ML20235N171

Response of FEMA to Seacoast Anti-Pollution League Request for Admissions to FEMA Re Graded Exercise Issues.* Related Correspondence

ML20235N171
Person / Time
Site:	Seabrook
Issue date:	02/14/1989
From:	Flynn H Federal Emergency Management Agency
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20235N172	List: ML20235N171 ML20235N182
References
CON-#189-8082 OL, NUDOCS 8903010078
Download: ML20235N171 (12)

Text

. ,. ______ -_________

H .s -

a .n h l

DOCKEifD UWlEC 4

'89 FEB 23 P6 :28 February 14, 1989 l

OFci  !

DUCK y -

l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC AND SAFETY AND LICENSING BOARD JUDGE IVAN W. SMITH, CHAIRMAN JUDGE RICH 1GD F. COLE JUDGE JERRY R. KLINE

)

In the Matter of )

)

Public Service Co. of New Hampshire, ) Docket No. 50-443-OL

) 50-444-OL

) Offsite Emergency Seabrook Station, Units 1 & 2) ) Planning Issues

)

RESPONSE OF THE FEDERAL EMERGENCY MANAGEMENT AGENCY (FEMA)

TO SEACOAST ANTI-POLLUTION LEAGUE'S REQUEST FOR ADMISSIONS TO FEMA REGARDING GRADED EXERCISE ISSUES The Federal Emergency Management Agency (FEMA), pursuant to

-Title 10, Code of Federal Regulations, Section 2.742, responds as follows to the Seacoast Anti-Pollution League's Request for Admissions to the Federal Emergency Management Agency Regarding Graded Exercise Issues:

Reauest No. 1: I 1

)

Twenty buses were dispatched to state staging areas during the graded exercise of the emergency response plan for Seabrook i Station on Day 1 of the scenario when evacuation was ordered.

Response to Reauest No. 1:

Denied.

Buses were not dispatched to staging areas when evacuation hD DO 5 0 43 O PDR ,gp u__ _ ._-

I:  ;-

1 k= .

V ,

1

.j

.was ordered. The Exercise Report, p. 165, states that the l I

process to mobilize and deploy bus resources was started between "

{

f 0955 and 1132. At 1206, buses were directed to deploy to State Staging Areas. Alert was declared at 0909. Site Area Emergency was declared at 1146. Gen'eral Emergency was declared at 1332.

New Hampsh' ire decided (Protective' Action) to evacuate 0-5 miles

'I at 1409. Twenty buses were deployed on Day 1.

l Reauest No. 2:

. Twenty-one drivers were. utilized for driving buses during Day 1 of the exercise scenario.

Response to Recuest No. 2:

1 Denied.

Twenty drivers drove twenty buses on Day 1. One driver drove a van (wheel chair van) on Day 1.

Reauest No. 3:

One ambulance and two ambulance personnel performed during the exercise.

Response to Reauest No. 3:

Denied.

One ambulance and two ambulance personnel performed medical transport of a simulated ill or injured patient contaminated with radioactive material (Objective #23). In a separate part of the exercise, one ambulance and two ambulance personnel demonstrated FEMA's Responses to SAPL's Request for Admissions, page 2.

l

l s' L i

Y R

i

. mobilization and. deployment to'the State staging area (Objective

1. 18, p. 165).

Reauest No. 4:

i There were two enviro'nmental sampling teams dispatched by j the Statelof New Hampshire during the course of the graded i exercise.

Response to Reauest No. 4:

Admitted.

Recuest No. 5:

Under the.NHRERP, no more than six two-person monitoring

' teams are planned to be dispatched to collect environmental samples.

Response'to Reauest No. 5:

Denied.

The NHRERP makes a distinction between plume monitoring (Objectives #7, #8, and #9) and environmental monitoring (Objective #27). The NHRERP States that the State is prepared to mobilize, deploy, and maintain on a twenty-four hour basis three two-person environmental sampling teams. The NHRERP will augment

'its environmental monitoring teams by requests to the Federal government and through the New England Interstate Radiological l Assistance Plan, if appropriate.

l Reauest No. 6: ,,  ;

one of the two teams dispatched during the exercise, Team

1. 1, was not familiar with procedures for sample collection or with survey techniques with the assigned instruments.

FEMA's Responses to SAPL's Request for Admissions, page 3.

L 1

E.esponse to Recuest No. 6:

Denied.

The Exercise Report (Objective #27, p. 193) states that New Hampshire Team #1 was not familiar with equipment necessary to transfer water between container (s). Both teams demonstrated good health physics practices in sample collection. The Exercise Report (Objective #27, p. 193) states that Team #1 had set monitoring instrument on the wrong scale. Team #1 did demonstrate adequate survey techniques.

Reauest No. 7:

Team #1 collected its sample at the wrong location.

Response to Reauest No. 7:

Admitted.

Reauest No. 8:

No TCP's were staffed in the Town of Hampton during the exercise.

Response to Recuest No. 8:

Denied.

State Police demonstrated ability to establish a TCP in Hampton (HA-01).

FEMA's Responses to SAPL's Request for Admissions, page 4.

t______---__ _

l Reauest No. 9:

The simulated establishment of TCP's/ACP's was not accomplished in the sequence or time that is called for by the NHRERP had the simulated exercise accident been a real radiological emergency.

Response to Reauest No. 9:

Denied.

The Exercise Report (Objective #20, pp. 182-83) states that State Police Liaison (IFO/ EOF) took action to ensure adequate police officers were available to handle TCP/ACP's. For example:

At 1037, action to deploy officers for beach closing to be announced at 1100. ACP/TCP's staffed by 1130.

At 1335, action to support evacuation 0-5 miles.

Protective Action decision to evacuate from 0-5 miles was made at 1409.

At 1530, ACP's and TCP's were staffed to support 1409 Protective Action decision that was announced by EBS at 1420.

Rgguest No. 10:

Four TCP/ACP locations were staffed by N.H. State Police during the exercise.

Response to Reauest No. 10:

Admitted.

Reauest No. 11:

One ACP/TCP was staffed in 13 of the N.H. local communities.

Rosponse to Reauest No. 11:

FEMA's Responses to SAPL's Request for Admissions, page 5.

7 ,

Denied.

ACP's and TCP's were staffed in fifteen communities: NH-02, EA-01, BR-02, EK-01, EX-01, GR-01, KI-02, NC-01, NF-01, NT-02, PO-01, SE-04, ST-01, NW-03, and EP-01.

Reauest No. 12:

No TCP's/ACP's were staffed in a total of four of the N.H.

local communities.

Resoonse to Reauest No. 12:

FEMA can neither admit nor deny this statement.

It is true that no TCP's/ACP's ware established in host communities. On the other hand, they were established in 15 of 17 local (risk) communities.

Recuest No. 13:

The Hillside Junior High School, which is designated in the plan as the facility for emergency worker monitoring and decontamination, was not staffed or tested for its proposed use during the course of the exercise.

Response to Reauest No. 13:

FEMA admits that the Hillside Junior High School facility was not staffed or tested during the exercise, but in further explanation notes that the Exercise Report (Objective #25, p.

191) states that the emergency worker monitoring process was demonstrated at Reception Centers. Emergency Worker Facility (EWF) status of preparedness (equipment, procedures, supplies) was inspected on July 22, 1988. Thus, the process was tested at FEMA's Responses to SAPL's Request for Admissions, page 6.

y .-

[i le ,

il: x.

s g*

Reception Centers and the EWF was inspected (Objective #21, pp l

' l 183 - 185). l Recuest No. 14:

The host EOC's in Salem, Dover and Rochester did not demonstrate shift changes during the exercise.  !

Response to Reauest No. 14:

Admitted.

J

,s FEMA states in further response ~that the Extent of Play Agreement did not require Host Communities to perform a shift' change. The objective Matrix on page 22 of the Exercise Report, reflecting the extent of play, is in error regarding Objective

1. 34'and Host EOCs.

Recuest No. 3.1:

Neither of the two state staging areas attempted 1 shift

. changes during the exercise.

Response to Reauest No. 15:

Admitted.

FEMA states in further explanation that the Plan of Record (6/88) for the exercise did not require twenty-four hour operation of Staging Area (s). See "Other Issues," p. 200 of the Exercise Report. The Exercise Report (Objective #34, p. 198) states that Staging Area staff discussed process and available i staff (via rosters) for twenty-four hour staffing, if required.

See Report entitled " Status of Corrective Actions for the 1988 FEMA's Responses to SAPL's Request for Admissions, page 7.

I i

FEMA Graded Exercise for Seabrook Station" dated December 1988, Section 2, State of New Hampshire, page 11, Other Issues. The Objective Matrix on page 22 of the Exercise Report, reflecting the extent of play, is in error regarding Objective #34 and Staging Areas.

Reauest No. 16:

None of the local EOC's demonstrated shift changes during the exercise.

Response to Reauest No. 16:

Denied.

The Extent of Play Agreement stated that eleven of seventeen local EOC's would demonstrate the capability to provide twenty-four hour coverage. Key positions were to be subject to shift changes. The Exercise Report (Objective #34, p. 199),

states that some local EOC's (2) demonstrated full shift changes and that some local EOC's (7) demonstrated partial shift changes.

Only two local EOC's failed to demonstrate shift changes for key positions. FEMA notes that the IFO demonstrated a full shift change and the IFO had the capabilities to demonstrate and did demonstrate compensatory measures for those local EOC's who could not perform their functions.

Reauest No. 17:

No New Hampshire National Guard personnel simulated a second shift capability at the reception centers during the exercise.

FEMA's Responses to SAPL's Request for Admissions, page 8.

7_ . _

if . .

Response to Reauest No. 17:

FEMA can neither admit nor deny this request.

The NHRERP states that National Guard personnel are available to staff Reception Centers. New Hampshire provided

~

staffing charts and some actual staff for shift change.at Reception Centers (Exercise Report, Objective #34, p. 198). It is possible that the New Hampshire National Guard personnel could have been listed on staffing charts.

Reauest No. 18:

The Sheriff's Deputies staffing local transportation staging areas did not demonstrate the capability to staff a second shift during the exercise.

Response to Reauest No. 18:

Admitted.

In further explanation, FEMA states that the Extent of Play and Objective Matrix, Objective #34, p. 22, did not require a shift change for local staging areas.

Reauest No. 19:

Three local liaison officers were not replaced on the second shift at the IFO.

Response to Reauest No. 19:

Admitted.

The Exercise Report, p. 199, states that the NHRERP specifies.that 9 local liaison officers are required if all 17 FEMA's Responses to SAPL's Request for Admissions, page 9.

local communities do not participate. Eleven local communities did participate. The shift change demonstration was adequate.

i Reauest No. 20:

The graded exercise did not involve the actual dispatch of i any emergency vehicles to any hospitals within the zone for evacuation of residents.

Resnonse to Reauest No. 20:  !

Denied.

The Extent of Play agreement did not require the dispatch of emergency vehicles to hospitals. Exercise Report Objective #18 states that routes were run from staging areas to the two risk hospitals (Exeter - route 92, and Portsmouth - route 84) and routes were run from the two risk hospitals to the seven host hospitals: Portsmouth Hospital (routes 83, 85, 86, and 87) and Exeter Hospital (routes 93, 94 and 95).

Eeauest No. 21:

The graded exercise did not involve the actual dispatch of any emergency vehicles to any nursing homes within the zone for evacuation of residents.

R?soonse to Reauest No. 21:

Denied.

Two emergency vehicles were dispatched to two nursing homes (evacuation bed buses), and from these risk nursing homes to host nursing homes. Five vehicles (cars) were dispatched to six risk nursing homes and from there to five host nursing homes.

I FEMA's Responses to SAPL's Request for Admissions, page 10.

I l

l 1

- _ - _ _ - - . -__ i

7 ,. ;g.

F, l.

.q .

Reauest No. 22:-

The gradedEexercise did not involve.the testing ofIthe L

capability of any host'special facilities to receive any nursing

'home patients-from the EPZ.

Resoonse to-Recuest N'.

o 22:

i' Admitted.

FEMA's exercise' objectives do not call.for the testing of.

host special facilities. l Reauest No. 23_:

.ERPA G was not ordered evacuated during the exercise.

Response to Recuest No. 23:

i Admitted.

FEMA :found that New . Hampshire Protective Action of sheltering ERPA G to be an. appropriate PA. See Exercise Report, 1 0bjective #11, p. 157.

)

Request No. 14:

The. scenario involved a wind shift that carried'the radiation plume over the communities in ERPA G. ,

i I

FEMA's Responses to SAPL's Request for Admissions, page 11.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ . - - - _ - - . _ . l

~

GD m ..

En l

,.1 l[ e L

l'

• 3; ,

~

. Response to Recuest No. 24:

-Admitted.

, Respectfully' submitted, u

ff. JOSEPH FLYNff - .

Assist" Int GenMal Counsel Federal-Emergency Management Agency 500 C Street, S.W.-

Washington, D.C. 20472

-(202) 646-4102

)

FEMA's Responses to SAPL's Request for Admissions, page 12.

- _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _