ML20215M446
| ML20215M446 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/27/1986 |
| From: | Wilkerson R Federal Emergency Management Agency |
| To: | |
| Shared Package | |
| ML20215M440 | List: |
| References | |
| OL-5, NUDOCS 8610300252 | |
| Download: ML20215M446 (6) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In the Matter of
)
).
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station, Unit 1)
)
)
AFFIDAVIT OF ROBERT S. WILKERSON 1.
My name is Robert S. Wilkerson.
I currently serve as the Chief of the Technological Hazards Division. State and Local Programs & Support Directorate, of the Federal Emergency Management Agency.
2.
I have personally reviewed the October 3, 1986, PREHEARING CONFERENCE ORDER (Ruling on Contentions and Establishing Discovery Schedule) and believe that it would fundamentally change the ongoing exercise planning and exercise process for off site safety considerations at commercial nuclear power generating sites throughout the country.
This process, since 1979, has been throughly integrated into both the initial and continuing Itcense process for such plants.
3.
Contentions on exercise design, scenario development, scope, and conduct to the extent that they deviate from the exercise results on the day of the 8610300252 861027 PDR ADOCK 05000322 C
_2-exercise are not relevant to the protection of health and safety around the plant. Only the designed event, the exercise and its results, provide insight into the adequacy of the emergency preparedness plan and process.
Deviations from scenario design or exercise conduct, even if demonstrated, do not in and of themselves render exercise results meaningless.
In most exercises, free play and unplanned interaction among players provides a critical realism to the simulation of what is at best an unpredictable environment.
It is the application and modification of procedures in a "real" environment that the evaluation process hopes to capture.
I I
4.
FEMA does not use the term " Fundamental Flaw" in its regulations or guidance concerning off site emergency preparedness.
FEMA does use the terms
" Deficiency" and " Area Requiring Corrective Actions" for exercises and uses the term " Inadequacy" for plans.
The Nuclear Regulatory Commission is fully aware and has concurred in the methodology and terminology used in our evaluation and review process.
They have in fact accepted the process in both initial licensing actions and even more numerous actions for operating plants since the involvement of FEMA.
The purpose of the exercise program is to test features of the plan that FEMA, in its discretion, and with NRC staff concurrence, determines are the most relevant to evaluation of the emergency preparedness process.
This does not mean that every element of every plan must be tested in every exercise.
Rather, over a continuous cycle, beginning with the qualifiylng exercise, various exercise objectives are reflected in scenarios that realistically tax policy implementation and personnel carrying it out in an emergency.
Inherent in the exercise cycle is the FEMA goal of evaluating reasonable assurance.
Reasonable assurance is the totality of trained individuals, systems and policy that can interact as opposed to statistical i
. assurance that particular components are available.
This process evaluation stresses flexible emergency response because of the inherent unpredictability of emergencies.
5.
The October 3, 1986 Order reflects substantive misunderstanding of the exercise evaluation process and falls to reflect the past acceptance by the Nuclear Regulatory Commission of the current framework.
This exercise litigation is for the sole purpose of documenting the exercise involving a simulated possible emergency at Shoreham and responses to it.
FEMA did not issue a finding concerning the exercise but did issue an exercise assessment that relects the official FEMA action on the exercise.
6.
I hereby declare under penalty of perjury that the foregoing is true and correct.
h Robert 5. Pit ikerson
~
f District of Columbia City of Washington Subscribed and sworn to before me this 27th day of October, 1986.
NOTARY PUBLIC
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My Commission expires J!/M
,196/
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/
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DGLKEILP USNHC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
,85 0CT 29 P4 36 In the Matter of
)
0FFICE.s e-
)
00CKE; E > Sia vci LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-00ESNC"
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of " FEDERAL EMERGENCY MANAGEMENT AGENCY'S MOTION TO RECONSIDER ATOMIC SAFETY AND LICENSING BOARD PREHEARING CONFERENCE ORDER DATED OCTOBER 3,1986, AND MEMORANDUM AND SUPPORTING AFFIDAVIT IN SUPPORT OF THAT MOTION" in the above-captioned proceeding have been served on the following by deposit in the United States mall, first class, or as indicated by a double asterisk by messenger, this 27th day of October, 1986:
John H. Frye, III, Chairman **
Fabian G. Palomino, Esq.
Administrative Judge Special Counsel to the Governor Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, D.C.
20555 Albany, NY 12224 Oscar H. Paris **
W. Taylor Reveley III, Esq.
Administrative Judge Hunton & Williams Atomic Safety and Licensing Board 707 East Main Street U.S. Nuclear Regulatory Commission P.O. Box 1535 Washington, D.C.
20555 Richmond, VA 23212 Frederick J. Shon**
Jonathan D. Feinberg, Esq.
. Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Empire State Plazt Washington, D.C.
20555 Albany, NY 12223
, Stephen B. Latham, Esq.
John F. Shea, III, Esq.
Herbert H.. Brown, Esq.**
Twomey, Latham & Shea Lawrence Coe Lanpher, Esq.
Attorneys at Law Karla J. Letsche, Esq.
P.O. Box 398 Kirkpatrick & Lockhart 33 West Second Street 1900 M Street, N.W.
Riverhead, NY 11901 8th Floor Washington, D.C.
20036 Atomic Safety and Licensing Board Panel Joel Blun, Esq.
U.S. Nuclear Regulatory Commission Director, Utility Intervention Washington, D.C.
20555 NY State Consumer Protection Board Suite 1020 Atomic Safety and Licensing 99 Washington Avenue Appeal Board Panel Albany, NY 12210 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Monroe Schneider North Shore Committee P.O. Box 231 Docketing and Service Section Wading River, NY 11792 Office of the Secretary U.S. Nuclear Regulatory Commission Philip H. McIntire Washington, D.C.
20555 Federal Emergency Management Agency 26 Federal Plaza Spence Perry, Esq.**
New York, New York 10278 General Counsel, Rm. 840 Federal Emergency Management Agency 500 C Street, S.W.
Washington, D.C.
20472 Robert Abrams, Esq.
Attorney General of the State Gerald C. Crotty, Esq.
of New York Ben Wiles, Esq.
Attn:
Peter Blenstock, Esq.
Counsel to the Governor Department of Law Executive Chamber State of New York State Capitol Two World Trade Center Albany, NY 12224 Rcom 46-14 i
New York, NY 10047 l
Anthony F. Earley, Jr., Esq.
, MHB Technical Associates l
General Counsel 1723 Hamilton Avenue i
(
.Long Island Lighting Company Suite K 250 Old County Road San Jose, CA 95125 Mineola, NY 11501 Hon. Peter Cohalan Martin Bradley Ashare, Esq.
Suffolk County Executive Suffolk County Attorney County Executive / Legislative Bldg.
H. Lee Dennison Building Veteran's Memorial Highway Veteran's Memorial Highway Hauppauge, NY 11788 Hauppauge, NY 11788 l
J
o Mr. Jay Dunkleberger Ms. Nora Bredes New York State Energy Office Shoreham Opponents Coalition Agency Building 2 195 East Main Street Empire State Plaza Smithtown, NY 11787 Albanj, New York 12223 Chris Nolln Mr. Robert Hoffmnan New York State Assembly Ms. Susan Rosenfeld Energy Committee Ms. Sharlene Sherwin 626 Legislative Office Building P.O. Box 1355 Albany, NY 12248 Massapequa, NY 11758 Brookhaven Town Attorney Bernard M. Bordenick, Esq.
475 E. Main Street Maryland National Bank Building Patchogue, NY 11772 Rm. 9604 Washington, DC 20555
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Y, William R. Cumming Federal Emergency Management Age y i
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