was declared by LILCO at 6:17 a.m.
79.
That during the Exercise a " Site Area Emergency" was declared by LILCO at 8:19 a.m.
80.
That during the Exercise a " General Emergency" was declared by LILCO at 9:39 a.m.
Sl.
That during the Exercise the decision to evacuate the entire 10-mile EPZ was made by LERO at 11:46 a.m.
82.
That during the Exercise the EBS message notifying the l
public of a Site Area Emergency and recommending that dairy animals be placed on stored feed was " issued" at 8:41 a.m.
83.
That during the Exercise the EBS message notifying the public to evacuate the entire 10-mile EPZ was " issued" by l
l LERO at 12:00 noon.
l 84.
That during the Exercise EES messages, the broadcast of which was simulated every 15 minutes between 12:06 and 3:48, recommended the evacuation of zones A-M, Q and R.
85.
That during the Exercise the Emergency Operations Facility
(" EOF") personnel projected that a wind shift would direct the plume away from zones A-M, Q and R as early as 3:00..
86.
That there was a 2.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> delay by LERO during the Exercise in correcting an error in reporting extrapolated dose data as actual measurements at other distances.
87.
That all evacuation recommendations made by LILCO personnel at the EOF during the Exercise were adopted by LERO personnel at the EOC.
88.
That there were several occasions during the Exercise when the Director of LERO, because he was not in the command room of the EOC, failed to receive telephone calls over the RECS telephone or the EOC's dedicated telephone.
89.
That in its evaluation of the Exercise or its results, FEMA did not review or evaluate or determine how many traffic accidents or obstructions would be likely to occur during an evacuation of the Shoreham EPZ.
90.
That at approximately 2:40 during the Exercise, LERO players were informed by exercise controllers that there were still approximately 18 percent of the population, or about 20,550 people, who had not yet evacuated from the EPZ.
91.
That, as of the time of the Exercise, school bus drivers had not been supplied with dosimetry equipment.
I.
92.
That, as of the time of the Exercise, school bus drivers had not been trained in potassium iodide policy or use.
93.
That, as of the time of the Exercise, school bus drivers had not been trained in the use of dosimetry or radiological exposure control.
94.
That, as of the time of the Exercise, not all ambulette drivers had been trained in who can authorize doses in excess of, and what to do in the event of, exposure beyond the general public PAGs.
95.
That, as of the time of the Exercise, school bus drivers had not been trained in who can authorize doses in excess of, and what to do in the event of, exposure beyond the general public PAGs.
96.
That during the Exercise rumor control personnel observed by FEMA were not able to answer questions purportedly received from the public because they had not been given accurate, up-to-date status reports.
97.
That during the Exercise the Emergency News Center
(" ENC")
was not declared operational by LERO personnel until 8:25 a.m. -
98.
That during the Exercise LERO held its first press briefing at 8:40.
- 99. 'That, although an EBS message recommending evacuation of the entire.EPZ was " aired" at 12:06 p.m. during the Exercise, at 1:19 p.m. a rumor control operator nevertheless advised a caller that evacuation had been recommended only for zones A-M, Q and R.
100.
That during the Exercise 90 minutes elapsed from the time that the LERO EOC informed the Port Jefferson Staging Area of a simulated siren failure until approximately half of the public alerting route for that siren's area had been driven by a LERO route alert driver.
101.
That during the Exercise the first bus drivers were dispatched from the Patchogue Staging Area at approximately 10:00 a.m.
102.
That during the Exercise the only activities necessary to implement an evacuation of non-institutionalized, mobility-impaired persons which were observed or evaluated by FEMA consisted of one bus driver driving a bus along one route, with no passengers picked up or discharged at any point. _ __,
- - ~ - _ _ _ - - -. -.
103.
That during the Exercise it took the Patchogue Staging Area 40 minutes to dispatch a bus driver after the request for a bus to evacuate children from the Ridge Elementary School had been received from the LERO EOC.
104.
That one bus driver dispatched from the Patchogue Staging Area and observed by FEMA during the Exercise took two hours 6
and ten minutes to proceed from the staging area to his assigned transfer point.
105.
That one bus driver dispatched from the Patchogue Staging Area and observed by FEMA during the Exercise proceeded to 5
the wrong transfer point.
106.
That one bus driver dispatched from the Patchogue Staging Area and observed by FEMA during the Exercise missed a segment of an assigned evacuation route.
107.
That during the Exercise 70 minutes elapsed from the time l
I that the LERO EOC informed the Patchogue Staging Area of a simulated siren failure until the simulated public alerting of that siren area was completed. _
108.
That traffic guides dispatched from the Riverhead Staging Area and observed by FEMA during the Exercise did'not arrive at their respective Traffic Control Point assignments until between 11:50 a.m. and 12:10 p.m.
109.
That during the Exercise 78 minutes elapsed between the time the LERO EOC informed the Riverhead Staging Area of a simulated siren failure and the time that simulated public alerting of that siren area was completed.
110.
That during the Exercise FEMA reviewed only rosters of names of persons identified by LILCO as second and third shift LERO personnel, in determining whether there was an ability to maintain staffing on a 24-hour basis.
111.
That during the Exercise FEMA did not observe persons identified as second or third shift personnel actually I
i report for duty.
l 112.
That during the Exercise FEMA did not speak to persons identified as second or third shift personnel. _ _ _ _ - - -
113.
That during the Exercise FEMA did not review or evaluate LILCO's ability to assure the necessary level of staffing of the number of school buses necessary to accomplish an evacuation or early dismissal of the school children in the EPZ.
114.
That during the Exercise FEMA did not observe LILCO employees at the ENC share information, prior to its release, with anyone other than other LILCO/LERO employees.
115.
That FEMA's observation and evaluation of the Shoreham T
Wading River School District's participation in the Exercise was limited to conducting interviews with the District Superintendent and the Principal of the Shoreham Wading River High School.
116.
That during the Exercise FEMA did not review, observe or evaluate the number of buses necessary to accomplish an early dismissal of school children from the Shoreham Wading River School District.
117.
That during the Exercise FEMA did not observe or evaluate whether the number of buses needed to accomplish an early dismissal of the children in the Shoreham Wading River School District would actually be available during a Shoreham emergency. ;
118.
That during the Exercise FEMA did not observe or evaluate whether the number of school personnel necessary to implement an early dismissal of the children in the Shoreham Wading River School District would actually be available during a Shoreham emergency.
119.
That during the Exercise FEMA did not observe or evaluate whether the number of school bus drivers necessary to accomplish an early dismissal of school children from the Shoreham Wading River School District would actually be available during a Shoreham emergency.
120.
That during the Exercise FEMA did not observe or evaluate the amount of time which would be necessary to accomplish an early dismissal of school children during a Shoreham emergency.
121.
That during the Exercise FEMA did not observe or evaluate whether the early dismissal of school children was an appropriate protective action for the school children in the Shoreham Wading River School District, given the accident in the Exercise scenario.,. _.
e 122.
That during the Exercise FEMA did not observe or evaluate the existence, availability, location or adequacy of a relocation center for school children evacuated from the Shoreham Wading River School District.
123.
That during the Exercise FEMA did not review or determine the number of buses which would be necessary to accomplish an evacuation of the school children in the Shoreham Wading River School District.
124.
That during the Exercise FEMA did not observe or evaluate whether the number of buses necessary to accomplish an evacuation of the school children in the Shoreham Wading River School District would actually be available during a Shoreham accident.
125.
That during the Exercise FEMA did not observe or evaluate whether the number of school bus drivers necessary to accomplish an evacuation of the school children in the Shoreham Wading River School District would actually be available during a Shoreham accident.._.
126.
That during the Exercise FEMA did not observe or evaluate whether the number of school personnel, including teachers, necessary to accomplish an evacuation of the school children in the Shoreham Wading River School District would actually be available during a Shoreham accident.
127.
That during the Exercise FEMA did not observe or evaluate the amount of time which would be necessary to accomplish an evacuation of the school children from the Shoreham Wading River School District.
128.
That during the Exercise FEMA did not evaluate whether the evacuation of school children was an appropriate protective action for the Ridge Elementary School, given the accident in the Exercise scenario.
129.
That during the Exercise FEMA did not review or evaluate the existence, availability, location, or adequacy of a relocation or reception center for children, evacuated during a Shoreham emergency, from the Ridge Elementary School.
130.
That during the Exercise FEMA did not review or determine whether officials from the Longwood School District, or from the Ridge Elementary School, had agreed to or approved the 1
IL
t proposal that a LILCO bus driver would transport Ridge Elementary school children to a location outside the EPZ in the event of a Shoreham accident.
131.
That during the Exercise FEMA did not review or determine whether officials from the Longwood School District, or from the Ridge Elementat*j School, had approved, or agreed to the use of, the Nassau Coliseum, or any other proposed relocation or reception center for school children evacuated from the Ridge Elementary School.
132.
That during the Exercise FEMA did not review or evaluate whether sufficient Ridge Elementary School personnel would be available during a Shoreham emergency to accompany and supervise school children evacuated from that school.
133.
That during the Exercise FEMA did not review or evaluate the availability of the number of buses necessary to accomplish an evacuation of all the school children in the Ridge Elementary School.
134.
That during the Exercise it took three hours for the bus purportedly " requested" by Ridge Elementary School to reach the school after it had been " requested" by injection of a free play message..
135.
That during the Exercise FEMA did not review, observe or evaluate the amount of time necessary for LILCO to accomplish an evacuation of those residents of all the special facilities in the EPZ who would require ambulance and ambulette transportation.
136.
That during the Exercise FEMA did not review, observe or evaluate the existence, availability, adequacy or location of relocation / reception centers equipped to accept evacuees from the special facilities in the EPZ following an accident at Shoreham.
137.
That during the Exercise FEMA did not review or evaluate or determine whether the officials responsible for the health and care of the residents of the special facilities in the Shoreham EPZ had agreed to or approved a proposal to evacuate and relocate evacuees from those facilities to any particular reception or relocation facilities outside the EPZ.
138.
That during the Exercise FEMA did not review, observe or evaluate the actual availability to LILCO during a Shoreham emergency of the number of ambulances and ambulettes necessary to accomplish an evacuation of the residents of all the special facilities in the EPZ.
139.
That during the Exercise FEMA did not review, observe or evaluate the actual availability during a Shoreham emergency of the number of drivers and medical technicians required to staff the number of ambulances and ambulettes necessary to accomplish an evacuation of the residents of all the special facilities in the EPZ.
140.
That during the Exercise FEMA did not review, observe or evaluate the actual availability during a Shoreham emergency of ambulances from volunteer fire companies or volunteer ambulance companies.
141.
That during the Exercise FEMA did not review, observe or evaluate the actual availability during a Shoreham emergency of drivers and medical technicians required to staff any ambulances provided by volunteer fire companies or volunteer ambulance companies.
142.
That during the Exercise FEMA did not evaluate whether an evacuation of the special facilities in the EPZ was an appropriate protective action, given the accident in the Exercise scenario.
143.
That during the Exercise FEMA did not review or evaluate the amount of time necessary for LILCO to effect an evacuation by bus of the transit-dependent general population. -
144.
That during the Exercise FEMA did not review, observe or evaluate the availability to LILCO, during a Shoreham emergency, of the number of buses which, according to the assumptions in the LILCO Plan, are necessary for LILCO to effect an evacuation of the transit-dependent general population.
145.
That during the Exercise FEMA did not review or evaluate the availability to LILCO of buses, for use in evacuating the l
l transit-dependent population, if an emergency occurred while 1
school is in session.
(
146.
That during the Exercise FEMA did not evaluate whether l
evacuation of the transit-dependent general population was the appropriate protective action, given the accident in the Exercise scenario.
147.
That during the Exercise LILCO players responded to the accident postulated in the scenario by " advising" approxi-mately 100,000 individuals to report to the Nassau Coliseum for radiological monitoring and possible decontamination.
148.
That during the Exercise FEMA did not review, observe or evaluate whether LILCO had sufficient staff, resources, facilities, or equipment to register 100,000 evacuees within a 12-hour period.. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
149.
That during the Exercise FEMA did not review, observe or evaluate whether LILCO had sufficient staff, resources, facilities, or equipment to perform radiological monitoring of 100,000 individuals and their vehicles within a 12-hour period.
150.
That during the Exercise FEMA did not review, obserte or evaluate whether LILCO had sufficient staff, resourc es,
facilities, or equipment to decontaminate 100,000 evacuees and their vehicles within a 12-hour period.
151.
That during the Exercise FEMA did not review, observe or evaluate whether LILCO had sufficient staff, resources, facilities, or equipment to handle properly the volume of contaminated waste that would be generated during a Shoreham accident by approximately 100,000 potentially-contaminated evacuees and vehicles.
152.
That the Institute for Nuclear Power Operations did not participate in the Exercise.
153.
That during the Exercise FEMA did review or evaluate the
" alternate evacuee monitoring plan" in OPIP 4.2.3, Section 5.11, of the LILCO Plan.
l,
154.
That during the Exercise FEMA did not review or evaluate tne capabilities or resources of INPO, other power plants, or any other entities to provide personnel or equipment for LILCO's use in monitoring evacuees from a Shoreham accident.
155.
That the only RAC members who participated in the RAC review of Revision 6 of the LILCO Plan were Roger Kowieski and Joseph Keller.
156.
That during the Exercise FEMA did not review the impact, upon LILCO's ability to mobilize LERO workers during the Exercise, of the fact that the date of the Exercise was known in advance by such workers.
157.
That during the Exercise FEMA did not review rosters of names in evaluating the ability of the American Red Cross to maintain staffing at the reception center or the congregate care centers on a 24-hour basis.
158.
That during the Exercise FEMA did not observe, or speak to, s
any American Red Cross personnel other than those who initially reported to exercise locations.
D 159.
That during the Exercise FEMA did not observe, review or evaluate LILCO's ability to identify, activate, or staff congregate care centers with the capacities and facilities that would be necessary if all residents of the EPZ were advised to evacuate, as occurred during the Exercise.
160.
That during the Exercise EBS message #3 was purportedly
" aired" to the public at 9:37 a.m.,
but it was not posted in written form at the ENC for viewing by the press until 10:45 a.m.
161.
That during the Exercise EBS message #4 was purportedly
" aired" to the public at 10:03 a.m.,
but it was not posted in written form for viewing by the press at the ENC until 10:45 a.m.
162.
That during the Exercise FEMA observed that insufficient copying capabilities at the ENC contributed to delays in the distribution of information to the media.
163.
That during the Exercise FEMA observed that maps and displays in the media briefing room of the ENC were insufficient.
164.
That during the Exercise FEMA observed that copies of EBS messages provided to the media contained information which had been marked for deletion, resulting in messages which were unclear, confusing and inconsistent with simulated radio broadcasts.
165.
That during the Exercise FEMA's free play message regarding the gravel truck impediment was injected at approximately 10:40 a.m.
166.
That during the Exercise FEMA's free play message regarding the fuel truck impediment was injected at approximately 11:00 a.m.
167.
That during the Exercise only one traffic guide out of the 14 interviewed by FEMA from the Patchogue Staging Area knew the location of the Nassau Coliseum reception center.
168.
That during the Exercise one of the traffic guides interviewed by FEMA indicated that he believed that the general public was to be directed to LILCO's Emergency Worker Decontamination Facility ("EWDF").
169.
That during the Exercise some traffic guides indicated to FEMA evaluators that they might question the authorization of other LERO personnel (specifically, the lead traffic guides) regarding excess exposure.
170.
That during the Exercise FEMA observed that the message concerning the " visual check" of the fuel truck impediment from the bus dispatcher at the Patchogue Staging Area to the LERO Transportation Support Coordinator at the EOC was partially illegible and was not written on a standard LERO message form.
171.
That during the Exercise the free play message requesting that a bus be sent to the Ridge Elementary School was given to the LERO Evacuation Coordinator at the EOC at approxi-mately 10:30 a.m.
172.
That during the Exercise FEMA observed that personnel at the Riverhead Staging Area did not properly record or appropriately identify event status information on Emergency Event Status Forms or on status boards.
173.
That during the Exercise FEMA observed that communication between the Port Jefferson Staging Area and traffic guides was difficult due to poor radio reception, and disrupted other communications from the staging area.
1 174.
That FEMA observed, during the Exercise, that the bus dispatcher at the Patchogue Staging Area made repeated inaccurate and misleading announcements to bus drivers concerning the dose levels at which they were to call in.
175.
That FEMA observed during the Exercise that the Transfer Point Coordinator at the Brookhaven National Laboratory Transfer Point, prior to 4:00 p.m., directed a bus driver to the EWD'F, despite the fact that a message from the bus dis-patcher to all transfer point coordinators had directed that all drivers arriving at transfer points before 4:00 p.m.
were to be directed to the Nassau Coliseum.
176.
That, in its evaluation of the Exercise, and in its conclu-sions concerning the results of the Exercise, FEMA assumed that only those persons advised to evacuate by the LERO players would seek to evacuate or would seek evacuation assistance or services from LILCO.
177.
That during the Exercise FEMA did not review or evaluate LILCO's capability to effect an evacuation of the 10-mile EPZ under circumstances when substantially more persons than the number estimated by LILCO to be the population of the 10-mile EPZ attempt to evacuate from areas outside and inside the EPZ.,
,__--m
,,m.
1 178.
That in evaluating the Exercise and in its conclusions concerning the results of the Exercise, FEMA assumed that members of the public would not begin to evacuate prior to 10:24 a.m.
179.
That during the Exercise FEMA did not review or evaluate LILCO's capability to effect an evacuation of the 10-mile EPZ under circumstances when persons inside or outside the EPZ begin to evacuate and seek evacuation services and assistance prior to the issuance of a formal evacuation advisory.
180.
That it took LERO personnel 4 to 5 minutes to perform radiological monitoring on some evacuees at the Nassau Coliseum reception center during the Exercise.
181.
That, with the exception of the Shoreham Wading River School District, officials of the other EPZ school districts have stated that they do not have the resources and that they are not capable of safely or effectively implementing an early dismissal or evacuation of their students during a Shoreham accident.
182.
That during the Exercise LERO traffic guides observed and evaluated by FEMA were not aware of the chain of command for authorization of exposures in excess of the general public PAGs.
183.
That during the Exercise LERO traffic guides observed and evaluated by FEMA were not aware that exposure in excess of the general public PAGs would be a voluntary act on their part.
184.
That during the Exercise LERO personnel were unable to locate, communicate with, or timely dispatch a route spotter to investigate and verify the fuel truck impediment.
185.
That during the Exercise LERO personnel were unable to verify whether a route spotter had been dispatched to the scene of the fuel truck traffic impediment.
186.
That during the Exercise LERO failed to notify or com-municate emergency information to the Federal Aviation Administration.
187.
That during the Exercise LERO failed to notify or com-municate emergency information to the Long Island Railroad.
188.
That during the Exercise LERO personnel failed to designate clearly on the EOC dose assessment status boards the distinction between DOE RAP monitoring data and LILCO field monitoring data.
189.
That during the Exercise downwind distances of sample readings by field monitors were incorrectly reported as 7000 meters instead of 700 meters for a thyroid dose.
III. SUPPLEMENT TO REQUEST FOR ADMISSIONS As to each request for admission numbered 1 through 189 above, or portion thereof, to which the answer is anything other than an unqualified affirmative admission, FEMA is requested, pursuant to 10 CFR 2.740b, to state the following, within fourteen (14) days after service hereof, using the same instructions for answering interrogatories as are set forth on pages 1 through 9 of "Suffolk County's First Set of Interrogatories to the NRC Staff and FEMA" dated October 15, 198'6:
1.
State the exact portion of each request which is not admitted; l
i O
2.
With respect to each such unadmitted portion of each request for admission referred to in the answer to Interrogatory No.
1 above state:
(a) the reason it is not admitted; and (b) the name of any Federal personnel who have information relating to, or knowledge of, the portion not admitted.
Respectfully submitted, Martin Bradley Ashare Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 Karla J.
Let' sche Michael S. Miller Susan M. Casey Kirkpatrick & Lockhart 1900 M Street, N.W.
Washington, D.C.
20036 Attorneys for Suffolk County
/
lAVN Fabian G.
Palomino
/
Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Attorney for Mario M.
- Cuomo, Governor of the State of New York i
I Steptfen B.
Latham
//
Twomey, Latham & Shea P.O.
Box 398 33 West Second Street Riverhead, New York 11901 Attorney for the Town of Southampton Dated:
November 4, 1986 a
$l F
00thE1E0 November 4, 19861RC
'86 M)V 10 P4 :23 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICt < ::
? bb Before the Atomic Safety and Licensing Board 00CXETib'.i s "M BRANCU
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON'S FIRST REQUEST FOR ADMISSIONS AND SECOND SET OF INTERROGATORIES DIRECTED TO FEMA have been served on the following'this 4th day of November, 1986 by U.S. mail, first class, except as otherwise noted.
John H. Frye, III, Chairman Dr. Oscar H.
Paris
. Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Frederick J.
Shon Spence W.
Perry, Esq.
Atomic Safety and Licensing Board William R. Cumming, Esq.*
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C.
20555 Federal Emergency Management Agency 500 C Street, S.W., Room 840 Washington, D.C.
20472
16\\-
h Anthony F.
- Earley, Jr.,
Esq.
Bernard M. Bordenick, Esq.
General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C.
20555 175 East Old Country Road Hicksville, New York 11801 Mr. William Rogers W.
Taylor Reveley, III, Esq.
Clerk Hunton & Williams Suffolk County Legislature P.O.
Box 1535 Suffolk County Legislature 707 East Main Street Office Building Richmond, Virginia 23212 Veterans Memorial Highway Hauppauge, New York 11788 Mr.
L.
F.
Britt Stephen B.
Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
195 East Main Street 1717 H Street, N.W.
Smithtown, New York 11787 Washington, D.C.
20555 MHB Technical Associates Hon. Peter Cohalan 1723 Hamilton Avenue Suffolk County Executive Suite K H. Lee Dennison Building San Jose, California 95125 Veterans Memorial Highway Hauppauge, New York 11788 Martin Bradley Ashare, Esq.
Fabian G.
Palomino, Esq.
Suffolk County Attorney Special Counsel to the Governor Bldg. 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway State Capitol Hauppauge, New York 11788 Albany, New York 12224 David A.
Brownlee, Esq.
Mr. Philip McIntire Kirkpatrick & Lockhart Federal Emergency Management Agency 1500 Oliver Building 26 Federal Plaza Pittsburgh, Pennsylvania 15222 New York, New York 10278 bl
/
L By Hand Karlp J. Letschu' KIRKPATRICK & LOCKHART 1900 M Street, N.W.
Suite 800 Date:
November 4, 1986 Washington, D.C.
20036