ML20235V384
| ML20235V384 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/01/1989 |
| From: | Cumming W, Husar I, Keller J Federal Emergency Management Agency, IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | |
| References | |
| CON-#189-8221 OL-5, NUDOCS 8903100163 | |
| Download: ML20235V384 (87) | |
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m-UNITED STATES OF AMERICA jo . NUCLEAR REGULATORY COMMISSION
'd Before the Atomic Safety and Licensina Board In the Matter of )
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5R
)
(Shoreham Nuclear Power )
Station, Unit 1) )
DIRECT TESTIMONY OF IHOR W. HUSAR-AND JOSEPH H. KELLER CONCERNING THE JUNE 1988 EMERGENCY PREPAREDNESS EXERCISE O
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8903100163 890301 2 PDR ADOCK 0500
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March 1, 1989
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UNITED STATES OF AMERICA
<j NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board In the Matter of )
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-3~22-OL-5R
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(Shoreham Nuclear Power )
i Station, Unit: 1) )
DIRECT TESTIMONY OF IHOR W. HUSAR AND JOSEFH H. KELLER O CONCERNING THE JUNE 1988 EMERGENCY PREPAREDNESS EXERCISE l
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(Wj UNITED STATES OF AMERICA
' NUCLEAR REGULATORY COMMISSION O
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- . In the Matter of. )
)
'LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-5R N ) (EP Exercise)
(Shoreham Nuclear Power Station, )
Unit 1) )
FEMA PREFILED TESTIMONY FEMA Counsel hereby serves on all parties and service list addresses FEMA's prefilled testimony on all contentions in the above captioned proceeding.
Respectfully submitted, ,
^
JA x.
William R. Cumming .
I Counsel for FEMA Entered at Washington, D.C.
this ist day of March, 1989 l
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I TABLE OF CONTENTS
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vl Preamble.................................................... 2 Contention 1.A.............................................. 10 Contention 1.B.............................................. 15 .
I Contention 1.D.............................................. 16 Contention 1.E.............................................. 17 3
Contention 1.F, 1.G, and 1.P................................ 20 y Contention 1.H.............................................. 22 Contention 1.Q.............................................. 23 Contention 6................................................ 27 Contentivn 6.A.1 and 6.D.8.................................. 34 Contention 6.A.4 and 11.A................................... 36 Contention 6.A.5 and 6.B.8.................................. 37
/~N Contention 11.B and 11.D.................................... 39
(%) (Consolidated with 6.A.4 and 6.A.5)
Contention 6.A.6............................................ 40 Contention 6.B.1............................................ 42 Contention 6.B.2 and 12.D................................... 43 Contention 6.B.3 and 12.C................................... 45 Contention 6.B.4 and 11.E................................... 46 Contention 6.B.5 and 6.B.6.................................. 47 Contention 6.B.7. and 6.B.10................................ 49 (Consolidated with Contention 12.E) .
Contention 6.B.9............................................ 51 Contention 6.C.1 and 6.C.2.................................. 52 Contention 6.D.2............................................ 54 Contention 6.D.7............................................ 55
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i Contention 6.D.12........................................... 56 l Contention 6.D.13........................................... 57 ,
1 Contention 7................................................ 58 Contention 7.E.1,.7.E.3 and 7.E.5........................... '59 Contention 7.E.2............................................ 60 Contention'7.E.4............................................ 61
< Contention-7.F.............................................. 62 s
Contention 18............................................... 63 l g-Contention 20............................................... 64 l Contention 20.A............................................. 65 '
(Includes 19.D, 4.A, 4.B, 4.C.1, 4.C.2, 4.C.3, 4.C.6, 4.C.8, 4.C.9, 4.D, and 4.G)
Contention 20.C............................................. 70 Contention 20.D and 20.F.................................... 72 ;
Contention 20.G............................................. 74 r
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Preamble The Federal Emergency Management Agency (FEMA) and the Nuclear Regulatory Commission (NRC) entered into a Memorandum of Understanding (MOU) on April 17, 1985, which defines NRC's and FEMA's responsibilities with respect to emergency
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preparedness. Included in that MOU is an agreement whereby v
FEMA would evaluate exercises of offsite emergency response plans. Requests for findings are usually made by the NRC to FEMA to assist the NRC staff in the licensing process.
By the terms of the MOU, FEMA is also responsible for l ,
providing " expert witnesses" on its analysis of plans and i'
evaluation of exercises before the Atomic Safety and Licensing Boards (ASLB) .
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l On February 8,1988, NRC requested FEMA, pursuant to the terms of the MOU, to evaluate an exercise of Revision 9 (subsequently updated to Revision 10) of Long Island Lighting Company's (LILCO) Local Offsite Radiological Emergency Response Plan for the Shoreham Nuclear Power Station (SNPS).
On May 20, 1988, and May 26, 1988, NRC staff agreed that the proposed objectives submitted by LILCO to FEMA, reviewed by the Regional Assistance Committee (RAC) and submitted by FEMA to NRC on May 13, 1988, were sufficient: (1) to demonstrate 2
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l Organization (LERO) in a full-participation exercise and (2) to constitute a " qualifying" exercise under 10 CFR 50, Appendix E, Section IV.F.1 in that it should test as much of the emergency plans as is reasonably achievable without mandatory public participation. ,
5 On May 23, 1988, NRC requested that FEMA conduct a review of s
Revision 10 of the LILCO offsite plan using the criteria established in NUREG-0654/ FEMA-REP-1, Rev. 1, Supplement 1, published for interim use and comment in November 1987 and finalized on September 23, 1988. Fundamental to that document are the three NRC assumptions mentioned below.
The assumptions upon which the plan review and the exercise were based are that in an actual radiological emergency, State and local officials that have declined to participate in emergency planning will:
- 1) Exercise their best efforts to protect the health and safety of the public;
- 2) Cooperate with the utility and follow the utility plan; .
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. 3 ) Have the resources sufficient to implement those portions of the utility offsite plan where State and local response is necessary.
NRC also requested on May 23, 1988, that Revision 10 changes ;
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to the plan be incorpor2ted into the exercise. Since a full RAC review of these changes could not be conducted in the short time frame remaining before the exercise, FEMA Region II agreed to review the changes, coordinate with the RAC where necessary, and incorporate them into the evaluation of the exe.rcise.
5 The Shoreham exercise covering plume pathway, ingestion a
pathway and recovery / reentry phases was conducted on June 7-9, 1988. The Post Exercise Assessment (PEA) dated September 2, 1988, was transmitted to NRC cn September 9, 1988. A copy of the PEA is being separately authenticated and entered into the record as FEMA Exercise Exhibit #1. -
FEMA notes that certain problems surfaced in the exercise which were identified as planning inadequacies because their source was primarily in the Plen or procedures.
The purpose of this testimony is to address the contentions relating to offsite preparedness at the Shoreham Nuclear Power Station, as confirmed by the unpublished Board Order of January 25, 1989, and modified by the letter of February 7, 1989, from Kirkpatrick and Lockhart on behalf of Suffolk County and New York State. That letter provided notice that subparts 1.I,13.D, and 1.0 to Contention 1 had been abandoned or withdrawn.
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As a part of this testimony, and in response to the February )
1, 1989, request from Edwin J.-Reis, Deputy Assistant NRC General Counsel for Hearings, to William R. Cumming of FEMA's.
Office of General Counsel, FEMA has stated its position on the existence of a fundamental- flaw in connection with the following Contentions: 6, 7, 18, and 20. FEMA understands 1 that only NRC can interpret NRC rules and that NRC staff input might be more appropriate in this regard. It also should be noted that throughout the entire exercise preparatory process, .)
NRC Headquarters and Regiona'l Assistance Committee staff met with and participated in discussions between the FEMA Region ]
1 II staff and LILCO's exercise control group. These discussions culminated in the exercise objectives, extent of play, number of exercise demonstrations to be evaluated and other exercise details and procedures.
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Q.1. Please state your name and business address.
I A. Ihor W. Husar . Federal Emergency Management Agency FEMA' Regio'n II - -
26 Federal Plaza New York, NY 10278 i A. Joseph H. Keller Idaho National Engineering Laboratory s ,
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p P.O. Box 4000 Idaho Falls, ID 83401 1
Q.2 Do you have statements of professional qualifications?
i A. Yes. Our statements of professional qualifications are attached to this testimony.
Q,3 When did Ihor Husar first become involved in emergency planning?
A. Mr. Husar became involved in radiological emergency planning in 1980 when he first served as Chairman for the
.. ,O FEMA Region II Regional Assistance Committee (RAC).- In i June 1986, Mr. Husat was reassigned to the FEMA Region II Natural and Technological Hazards Division as Supervisory Natural and Technological Hazards Specialist )
and, at that time he was also appointed RAC Chairman. l On April 3, 1988, Mr. Husar was promoted to Chief, Natural and Technological Hazards Division. He still l retains the post of RAC Chairman.
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- Q.4 When did Ihor Husar first become involved in a review of I
k- emergency planning as it relates to the Shoreham Nuclear Power Station?
A. Mr. Husar first became involved in a review of radiological emergency planning for the Shoreham Nuclear
Power Station on October 6,1986, based on a request from FEMA Headquarters to review ' Revisions 7 and 8 of the u
Shoreham Offsite Radiological Emergency Response Plan.
Q.5 Please describe the nature of that involvement up to the prasent time.
A. Mr. Husar, in his capacity as RAC Chairman, oversaw the J technical review of Revisions 7 through 10 of the LILCO Local Offsite Radiological Emergency Response Plan for ,
the Shoreham Nuclear Power Station. He has been a witness in these proceedings. At the time of the June 7-9, 1988, Shoreham exercise, Mr. Husar was the principal technical FEMA regional official in the Radiological Emergency Preparedness (REP) program and he was responsible for directing FEMA's evaluation of the exercise. He was in charge of all technical FEMA regional activities related to the exercise prior to, during, and after the exercise.
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l SO h Q.6 When did Joseph Keller first become involved in l
radiological emergency planning?
A. Mr. Keller -became involved in radiological emergency planning in August 1979,.when a contract for support to
- the Federal Interagency Task Force on offsite Emergency Instrumentation for Nuclear Incidents was entered into by his employer. He was assigned the responsibility of principal investigator on that contract.
Q.7 When did Joseph Keller first become involved in a review of emergency planning as it relates to the Shoreham Nuclear Power Station?
A. Mr4 Keller became involved with the review of the LILCO Local Offsite Radiological Emergency Response Plan for the Shoreham Nuclear Power Station when he received a letter from a former Director for FEMA Region II, dated October 4, 1983.
9 Q.8 Please describe the nature of that involvement up to the present time. -
1 A. Mr. Keller was originally requested to review Revision 1 of the plan. Subsequently he reviewed Revisions 2 O
through 10 of the plan. On February'13, 1986, and June 7-9, l'988, he was an evaluator at the Shoreham exercises.
He.has been a witness in these proceedings.
Q.9 What documents have you relied on_in your evaluation of- ,
the June 7-9, 1988, exercise of the LILCO Local Offsite
- Radiological Emergency Response Plan for the Shoreham Nuclear Power Station?
A. We have used the joint NRC/ FEMA guidance document entitled, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants: Criteria for Utility Offsite Planning and Preparedness"., NUREG-0654/ FEMA-REP- 1 0
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1, Rev. 1, Supp. 1. As stated on p. 1 of the Introduction to Supp. 1, that document.was intended to facilitate the implementation of the changes to 10 CFR Part 50.47 (c) (1) and 10 CFR 50, Appendix E, Section IV.F of the NRC regulations. Also applicable are operative FEMA Guidance Memoranda (GM), the Exercise Evaluation I Methodology.(EEM)., selected NRC adjudicatory decisions, various NRC letters interpreting NRC requirements, and other technical, policy and background documents, as appropriate. j O
CONTENTION 1.A oN AJ ISSUE: There was an insufficient test of the prompt notification system. There was no adequate testing or evaluation of LILCO's siren system- and no test broadcast -of an
- Emergency Broadcast System (EBS) message.. Furthermore,.
4 LILCO's EBS radio station, WPLR-FM, had withdrawn from EBS suppo!c of'LILCO prior to the exercise.
ANSWER: LERO met FEMA Exercise Objective 12 which is to demonstrate the ability to initially alert the public within the~ 10-mile EPZ and begin the dissemination of an instructional' message within 15 minutes of a decision by appropriate State and/or local officials. Demonstration under this objective was successfully accomplished within the parameters of FEMA GM AN-1 dated April 21, 1987, and FEMA-REP-10, dated November, 1985.
GM AN-1 states on page I-2 that the "15-minute capability" is confirmed through . the observation of actual demonstrations or simulations (emphasis added) of this capability during offsite radiological emergency preparedness exercises. GM AN-1 further states on page I-5 that it is " acceptable to simulate the activation of alert and notification systems during exercises.
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V..' - simulated, .the- 15-minute capability. can still- be-confirmed." It adds that "the observer should see the.
preparation of the' instructional message, coordination -
- with participating jurisdiction, . communication with the broadcast. station and completion of the authentication.
+ process."
FEMA-REP-10, page N-2, Acceptance Criteria, states that an exercise should be structured to demonstrate that
~ "A satisfactory ' exercise of an alert. decision-implementing chain can occur up to the point of'actually.
activating the alert and notification system (although activation should be simulated as realistically as-possible)."
Page 32 of the PEA specifies how the public alert and
. notification (A&N) system was to be tested in the exercise. Both simulation and real activation of the' siren system occurred during the exercise, as shown.on
. Table 1.3 on page 40 of the PEA. For example, as indicated on the Table, activation of the siren system was simulated twice before being actually demonstrated once at 1023 on Day 1 of the exercise. Although activation is not necessary, page I-4 of GM AN-1 states that, "It is acceptable to verify the capabilities of the i
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system at any.one of the activations,.if there is more s than one, as long as the entire sequence'can be observed during the activation chosen for verification." However, it is a well.known fact that many of the 89 sirens in the LILCo system failed to sound when activated during the exercise. The siren failures are men'ioned t on page 44
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of the PEA. As a practical matter, LILCO discovered that the cause of the failure had to do with timers on siren
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control boxes, and as stated in their June 16, 1988, letter to the then Director of FEMA Region II., " ...
another siren test was scheduled, refresher operator ;
training was provided to the Director (of Local Response]
and the set points of the timers in question were adjusted as necessary."
As page 44 of the PEA states, the " issue of the siren failure will be dealt with through the maintenance and operability requirements of FEMA-REP-10. " This statement refers to the' routine siren testing requirements found in Appendix 3 of NUREG-0654/ FEMA-REP-1, Rev. 1, and elaborated on in Appendix 4 of FEMA-REP-10. As part of the A&N approval process, FEMA will verify the siren l operability estimated from the results of the siren <
testing program as it was implemented for the 12 months preceding the submission of the A&N design report. The operability of a siren system is considered acceptable 12
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- when an average of 90%~of the sirens (as determined'by a simple average of the results of.all the regularly conducted tests) can be demonstrated functional over-the-12-month period immediately preceding the submittal,of l the design report. In the case of a design report submitted far ahead of the time when FEMA can finalize
a date for the major telephone survey or finalize its review of the system, FEMA will require more recent operability records.
FEMA believes that this process of confirming system reliability based on records over an extended period is 1
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of siren sounding in an' exercise. FEMA would not deem
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t a system acceptable, for example, based on one successful system-wide sounding. By the same token, FEMA does not deem it unsuccessful based on one system-wide malfunction. The results of any such ree.1 activation, whether successful or unsuccessful, are simply factored into the annual operability records for the site in 1
. question. )
Concerning the participation of WPLR-FM, the LILCO plan, page 3.8-7 states that "WPLR has agreed to serve as the Common Program Control Station (CPCS-1) for the Shoreham local EBS until the issuance of a full power operating l O
license, and if . needed, to remain a member station thereafter."
LILCO certified to FEMA in a letter dated June 3, 1988, that the radio station WPLR-FM would continue to be a part of the LILCO plan for issuing instructions to the )
- I public via EBS until Shoreham receives a license to operate above 5% total generating capacity. In fact, WPLR-FM participated in the June 1988 exercise and actual calls were made to the radio station, as observed by the FEMA evaluator at the station.
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,7 CONTENTION 1.'B ISSUE: Only one school participated in the exercise and this was an inadequate test of ths plan.
ANSWER: As interpreted by the March 7, 1988 Amendment to GM EX-3, jointly developed by NRC and FEMA and cited on page 13 of the PEA, the joint FEMA /NRC document NUREG-0654/ FEMA-REP-1, Rev. 1, Supp. 1 does not require the actual participation of public schools in a non-participating jurisdiction, since they are deemed to be governmental organizations. This was further confirmed by the May 11, 1988 letter from NRC to FEMA and a May 25, 1988 legal interpretation of the status of schools in New York State issued by FEMA's Office of General Counsel.
In keeping with the determination that with the exception of the Shoreham-Wading River School District, public school districts were part of the non-participating-governments, they were represented at the FEMA Control Cell, so that the interface between LERO and the districts could .be tested. In addition, LILCO's compensatory transportation measures for schools were tested as described on page 113 of the PEA. See Figure 1.1 on page 4 of the PEA for the list of bus companies
> whose vehicles drove routes, which were evaluated.
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i CONTENTION 1.D (Consolidated with CONTENTION 14.F)
ISSUE: Children were not taken to Nassau Coliseum and nothing was demonstrated at this facility.
ANSWER: Nassau County is a non-participating jurisdiction in offsite emergency preparedness for the Shoreham Nuclear Power Station. Since Nassau County did not participate in the exercise and did not allow their facilities to be used for demonstration of LERO capabilities, FEMA considers that the non-use of the Nassau County Coliseum is covered by the provisions of the 3 basic NRC assumptions of NUREG-0654/ FEMA-REP-1, Rev. 1, Supp. 1, Ov as specified in the preamble to the FEMA testimony.
Nassau County officials were represented by the FEMA Control Cell during the exercise.
The Nuclear Regulatory Commission does not require public participation in exercises. Thus, teachers and students, even in participating jurisdictions, are not required to participate in exercises.
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j GQliTENTION 1.E
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ISSUE: LERO's compensating plan for school evacuation was inadequately tested in that:
- only 1 school-participated;
- there was - an inadequate number of school bus drivers t dispatched; -
- there ' was .no- demonstration of monitoring. and' decontamination of school children; and
- there was no demonstration of adult supervision of evacuating school children.
ANSWER: As interpreted by the March 7, 1988 Amendment to EX-3, cited on page 13 of the PEA, the joint NRC/ FEMA document -
NUREG-0654/ FEMA-REP-1, Rev.1, Supp.1, does not require the actual participation of public schools in a'non-participating jurisdiction, since they are deemed to'be governmental organizations. This was further confirmed by the May 11, 1988 letter from NRC to FEMA and a May 25, ;
1988 legral interpretation of the status of schools in New York State' issued by FEMA's Office of. General Counsel i (see replies to Contention 1.B and 1.D, above).
i The LERO plan calls for the deployment of 508 school bus drivers in the event evacuation of schools is required 17
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g in the event of a' radiological emergency (OPIP 3.6.5, Attachment 3A) . This is the total number for buses which '
normally . service schools. and in addition, the supplementary buses necessary for a one-wave evacuation.
Forty (40) school bus drivers were evaluated, including drivers' representing the Shoreham Wading River School District resources. This is greater .than the number evaluated in the 1986 exercise. In addition, all school bus drivers were mobilized and dispatched, as described in the extent of play discussion on pages 33 and 34 of l
the PEA. All bus drivers evaluated by FEMA had their assignment packets. FEMA has no information on how the intervonors arrived at their figure of 613 as the total
'V' n number of bus drivers or the figure of 30 as the number of school bus drivers evaluated by FEMA.-
1 All school bus routes evaluated included driving to the school relocation centers. However, as part of the extent of play negotiations, drivers were not to stop at either their ass'igned schools or school relocation 3 centers, but were to drive by the facilities. After driving by the relocation centers, but before reporting to the EWDF, all bus drivers were to first stop at LILCO's Garden City facility where they were to receive the instructions they would have received at the school 18
relocation centers had these facilities been activated for the exercise. A number of bus drivers were to be directed to report to the Hicksville Reception Center from Garden City, simulating that the school children
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they were carrying came from areas that were potentially contaminated by'the passing plume.
In keeping with FEMA's procedures and the NRC position which provide that mandatory public. participation is not required in exercises, there.were no school children or teachers evaluated as part of the exercise. In addition, the bus routes (transportation resources) were tested out-of-sequence'on Day 2 of the exercise.
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1 CONTENTION 1.F, 1.G AND 1.P .
l l ISSUE: There was insufficient testing of LERO's ability- to j provide resources for transportation of special facility ;
residents and- the homebound, mobility-impaired' population.
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ANSWER: FEMA chose to evaluate a representative demonstration of transportation resources for mobility-impaired, special facility residents and homebound, mobility-impaired individuals, in order not to strip the ambulance and ambulette pool reserved for the non-exercise-related emergency requirements of the communities they serve.
Toward this end, a decision was made to utilize ambulances, ambulettes and buses for the demonstration of evacuating the mobility-impaired, special facility population. As a result, a total of 6 ambulances, ambulettes and buses were utilized for this demonstration. This is a greater number than the number evaluated in the 1986 exercise. -
Twelve actual emergency vehicles were dispatched to evacuate the homebound mobility-impaired population (6 homebound ambulance /ambulette patients, and 6 curbside pickups by bus and van) . It is FEMA's position that this 20
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O purposes of'the exercise. In addition, the number is greater than the number evaluated in the 1986 exercise.
The. fact that no person was transported is in keeping with FEMA's policy of not requiring participation of the general public (non-emergency workers) in REP exercises.
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CONTENTION 1.H -
O Lj ISSUE: LERO did not demonstrate its ability to select hospitals outside the EPZ for relocation and healt.h care services at the time of an emergency.
ANSWER: It is FEMA's position that LERO followed-its procedures as identified in OPIP 3.6.5, Attachment 5, 'and established the number of vacant hospital beds available in reception hospitals. It is immaterial whether the contacts were made to actual hospitals or to the LERO Control Cell. What is material is that the procedure was followed, the number of vacancies was determined and the data base was established in order to prioritize which hospitals would be used, if needed.
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/9 CONTENTION 1.0 LI ISSUE: There was an insufficient test of the communications network.
ANSWER: It is FEMA's position that LERO met FEMA Exercise Objective 4. Figure 3.4.1 of the plan shows many lines
, of communication not asserted to be deficient.
Therefore, the communications net as a whole was successfully demonstrated. Actual calls were made to WPLR-FM as observed by the FEMA evaluator at the radio station.
Issues related to the participation of the American Red
(~]J L Cross were dismissed by Judge Frye's Memorandum and Order LBP-89-1 of January 3, 1989. Although this ruling is on appeal, FEMA believes it is a logical extension of the decision wherein the Commission in Lona Island Lichtina h (Shoreham Nuclear Power Station, Unit 1), CLI-87-5, 25 NRC 884, 888 (1987), recognized that the American Red Cross charter from Congress and its national policy require that the American Red Cross provide aid in "any radiological or natural disaster," whether or not there are letters of agreement with the American Red Cross in connection with a particular emergency plan.
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I Based on this Commission decision, FEMA supported the -
deletion of Objective 22 concerning the testing of Congregate Care Centers from the objectives to be tested in the June 1988 Shoreham Exercise. NRC staff supported this specific deletion in their May 20, 1988 memorandum confirming the fact that the objectives submitted by FEMA on May 13, 1988 would constitute a qualifying exercise.
The Director of the Division of Radiation Protection and Emergency Preparedness, Office of Nuclear Reactor Regulation, stated the following:
Regarding the deletion of Objective 22 (FEMA Guidance Memorandum EX-3) because A of the non-participation of the American N -),
Red Cross, we believe that this is appropriate. In a May 11, 1988 letter from Edwin Reis, Deputy Assistant General Counsel, NRC, to William R. Cumming, Office of General Counsel, FEMA, we stated that the Commission had previously found that the American Red Cross charter from Congress and its national policy require it to provide aid in "any radiological or natural disaster," whether or not there are letters of agreement in connection with a particular emergency plan. We will
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support the position that the American 7q 5
Red Cross responds to natuital and technological disasters as a routine and that it is not necessary.to demonstrate
. this capability in a radiological emergency preparedness exercise if they decline to participate. In this case we believe it is not reasonably achievable to gain their participation in the Ghoreham exercise.
I With regard to other organizations cited by this contention, please refer to the replies to Contention 1.B concerning the participation of schools, and Contention 1.D concerning the participation of Nassau j County. Such non-participating governmental organizations were represented by the FEMA Control Cell during the exercise, as explained on pages 11 and 32 of the PEA, according to guidance supplied in the March 7, 1988 Amendment to GM EX-3, jointly developed by NRC and I- FEMA, and the joint NRC/ FEMA document NUREG-0654/ FEMA-i REP-1, Rev. 1, Suppe 1. The use of the Control Cell in i
this manner was supported by NRC staff as confirmed in I their May 26, 1988 memorandum. The extent of exercise play approved by FEMA for the testing of communications with the FEMA Control Cell provided a sufficient O '
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demonstration' under representative objective 4 of communications with the organizations represented by i
Fig. 3.4.1.of the Plan. I 1
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CONTENTION 6
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Contention 6 makes many assertions about 'the EBS messages issued during the June 1988 exercise of LILCO's
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I Local Offsite Radiological Emergency Response Plan for 'I Shoreham. One of the main issues is the-timeliness of. !
the EBS messages. This is discussed in the PEA on page
- 45. The report explains that no problems were observed in the issuance of EBS messages ' within the' 15-minute guideline (specified in NUREG-0654/ FEMA-REP-1, Rev. 1, Appendix 3, FEMA-REP-10 and GM AN-1, as ' the maximum acceptable amount of time for alerting and notifying the I public after 'a decision is made to do ao by State and i local officials). It should be noted that in evaluating the timeliness of LERO's EBS mecsages, FEMA considered ;
s the time at which LERO received the FEMA Control Cell approval of the message as the decision point. In j addition, due to the nature of the potential doses,- .
there is no. rationale for a 15-minute guideline for EBS >
messages issued in ingestion and recovery and reentry phases'.
During the June 1988 exercise, several problems were observed in the EBS messages used to convey information ]
about the radiological emergency to the public. For O "
example, as stated .in Contention Subparts 6.A.1 and ;
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technically inaccurate information regarding offaite-doses. FEMA cited this error as an ARCA on p. 45 and p.
55 of,the PEA. The recommendation for corrective action also notes that all EBS messages should be screened to
- ensure that cumulative information is appropriate to the
- changed conditions (projected doses).
l In addition, as mentioned on p. 45 of the PEA, although EBS messages were generally detailed and comprehensive, ;
new and important information was usually inserted in' the middle or at the end of previous messages rather than at the beginning where new information should be carried. Due to the excessive length of the messages,.
listeners might potentially miss pertinent information.
However, although the evidence of this problem surfaced )
in the exercise, FEMA and the RAC determined that the source was primarily in the procedure for generating EBS i I l messages, OPIP 3.8.2. As a result, this problem was j classified as a plan inadequacy and inserted in FEMA's )
review of Revision 10 of the LILCO Plan, issued with the i i
PEA on September 9, 1988.
In its letter of November 21, 1988, to the NRC, LILCO l l
has gone beyond FEMA's suggested changes and has, among l
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other things, committed to revise its EBS procedure to address problems, conduct training for appropriate staff and as a' final demonstration, conduct a Public Information Tabletop training drill. On December 5, 1988, NRC requested - that FEMA review LILCO's proposed plan revisions and schedule for corrective actions to address problems cited in the PEA and plan review. FEMA has not completed its review of the proposed actions, but will do so as soon as possible. When FEMA receives and reviews the actual revised draft messages, revised procedures, and other corrective measures as appropriate, an evaluation of their adequacy can be made.
O FEMA's responses to the subparts of Contention 6 show that some of the intervener individual factual assertions are not specifically mentioned in the PEA.
Later analysis of available data performed in preparation for this hearing has revealed that some of i these assertions are correct. However, there are certain additional factors discussed below which form the basis for FEMA's continued use of the exercise to support its overall positive finding.
As a necessary means for the evaluation of Evaluation Criterion N.1.b. in NUREG-0654/ FEMA-REP-1, Rev. 1, Supp.
29
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J p 1, as reflected in the new Objective 37, FEMA l 1 i established a control Cell to provide a mechanism for the evaluation of the participants' ability to interact with non-participating State and local governments. The control Cell operations at the exercise were structured in the context of CLI-86-13 (Lona Island Lichtina Co.
(Shoreham Nuclear Power Station, Unit 1) 24 NRC 22 (1986)) which reversed the Appeal- Board ruling on the legal authority issue (ALAB-818, 22 NRC 651) and was, in effect, the precursor to the revised NRC rule (10 CFR 50.47 (c) (1) ) . The commission explicitly directed the ASLB to assume that the State of New York and County of Suffolk would in fact respond to an accident at Shoreham on a best-effort basis that would use the LILCO plan as the only available comprehensive compendium of emergency planning information and options (24 NRC, at 33).
An objective of the Control Cell was to allow the testing of the LERO plan as a " stand-alone" plan. If the LERO plan could be implemented with the utility's resources alone, it would necessarily follow that it could be implemented with the combined resources of LERO and the State and local governments. The FEMA Control Cell operation was geared to allow the exercise to satisfy the NRC assumptions in NUREG-0654/ FEMA-REP-1, Rev 1, Supp. 1, in the context of actual emergency O 30 Q !
l i operations. Use of the FEMA Control Cell was also geared
-O. to allow the exercise to demonstrate a full range of ,
LERO's ability to interface with the State and local "best efforts" which could range from simple delegation of legal authority to the fullest cooperation with utility and Federal officials. NRC representatives and FEMA counsel present in the Control Cell during the entire exercise concurred in this approach. , ,
As FEMA Control Cell documents show, the FEMA Control Cell specifically approved each message before it was issued, in accordance with the LERO plan. Before granting approval, it asked specific questions on the rationale for particular phrasing (like the use of the I
phrase "early dismissal" in the first message) and made specific requests for word changes. Sometimes these were substantive, sometimes they were not. However, FEMA believes that this interaction created the impression that the EBS messages were being fully reviewed for content before approval was granted, when
'in fact the review was far less than total. Based on the above considerations, even if all of the factual assertions of the interveners were to be true, FEMA ,
continues to support the overall conclusion of the exercise report.
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- Further, in FEMA's approach. to evaluating the l seriousness of inadequacies in EBS messages, if it can !
be shown that the public would have been exposed to-significant quantifiable additional dose as a result of the inadequacy of the messages, which could have been avoided if adequate messages had been issued, the inadequacy.should be rated as a Deficiency. In certain limited circumstances, Deficiencies have been assigned to inadequacies absent quantifiable avoidable dose.
Given the inadequacies in the LERO EBS messages, it is FEMA's position that while there may have been some confusion created in the minds of the. listening public,
.J there would have been no quantifiable additional dose, which could have been avoided, as a result of the EBS messages. In addition, based on considerations about the Control Cell interaction noted above, FEMA Region-II continues to support the overall conclusion of the exercise report.
In any event, it is FEMA's position that the inadequacies in the EBS messages are not a fundamental flaw because they do not meet all the factual criteria as defined in ALAB-903. The second criterion of the fundamental flaw definition is that a significant revision of the plan is required. It is FEMA's position that the second criterion is not met. Some plan ,
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b revisions are required to correct the inadequacies that were surfaced by the exercise. However, these plan revisions are not significant. Clearly, the concept of operations adopted in the plan does not need to be
- revised. What is needed is a revision to the EBS formatting instructions'in one procedure and a greater emphasis on following the instructions, already in the procedure, by deleting outdated information.-
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CONTENTIONS 6.A.1 and 6.D.8 j O _
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15.SJ1E: EBS messages #4, #5, #6, and #7 contained technically inaccurate information regarding offsite doses.
ANSWER: The information contained in EBS messages #4, #5, #6, and #7 stating that "[b]ased upon radiation measurements exposure to small doses is projected at the site boundary downwind of Shoreham" was inaccurate based upon conditions existing at the time that these messages were issued. In fact, FEMA cited this as an Area Requiring Corrective Action (ARCA) on pages 45 and 55 of the PEA.
As discussed above, this outdated information would not have resulted in significant quantifiable avoidable dose because:
Evacuation and sheltering were already in progress l based upon instructions issued to the public in EBS message #3 which was issued at 1026 and although the "small dose" information was incorrect, it would not have changed these protective actions.
- The protective actions described in EBS messages #4,
- 5, #6, and #7 reinforce the interpretation that the release referenced in the messages does in fact pose
( 34
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public.
+ Other aspects of EBS,me'ssages #4, #5, #6, and #7 which tend to reinforce the public's likelihood of evacuation and/or sheltering'are the following: (1)
.the repeated definition, of the Emergency Classification Level, (2) the repeated instruction for evacuees to go to the reception center (as explained
' in their erargency information brochure), and 3) the.
repeated statement that a release of radioactive material had occurred and was continuing.
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' CONTENTION 6.A.4 and'11.A -
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l ISSUE: The EBS . messages were inaccurate in that ingestion l pathway actions should have been recommended prior to the issuance of the ultimate recommendation.
ANSWER: It is FEMA's position that the EBS messages tracked the protective action decision process. Information was not included in EBS messages until the LERO recommendation was.made final'by the concurrence of the Control Cell.
The. PEA states that once the decision was made, the EBS
"'"' "' "' '" " ' '""' "' '"' ""^
l <D states that PARS for the ingestion pathway in New York State beyond the 10-mile EPZ were slow to be developed.
The only appropriate PAR for New York which was not issued in a timely manner, i.e., on the morning of Day 2 of the exercise, was to place dairy animals on stored feed and water. It is FEMA's position that .with the exception of the above example, other ingestion pathway i and recovery and reentry recommendations were well foundedandwithintheguidelinesestablishedbyFede[al 1 guidance and the plan.
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I 'v' CONTENTION 6.A.5 and 6.B.8 I
ISSUE: The LERO recommendation to place dairy animals on stored .
feed was not timely and was unclear as to the area intended to be covered. In addition, EBS message #16 was not accurate in that there is confusion between q l taking no action and putting dairy cattle on stored feed i
and water, l
ANSWER: EBS message #16, issued at noon on Day 3, is clear in its specification as to the extent of the coverage intended. Contrarp to assertions, "all locations east U of the William Floyd Parkway on Long Island" is sufficiently specific to allow residents to understand if the instruction applied in their area. In addition, as stated on p. 52 of the PEA, LERO was making contact with all agricultural entities identified in the plan to ensure that the proper actions were being taken at the source. EBS message #16 was the first EBS message issued after the time asserted (1051) that LERO had proposed a PAR to the Control Cell.
As stated above, the PEA identifies the untimely development of recommendations for the dairy animals in 37
the'10- to 50-mile portions of the New York-ingestion pathway EPZ. EBS message #16 continues .the approach I. adopted by LERO for. essentially all EBS messages, i.e.,
1 l- making the messages cun.ulative. .When new information'or instructions to the public were issued, the previously.
correct, but now outdated instructions were not always deleted from the messages.
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,-s CONTENTIONS 11.B and 11.D me (consolidated with 6.A.4 and 6.A.5)
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ISSUE: LERO EBS messages should have contained ingestion pathway instructions at an earlier time.
ANSWER: As discussed in. the response to Contention 6. A.4, the instructions to place dairy animals on stored. feed and I water in the New York 10- to 50-mile portion of the EPZ were untimely. Other actions were taken as they became warranted and were approved by the Control Cell.
According to Federal guidance, as documented in FEMA Guidance GM IN-1, other actions in the ingestion pathway
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were not warranted until laboratory measurement of samples verifying values in excess of guidelines in food had been made. The PEA, at page 52, documents-actions which were being taken to obtain the necessary samples and laboratory analysis to make the required verification.
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i _ CONTENTION 6.A.6 l.
ISSUE: EBS messages -#4 and #5 contained incorrect information regarding the whereabouts of school children from the Rocky Point School District.
ANSWER: According to the plan (see OPIP 4.2.1, - Section 5.4.11) buses arriving at the school relocation center from zones affected by the plume-are to be directed to the Hicksville Reception Center for monitoring after they arrive at the Nassau Coliseum. As of 1146, children from the Rocky Point School District were.in transit to the Nassau Coliseum and arrived at that location at around 1315 (i.e., 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 29 minutes 'later).
Therefore, EBS message #4 issued at 1211 and EBS message
- 5 issued at 1308 were correct.
EBS message #6 issued at 1340 indicates that as of 1315,-
children from the Rocky Point School District were being transferred to the Hicksville Reception Center for monitoring. The first school bus did not arrive at the Hicksville Reception Center until approximately 1445.
Therefore, the information in EBS message f5 was accurate when it was issued.
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-l EBS messages #6 and #7 indicate that the students would be returned to the Nassau Coliseum when the monitoring Process is completed and EBS message #7 adds that parents should pick up their children at that location.
This is in keeping with the provisions of the plan.
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CONTENTION 6.B.1.
ISSUE: Between 1100 (when the releece occurred) and 1211 (when EBS message #4 was issued), EBS message #3 was repeated i
containing inaccurate information regarding tM possibility of a release. ;
1 ANSWER:- The facts stated in the contention are correct. It would have been better for LERO to have issued an update to EBS message #3 sooner stating that a release had
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cccurred. However, as stated in the answer to contention 6.A.1, this was not considered a major problem' because protective actions were already in
' O progress at 1100 based on instructions contained in EBS message #3 and the public should have been following those instructions.
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j CONTENTION 6.B.2 and 12.D _
\d j ISSUE: The advice.to evacuees from specified planning zones to report to reception' centers was untimely.
ANSWER: EBS message #3 contained the first recommendation for j the evacuation of specified planning zones. It also j contained directions to the LERO reception centers and a reference to the Shoreham Public Emergency Procedures Brochure. The instructions to report to the reception centers are contained in the EBS messages that followed the start of the release of radioactive material to the e environment. It is technically unwarranted and
'\ unnecessary to instruct evacuees to report to reception centers prior to any release of radioactivity. The interveners assert that there was a delay in explaining why evacuees should follow the previous instruction even after LERO was aware that "a substantial number of people" were not reporting to the reception centers in spite of the previous recommendation to do so. Assuming that the timing asserted is correct (i.e. 1450), the next EBS message issued, EBS message #7 issued at 1748, does contain a more detailed explanation for the basis on which evacuees were told to report to reception centers. While it would be desirable to include such 43
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)
discussion between the LERO responders and the Control Cell before final approval of EBS message #7. A portion of this delay was the result of the shift change required by Objective 34, described on p. 48 of the PEA, which, as a result of extent of play negotiations, was
- scheduled to take place at the LERO EOC between approximately 1500 and 1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br />, in various phases.
FEMA maintains, as stated in the PEA, that once the l Control Cell approved the actions recommended in the EBS message, thereby conferring to LERO the legal authority to make such a recommendation to the public, the messages were aired within the 15-minute guideline.
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CONTENTION 6.B.3 and 12.C .
ISSUE: LERO was untimely in advising residents of areas recommended .for evacuation, who chose to ignore the evacuation recommendation, of alternate means of protection. .
- l ANSWER: LERO made' continued recommendations to individuals in specified planning areas that the best course of action would be evacuation as soon as possible. This advice to the public was contained in EBS messages #3 through #8.
It was appropriate to continue the evacuation recommendation until the release of radioactive material into the environment had been terminated and the plant stabilized. All of the above EBS messages contained instructions to individuals in other planning areas on the definition of sheltering,and that would have given information to individuals who had chosen not to follow the evacuation recommendation or other protective actions' options. It would have been inappropriate for LERO to purposefully insert conflicting advice to residents of specified planning zones. To do so would have led to confusion in the public.
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, CONTENTION 6.B.4 and 11.E O
ISSUE: There were delays in inserting " automatic" protective action recommendations for dairy animals in the LERO EBS messages.
ANSWER: It is FEMA'S position that there were no inordinate delays with regard to the inclusion of " automatic" ~l protective measures for dairy animals, at either the SAE l i
or the GE levels. The PEA states that the EBS message at SAE which contained the required PARS for dairy animals was issued within 8-10 minutes after the LERO l recommendation was approved by the FEMA Control Cell.
In the case of the GE EBS message (#3), this interval t
was 6 minutes. FEMA does not consider either an undue delay.
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CONTENTION 6.B.5 and 6.B.6 ISSUE: Information regarding the treatment of students who live inside the plume EPZ but who attend school outside the EPZ was not included in EBS messages in a timely manner.
ANSWER: FEMA believes that the Contention inappropriately interprets the facts concerning the first decision time, i.e. 1146. The LERO call to the FEMA Control Cell representing the notification of the final school district superintendent of a school outside the EPZ with students living inside the EPZ was concluded at 1323.
In these calls, superintendents were told that parents O of such students would be notified via EBS that the children would be taken to the Nassau Coliseum unless they had been picked up by their parents. However, the superintendents were asked to call LERO back if any
. children had not been picked up. When LERO had not heard from any of the superintendents, LERO initiated calls at 1622 to confirm that no help was needed. The first superintendent who replied by requesting assistance did se at 1626+ Within 5 minutes, the LERO Public Information Coordinator had called the superintendent to review appropriate language for inclusion in the next EBS message #7. The LERO school 47
, -coordinator continued to make calls until 1648 to verify
'k. whether other school districts also needed assistance.
Even a notice of the proposed pick-up procedure could not have been inserted in an EBS message until after all school superintendents had been notifie'd (i.e. 1323).
Thus, the first EBS message which could have potentially included that information was EBS message #6 at 1340.
However, it was not specifically known until 1626 that the procedure would be implemented. It was inserted in the first EBS message after this was known (#7).
Although the portion of the information contained in EBS message #7 (issued at 1748), concerning this type of g school children was approved by the Control Cell at 1633, the EBS message in its entirety was not approved until approximately 1739. Although it would have been issued earlier, the fact that the LERO Control Cell system was involved in a lengthy discussion precluded the earlier issuance. Some of the delays in the issuan'ce of EBS #7 can be attributed to the control cell issues identified above.
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CONTENTION 6.B.7 and 6.B.10 (Consolidated with CONTENTION 12.E)
ISSUE: Information involving traffic impediments was not provided to the public in a timely manner.
ANSWER: ,
In the case of the incident in Coram at Granny Road, the impediment " occurred" (the free-play message was inserted into the exercise play) at 1200. It was first recorded on a Traffic Control Coordinator log at the LERO EOC at 1201, although complete reading of the message twice and confirmation took 8 minutes. At 1218 the traffic guide involved in directing evacuation traffic at this location was instructed by the LERO EOC on how to reroute traffic. Thus, it appears that corrective action was being implemented in the field approximately eighteen (18) minutes after the incident had occurred. The alternate evacuation strategy used a section of Route 112 which marks the boundary of the EPZ. Although it would have been desirable to issue an EBS message with this information sooner, there were small delays in both the LERO,'and Control Cell organizations. The combination of these delays precluded earlier issuance of this message.
49
G In the case of the incident cit'ed at Sheep Pasture Road, the impediment " occurred" at 1125'and was fully reported to the county representative 'at the control . Cell by approximately 1145. At 1155 the traffic guide involved in this situation. requested from the LERO EOC -
instructions on how to handle backed up traffic, and he
<r was immediately advised how to reroute it. While this:
a corrective action was being taken at the scene, the EBS message was broadcast .within 16 minutes of - the field actions and 26 minutes of their approval, with the result that the public announcement issued at 1211 dovetailed, -within a reasonable period of time, the action taken in the field.
O With regard to the impediment at Wading River and Shultz Road reported to have " occurred" at 1259, the county representatives at the control Cell were advised by the LERO EOC of a proposed rerouting at 1317. The county approved this proposal at 1325. The traffic guides at the scene were advised how to reroute traffic at 1332.
At the same time (1332) EBS message - #6 concerning this -
impediment was approved by the County (FEMA Control cell). It was issued at 1340, not 1440 as stated by the contention. In addition, at 1343 the impediment was reported to be partially cleared with one lane of traffic open. l 50
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, CONTENTION 6.B.9
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ISSUE: LERO EBS message #17 narrowly defined. the area of contamination.
ANSWER: The assertion confuses the presence of contamination with level's of contamination which warrant taking protective measures. As already discussed, a precautionary PAR of placing dairy animals on stored feed was warranted and was in fact implemented in an untimely fashion. Even if the facts asserted concerning statements to the Control Cell are true, the fact that contamination is present does not warrant taking a b protective action. The area defined in EBS message #17 was the proper area as verified by the measurement data for which protective measures were warranted based on Federal guidance and the plan.
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CONTENTION 6.C.1 and 6.C.2 ISSUE: The ' LERO EBS messages were excessive in length and formatted poorly.
^
ANSWER: FEMA ~has analyzed the EBS messages issued during the exercise and has compared them'with the draft messages contained.in the plan of record for the exercise (i.e., h Revision 10).-
- All but one EBS message developed at ' the 1988 exercise generally followed the appropriate draft messages cont'ained in the plan and they were.
e detailed and comprehensive. These were essentially the draft EBS messages reviewed by the RAC in its detailed review of Revision 9 of the plan (dated April 28, 1988) and found to be adequate to satisfy the requirements of NUREG-0654/ FEMA-REP-1, Rev. 1, Supp. 1. Changes made to these messages in Revision 10 were in keeping with other changes in the plan and the messages were not altered significantly.
It is also FEMA's belief that LERO participants believed that the specific innguage of the messages i 1
developed during the exercise was reviewed by the .]
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I control cell.and that in'accordance with the plan, LERO issued only, EBS messages approved by the Control Cell. In fact, the control Cell review wan not always complete.
Nevertheless, as specified in the PEA (page 45) and the RAC review (page 3) of Revision'10 of the plan
... (dated September 6, 1988), new and important information was usually inserted in the middle or at the end of previous messages rather than at the beginning where new information should be carried.
Also, due to the excessive length of the EBS messages, listenere may potentially.miss pertinent
/' information.
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Although problems with the EBS messages surfaced in the exercise, FEMA and the RAC determined that their source was primarily in procedure OPIP 3.8.2, and thus that it was more appropriately cited as a plan j inadequacy. Accordingly, FEMA and the RAC have recommended that the format of draft EBS messages in the plan should be revised to make messages more concise and to emphasize important and any new information at the beginning of messages.
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. CONTENTION 6.D.2 Q .
ISSUE: The EBS messages did not inform the public that the Long.
Island Railroad had suspended service within the plume EPZ.
A ANSWER: The evacuation strategy in the plan does not rely on the ,
Long Island Railroad (LIRR) as a primary means of evacuating the EPZ. During the exercise, the LIRR (represented by the FEMA Control Cell) was contacted on the morning of Day 1 and agreed to stop. service between Yaphank and Riverhead (PEA - page 48).
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l CONTENTION 6.D.7 )
7-V ISSUE: In EBS message #3, persons in Zone K were told to evacuate in one sentence and to shelter in a later sentence in the same paragraph.
ANSWER: The facts asserted are correct based on the hard copy of information available to FEMA. EBS message #3, page 3, j item- 3 lists Zone K as an area to be sheltered.
However, in the next to the last paragraph of EBS message #3, it does state that people in Zone K are advised both to avacuate and shelter. While the l
. inclusion of the statement to evacuate is in error, its
\- implementation would not have impacted the radiological health of those people in Zone K. Since the people in Zone K were in the 5-10 mile ring, early evacuation of this area would have resulted in a more conservative protective action. It should be noted that the ,
l accidental inclusion of the evacuation of Zone K was 1
corrected in EBS #4 and never repeated *in later messages.
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CONTENTION 6.D.12
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4 ISSUE: EBS message #17 was inconsistent with regard to
, instructions for ingestion pathway actions.
ANSWER: The information recommending no action be taken outside
-the 10-mile EPZ, is correct with regard to the guidelines cited. There was never any technical reason which would have warranted taking protective action-based on EPA PAGs beyond the areas already evacuated.
Both citations in the assertion make reference to the EPA guidelines and in that regard, the EBS messages are technically correct. There are instructions to both t[ people in the 10-mile EPZ and people in certain areas outside the 10-mile EPZ. .Those few who were still in the 10-mile EPZ would have had to have chosen to ignore the evacuation recommendation. The directions for those outside the 10-mile EPZ were only for those areas where ingestion pathway protective actions were warranted based on FDA PAG's but not on EPA PAG's, i
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CONTENTION 6.D.13 ISSUE:- EBS message #17 was confusing and. unclear with regard to specific geographic areas impacted by the protective action instructions.
ANSWER: The assertion states that EBS message #17 is unclear in-l that the precise EPZ zones affected were not identified'.
It is FEMA's position that this assertion is without basis. The EBS message clearly defines, by use of familiar geographic boundaries, the area intended for actions. It is true that planning zone designations were not used as had been done in previous EBS messages; however, there are no planning zones in the plan beyond >
the 10-mile EPZ and none are required. Rather LERO made good use of descriptive landmarks to designate the area of concern. It is. FEMA's position that the message is clear in that locally grown produce and vegetables were from the area of concern. If the public'did in fact misunderstand the intent and " treated" all locally grown produce and vegetables, - no harm would have occurred
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since the treatment was more conservative than required ,
and in addition, was simple and easy to accomplish.
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CONTENTION 7 -
The Emergency News Center (ENC) in the LERO offsite plan
^
is not responsible for the generation of the EBS messages. It has been, and continues to be, FEMA's position that critical emergency information 'and i
instructions are,to be provided to the public through 2BS. Additional means (news releases and media briefings) are supplemental to this primary means. It is apparently true that there were delays in posting EBS messages / news releases in the ENC. However, FEMA cannot independently quantify the delay. At the ENC, the media had the means'for monitoring EBS broadcasts. Therefore, the media would have learned of the information when the O EBS, messages were broadcast.
Concerning a related Deficiency in the 1986 exercise, FEMA's primary concern was with the rumor control operation being unable to answer questions with timely and accurate information.
I It is FEMA's position that the delays discussed in the responses to this contention do not meet all the l criteria for a fundamental flaw because the correction of the delays does not involve significant revision of the plan.
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CONTENTIONS 7.E.1. 7.E.3 and 7.E.5 f I
l ISSUE: There was a delay in the posting of EBS message #1, in -l the receipt of EBS message #5, and in the distribution 1
of EBS message #16 at the ENC.
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ANSWER: FEMA has no independent information about the timing of the posting of EBS message #1, the timing of the receipt of EBS message #5 or the timing of the distribution of EBS message #16 at the ENC. The only independent information available to FEMA is the EEM evaluation forms completed by its evaluators. It is true that the f evaluations identified a concern about the timing of the ;
postings. However, since they only cited the issue as-i an Area Recommended for Improvement, FEMA must conclude l that they did not consider it a serious problem.. They I
did not supply precise times for individual postings. )
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CONTENTION 7.E.2 ISSUE: News release #3, which contained the EBS message of a General Emergency, was isrued by LERO to the public at 1026, nearly one hour after the General Emergency was declared.
ANSWER: First, a news release cannot precede the EBS message which contains the initial information. The interveners j present 1026 as an example of a late posting time at the ENC. Since the EBS message was broadcast at 1026, the posting time would be simultaneous. In such a case, l FEMA believes there is no issue.
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CONTENTION 7.E.4 ISSUE: One hour and 15 minutes. elapsed from the downgrading of
. the emergency classification to the Alert ECL (at 0930 on Day 3)' until the distribution of EBS message #15, announcing that at the ENC.
ANSWER: Based on hard-copy documents available to FEMA, since EBS message #15 was " broadcast" at 1026 on Day 3, according to the intervanor assertions, it was distributed at the ENC 19 minutes after its issuance.
It is FEMA's position that this is satisfactory.
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' CONTENTION 7.F ISSUE: Divergence in the timing of LILCO's news releases and LERO's EDS messages would create confusion for the media.
FEMA does not evaluate the activities of LILCO and does ANSWER:
not have any independent knowledge of LILCO actions concerning public information during the exercise. For FEMA's testimony on LERO- EBS messages, refer to Contention 6. LERO News Releases contain as their primary information the EBS messages and they (news releases) cannot be issued until after EBS messages. In addition, the LERO EBS messages, as discussed in the response to Contention 6 above, were not issued until after they were approved by the FEMA Control Cell.
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L CONTENTION 18 1
ISSUE: The exercise revealed that LERO's communications system f
is not reliable. -
ANSWER: The assertions in the contention only cover a small' i l
fraction of the total LERO communication system. The PEA cites several examples of minor, short-term communications equipment -malfunctions. It is FEMA's position ' that all of -the . malfunctions were adequately compensated'for by the participants during the exercise and had no significant impact on the ability of the LERO.
responders to mitigate the consequences of the O radiological emergency event. It is FEMA's position that this does not factually uset all the criteria'for' a fundamental flaw, because although an~ essential element of the plan is involved, minor or isolated problems on the day of the exercise do not constitute a fundamental flaw in the emergency plan.
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CONTENTION 20 FEMA considers training to be a reviewable planning
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element under NUREG-0654/ FEMA-RED-1, Rev. 1,'Supp. 1 insofar as it is covered under Standard O. FEMA does not have an independent standard exercise objective that.
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deals with training. FEMA's exercise objectives are geared to the evaluation of organizational functions and .
activities implemented in a manner consistent with the organization's emergency plan and procedures.-
It is FEMA's position that inhile there were a number of 'I isolated instances where individual exercise ]
> participants were judged to have inadequately implemented the. plan and where FEMA recommended-additional training as a potential corrective action, on balance, the overall performance was adequate. It is also FEMA's position that there was considerable improvement in the LERO performance-between the 1986 and the 1988 exercises.
1 Given these facts, FEMA's position is that training issues identified in the PEA do not meet the factual criteria to constitute a fundamental flav, in that the
]
training program in the plan does not require j significant revision.
64 1
CONTENTION 20.A
.i g (Includes 19.D, 4.A,_4.B, 4.C.1, 4.C.2, 4.C.3, 4.C.6, 4.C.8, 4.C.9, 4.D, and 4.G)
ISSUE: There were repeated instances demonstrating .that LERO personnel were poorly trained in how to interface with government officials.
ANSWER: It is FEMA's position that the interface between LERO participants and the FEMA Control Cell was virtually continuous throughout the three-day exercise.
Evaluators felt that this interface was very well demonstrated by LERO personnel ~and this objective was !
q met for the plume patihway, ingestion pathway and b recovery / reentry phases of the exercise. Based on the preponderance of the evidence, it is FEMA's position that LERO's ability to interface with the governments was adequate. It should be noted that FEMA also evaluated LERO's capability to interface with potential government officials in the field, through interviews.
The assertion in subpart 4A relative.to the untimeliness
~
of LERO's contact with the State of New York at the Alert ECL is not based upon a correct interpretation of OP.* 7 3 .1. 2. , Attachments 1 and 10, which indicate that the State is only contacted at the Alert ECL if Suffolk
( 65 l
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n County cannot be contacted. LERO contacted Suffolk County (via the FEMA Centrol Cell) at 0547, ( i.e.,
immediately, for all intents and purposes). In
! addition, in every exercise evaluated by FEMA Region II-in New York State, the State has not assumed lead responsibility in decisionmaking from the counties for plume phase play.
With respect to the assertions in subpart 4&C.9, relative to LERO officials incorrectly reporting the Alert declaration as having occurred at 0613, FEMA's Control Cell logs show that this type of call occurred immediately .after LERO officials arrived at the LERO n EOC. In addition, two of three officials who mado the error corrected the erroneous information within 7 minutes in one case and 28 minutes in the other. The third person was removed as a point of contact before l cc,rrecting the error. In any case, since the local school officials rectiving the information already would have cancelled clasces, there would have been no significant impact on the health and safety of the public.
With respect to the assertion in subpart 4B, refer to FEMA's response to Contention 1A concerning the fact that the actual siren failure was not a relevant part of
,O "
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I exercise play. LERO- participants reported- the .l
- \_/ appropriate, pre-arranged exercise information to the. .
FEMA Control Cell concerning-the simulated: failure of 3 t
sirens and deployment of.back-up route. alert drivers.
i Relative to the assertion in subpart 4.C.3, that LERO inappropriately used the term "early dismissal" : as a- fj protective action recommendation at 0600, FEMA's' position is that this term of art was appropriately used. At 0600, LERO officials could reasonably' expect i
that some school children may- have been en route. to schools. Under such conditions, the term of-art "early dismissal" covers both early dismissal and the-l
! cancellation of classes. !
With respect:to the assertion in subpart 4.C.2, refer to l
Contention 6.A.4 for FEMA's position on how LERO addressed ingestion-related problems.
Relative to the assertion in subpart 4G, that LERO failed to consult with New-York State officials before ,
\
extending an ingestion PAR to 50 miles, FEMA's position is that the FEMA Control Cell log does not confirm that the referenced call originated from a LERO decision maker. In addition, LERO complied with the requirements for coordination and approval of PAR's as documented in 67
t 1
i FEMA Control Cell forms where the Suffolk- County-O. executive informed the LERO lead decision maker that he wanted to approve, before release, EBS messages'as well as protective &ction recommendations. According to FEMA Control Cell forms, at 1040 the Suffolk Cohnty executive had concurred in the decision to place eastern Long 4 1
Island animals on stored feed.
With respect to the assertions in subpart 4.D, it is useful to consider that any confusion in the organizational identity of FEMA Control Cell players was not representative of a real event.
l With respect to the assertion in subpart 4.C.1, it ' is j FEMA's position that the FEMA Control Cell was kept well informed on Day 1 that EPZ plume exposure PAG's were predicted to be exceeded. Based on additional documentation that FEMA has reviewed, it is FEMA's position that the information that LERO provided concerning doses comparable to chest x-rays was correct at the time it was given. Furthermore, it'does not have '
any relation to exceeding PAG's.
With respect to the assertion in subpart 4.C.6, we have no reason to dispute the facts asserted. ;
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68
i N .With respect to the assertions in-subpart.4.C.8,-refer to FEMA's responses to. subparts 6.B.5 and 6.B.6.
-With respect to the assertions in subpart 19D, it.is FEMA's position that, on balance, the many communications with the FEMA Control Cell were effective, timely and appropriate. It should be noted that.in addition to the control cell contacts by phone
- documented in the FEMA Control Cell logs, there was a continuous interfacing in person at the Control Cell provided by the LERO liaisons not documented in phone ,
logs. Based on ' interviews with FEMA Control Cell personnel, these liaisons were extremely helpful. It is FEMA's position that LERO could assist and cooperate with State and local governments should those officials follow the LERO offsite plan.
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t CONTENTION 20.C 1-q.
bl .,
l ISSUE: The number of ARCAs in training identified in the PEA indicate that the overaill training of LERO personnel required to implement the plan has not been effective.
ANSWER: The PEA indicates that many of the ARCAs identified during the 1988 exercise reveal the need for additional training of LERO workers. However, it should be emphasized that, as before, many of the participants '
were adequately trained to carry out their emergency roles. Moreover, the results of the 1988 exercise indicate that there has been substantial improvement in :
e i !
U- the training of LERO's workers since the 1986 exercise.
Nevertheless, it continues to be FEMA's position that the training program could be enhanced to further improve LERO's emergency response capabilities.
With regard to the specific ARCAs cited in this contention, it is FEMA's position that the training issues are sufficiently described in the PEA.
Furthermore, it is FEMA's position that each of the issues identified in the PEA are based on separate observations of individuals that were made during the exercise evaluation. It is also FEMA's position that, 70 0
generally, the exercise inadequacies identified in the PEA where additional training is the recommended corrective action, were the result of individual participant errors on the day of the exercise.
Therefore, the ARCAs are not and should not be aggregated to arrive at a more significant level of
. Concern.
0 0
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., CONTENTION 20.D and 20.F t
ISSUE: The exercise demonstrated that LERO personnel were_not adequately trained (1) to communicate necessary data and-information and to inquire and obtain such information or (2) to deal with the media in providing timely, accurate, consistent and non-conflicting information.
ANSWER: FEMA's position on the exercise events presented 'in contentions 6 and 7 is given above. As previously stated, FEMA and the RAC determined that the source of some of the problems was in the procedure for generating
^
EBS messages, OPIP 3.8.2. As a result, this problem was i
' classified as a plan inadequacy and inserted in FEMA's review of Revision 10 of the LILCO plan, issued with the PEA on September 9, 1988. It is logical to assume that ,
l if procedures are changed, training will be required in their implementation.
Further, in its letter of November 21, 1988 to the NRC, ;
LILCO has gone beyond FEMA's suggested changes and has,
~
among other things, committed to revise its EBS ;
procedures to address problems, conduct training for appropriate staff and as a final demonstration, conduct a Public Information Tabletop training drill. On O '2 ;
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______.m__ _ _ _ _ - . . _ _ _ _ _ . _ _ _ _ _ _ _ _ _
December 5,'1988, NRC reques'ted that FEMA review LILCO's O proposed plan revisions and schedule for- corrective
~
actions to address problems cited in the PEA and plan review. FEMA'has not yet completed its review of the proposed actions but will do so as soon as possible.
Subsequently, when FEMA receives.and reviews the actual revised . draft messages, revised procedures, and other corrective measures as appropriate, an evaluation of a
their adequacy can be made.
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73
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l CONTENTION 20.G l
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ISSUE: The exercise demonstrated that.LERO personnel were not adequately trained in emergency worker radiological exposure control measures. l l
ANSWER: FEMA has limited its testimony on the issue of emergency l
- worker radiological exposure control measures because this is an area for which a broad spectrum of emergency workers receive the same type of training. It is FEMA's position that the PEA adequately covers this issue. l However, it should be noted that many ARCAs observed in emergency worker exposure control in the 1986 exercise were corrected even though three (3) new issues were identified- in the. 1988 exercise. The many ARCA's corrected and the limited number of observed new problems strongly indicates that the effectiveness of the LERO radiological exposure control training program has improved over time.
74
%/
Ihor W. Husar A native of Central New Jersey, Mr. Husar entered the emergency preparedness field in April 1979, after working seven years in security and intelligence for DOD, when hired by the Defense Civil Preparedness Agency, New York field office. Serving as a field representative, he was responsible for providing emergency preparedness financial and technical assistance to New Jersey, New York, Puerto Rico and the Virgin Islands.
Mr. Husar has been employed by FEMA since its establishment and has served the New York Regional Office in many capacities. He was Chairman, Regional Assistance Committee (RAC) for State / local response planning surrounding nuclear power plants from 1980 to 1983. He was Acting Division Chief, Plans and Preparedness, and
. has responded to Presidential declared disasters throughout Region II. Mr. Husar performed a support role in the Love Canal emergency, as well as Puerto Rico and New York State hurricane disasters.
Until the position was abolished in June 1986, Mr. Husar was Branch Chief, National Preparedness Programs. He was directly responsible for the management of Government Preparedness (Special Access Programs) and National Preparedness Programs in the region. He was Executive Secretary, Regional Preparedness Committee (RPC) plan development. He also served as Regional Individual Mobilization Augmentee (IMA) Program Coordinator.
Mr. Husar has considerable disaster assistance experience. On October, 1984, Mr. Husar was appointed Interagency Hazard Mitigation Team Leader during the Presidential Disaster Declaration in Hornell, New York. In that capacity, Mr. Husar directed a ten day investigation of flood damage in Steuben and Allegany Counties by a team comprised of Federal agency and New York State officials.
The results of the investigation was a report to the disaster Federal Coordinating Officer providing findings and recommendation regarding non-structural hazard mitigation measures.
In October, 1985, Mr. Husar was appointed the Regional Assessment Chief for the Presidential Disaster Declaration caused by Hurricane Gloria involving flood damage .in several counties of New York State. In that capacity, Mr. Husar evaluated field investigation details and prepared the FEMA assessment of damage and recommendations to the Federal Coordinating Officer.
In June 198N, Mr. Husar served as a FEMA controller in the Federal Full Field Exercise (FFE-2) involving the Zion nuclear Power Station. The federal play in this exercise was the second test of the Federal Radiological Emergency Response Plan (FRERP). Mr.
Husar coordinated and monitored the participation of FEMA responders throughcut the three day exercise.
O
From June 1986 to September 1987, Mr. Husar was Supervisory Natural O
l
.& Technological Hazards Programs Specialist, in the Natural &
D Technological Hazards Programs Division (NTH), and was selected by l
l the Acting Regional Director to serve again as RAC Chairman. Mr. !
Husar was responsible for the day to day oversight of National l Flood Insurance Program (NFIP) in the region as well as technological hazards programs. The latter program area includes off-site safety surrounding commercial nuclear power plants and response planning for peace time radiological accidents (including nuclear weapons accidents) and hazardous materials. In addition, he has retained responsibility for the Regional Emergency Response Team (RERT) Plan.
In October 1987, Mr. Husar was appointed Acting Division Chief, Natural and Technological Hazards Division for the FEMA Region II
. office. Mr. Husar was the lead FEMA witness in LBP-88-13 held in June 1988, testifying on the adequacy of LILCO's offsite emergency planning. On April 3, 1988, he was promoted to that position. As Division Chief, Mr. Husar is responsible for supervising the programs described above. Mr. Husar has retained the position of RAC Chairman, to which he was reappointed in August, 1986.
Mr. Husar graduated from Rider College, Lawrenceville, NJ, in 1967 with a Bachelor of Arts degree in Secondary Education (History).
He has ' completed pre-candidate work for a Masters in Business Administration degree with Southern Illinois University.
In 1984, Mr. Husar was nominated . for and completed Executive
( Management training at the Executive Seminar Center, Kings Point, j NY. He has been the recipient of several awards during his career in the Federal government.
Mr..Husar is a Vietnam veteran, having served four years on active duty as an Army Intelligence officer. He is currently a Lieutenant ;
Colonel in the US Army Reserves. l He presently resides in Marlboro, New Jersey, has been married 19 years, and is the fatter of six children. ;
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JCSEIH H. IG1IER PNNESSICNAL OQALIFICATICNS Education:
mehalar of Science in Chemistry, Washigten College, Chastartown, MD, 1956.
Master of Science in IrmA Chemistry, Pennsylvania State University, University Park, PA, 1958.
Graduata Assistant in Chemistry, Pennsylvania State University, University Park, PA, 1958-61.
Professional Positicns: 1961-1966 Assistant Professor of Chastistry Lt Idaho State University, Pocatello, ID. Respmsibilities included +=ch4g courses in freshman h4atry, quantative analysis, instrumental analysis, advanced irmA chemistry and 1ctoratory rM4*=4atry.
<s 8/66 - 10/73 .
Employsd a't the Idaho Naticnal Egineerig LaLmatcIy in Idaho Falls, ID (then called the National Reactor Testig Station) .
Ths site is gew-it owned and ad=4N by the nyam of Energy Research and Devel w it Agency. I was employed by one of the operatig contractors, initially Idaho Nuclear Corp.
followed by Allied ch=4c=1 Corp. My position was a technical cna in the research a1x1 develwit area of fission product behavice and r# des.
10/73 - 6/74 Employed ~as research scientist by Nuclear Enviu-ital Services divisicn of SAI, Inc., Idaho Falls, ID. respcasibilities included ed support cm performance gaamia rad waste s -:
c ==4ng aqn4M in a BWR and analysis of sources of inplant radiaticn vmn to wamu. .
6/74 - 12/78 Employed as scientific and engineering supervisor by Allied Craical Caraticn at the Idaho National Engineering Iatw.atcry. Raspcasibilities imi via4 supervision of a research laboratcry involved with analysis of fission product levels in 1 %.ted nuclear fuel s=c4=:s and analysis of the fissien prcduct content of samples of the worlds 1st known natural fissicn reactor and the supervision of an analysis laboratory for O erh-it.41 samples.
NBC.
Carv'n+M centract r= art:h in support of
12/7s - present Employed as 4-+4=t by Allied hir=1 cczp., Born Nuclear Taahn co., Inc., (after 7/3/79), and W_= Idaho Nuclear ccupany, Inc. (after 3/1/s4), at the Tdabe National EncJ neerincJ i h4r.grf. Respcms4_h414 ties incitsis research and devoled, ocntract ?_-eat to NRC and FEMk.
Attended FDR orientatica trm4Mm ocurse cm PM4alagical Eastgency R-,--lei - Planning for DOE Ozitract Porsconal. 4 Experience: .
A Prove existance of previously tau.wdzad =4* 2us radiciodina species to be hypniMas acid. !
Developed sampling device to differentiate Man h4=1 forms of airbcas rM4a1M4=. :
Developed iru w.ic adarw+=st to retain =4*-_me radioicdina.
Measured gaseous f4==4e=1 perv**+= in effluents and process l c
streams in 5 BNR's staties.
Perfnmed effluent and environmental measurements to assess -
iM_irc p n ilk dose p M f at BNR's.
i Moda effluent and envircemental measurunents of rad 4aiMina at a cha**1 cal plant to assess envium
- 1 4W.
Analyzed fuel = par 4==1s to determine accurately the fission yields in the fast flux region of the neutztm ep Lam.
Analyzed faal =p -4==ns to es+=h14=h breeding or conversion ratio in 21-U fuels frcat the light water breeder program.
Developed a m14ng device for =47eus 14 C and3H in nuclear plant affluents and process streams.
Participated in enviam dal program to measure movement of radicam14d== through process a? M in PWR's so that the 4
pr=44r+1ve models can be evaluated.
Respcosible for t=<h4r =1 avaluatica of > ---@ BiR off-gas I systems.
Evaluated applicability of off-sita, real-time instrumentation to da+ amine the magnitude of unmanitored releases in accident situaticrs.
.y,
, y
(
Evaluated soil to v.pMHm transfer of stable casium ard strentita.
Reviewed current state of knowledge en v-gaxy in the ,
envircrament ai*rmis m44aiad4= by rain ce snow.
Td4f4-4 as FEMA witness at Indian Point ard Shoreham ASIB hearing.
Adjunct *=-414ty member at FEMA Eastguncy Management Institute. .
Publications: -
J. H. Kaller, F. A. Duca, and F. O. Cartan, "Ratantien of Iodina m Selected Particulate Filters and a Porcus Silver Membrana Being censidered for the IOPT Maypeck", IN-1078, May 1967 W. J. Maack, D. T. Ponce, and J. H. Kaller, "A Highly Efficient L ,mic h for Airborna Icdine ap=-4== (Silver Zeolite)
Develoguent Studias", IN-1224 Octcher 1968 R. L. Nebehme, J. H. Kaller, L. T. Iaksy, D. E. Black,
%. W. P.. Pelica, and R..E. Sd11ndler, "Cbntairunent Behavice of Xancn
< . and Iodine Utider sina21stad IesM-coolant Accident Ctrditions in the c - : - 4 h- - - : - i=*4 = W==**, IN-1394, . June 1971 B. Weiss,' P. G. Voillaque, J. H.10 aller, B. Enhn, H. L. gger, A. Martin, and C. R. Ph4114=, "DePallad Measurements of I in Air, V,Laticri, and Milk Around 22rea operating Reactor ;
Sitas", NCRIID-75/021, March 1975 -l>
W. J. Maack, F. W. W_1*=, R. L. Trm p, and J. H. Kaller,
" Analytical Results, PN Nuclear Q:mstants ard suggestad !
Cbrr=1=+4N for the Evaluaticr1 of CKIO Fissim Product Data", at IAEA Internaticmal Syngositua en the Oklo Phancanencrt, Libarville, Gabon, IAEA-SM-204/2, June 1975 W. J. Maack, W. A. Emel, L. L. Dickersen, J. E. Delacre, J. .H. and R. L. Trtap, " Dim @.ias and i Kaller, Regarding E. A.2p,tiermal Pu Fissicri Yields and the Use of as a Ek2rnup Mcnitar", ICP-1092, h 1975 N. D. Dyer, E. B. N=4 =+=4rk, J. H. Kallar, ard B. G. Motas,
" Procedures Sourca Term Measurement F% ", TREE-1178, ,
l October 1977 N. D. Dyer, J. H. Keller, R. L. Bunting, B. G. K:rtas, S. T. Cranny, D. W. Akers, C. V. McTanac, T. E. Ccoc, i R. L. Kynasten, S. W. Duca, D. R. Underwood, J. W. Tkachyk, "In-Plant Source Ter:n Measurements at Ft. ca1Mm Statien-Unit 1", NURED/CR-1040, July 1978 I
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J. L. ".21cupsen, S. W. Duca, and J. H. Kaller, "An F -- 2 aic
- Tritita and Carte-14 Manitcring Systant", NOREG/CR-0386, V*r .
1978 .
N. C. Dyer, J. H. Kallar, R. L. Bunting, B. G. It:rt:as, S. T. Creney, D. W. Akers, C. V. )t:: Isaac, T. E. Ocz, R. L. Kyrs t.wi, S. W. Duca, D. R. Underwood, J. W. 'Dcachyk, "In-Plant source Tazz Measurements at zicra Station",
, NOREG/CR-0715, MW 1979 J. J. Kaller, L. W. McClure, M. Hoza, A. - L. Ayurs Jr. , R. I.o, and L. W. Barrutt, "Beiling Water Reactor off <jas Systems Evaluation", NUREG/CR-0727, June 1979.
R. W. Benedict, A. B. Christansen, J. A. Dal Debbio, J. H. Kaller, and D. A. Enacht, "Pr'oe4=1 and Ecmaic Fansih414ty of Zeolite E- ; =ilaticra for Krypt:crt-85 Storage", ENICIM1011, September 1979 J. H. Kaller, B. G. Metas, D. W. Akats, T. E. Car, S. W. Duce, and J.. W. 'Dachyk, "Mansurement of Xe-131, C-14 and Tritium in Air and I-131 V+;-tJim and Milk Arcund the Quad Cities Nuclear Power Statimt", NOREG/CR-1195, ENICD-1023, )ttrch 1900 7
h?
'v '
J. W. Mandler, S. T. Cetzisy, N. C.. Dyer, C. V. McIsaac, A. C. Stalker, B. G. Mates, J. H. Enller, T. E. Ckac, D. W.. Akers, J. W. 'Diact2yk, and S. W. Duos, "In-Plant Source Tara Measurements at Tuthey Point Shation - Units 3 and 4", NOREG/CR-1629, September 1980 P. G. Va411eque, B.10thn, H. L. Kruiger, D. M.18:rttagonary, J.. H. Kaller, and B. H. Waims, guaticut of the Air-Vy; t.icn-Milk Pattany for I at the Quad Cities Nuclear PcWur Staticrt", NUREG/CR-1600, Novuuber 1981 W. J. Maack, L. G. Hoffman, B. A. Staples, and J. H. Kaller, "An h W of Offsita, Baal-Time Does Mansurement Systems for
. InnariJ:ancy Sitcatimis", NOREG/CR-2644,11NICD-1110, April 1982 L. G. Hoffman and J. H. Kaller, "h-3 <M4m of Soil to Plant Transfer coefficients for Stable casium and 5Lma.ium",
NCRI!G/CR-2495, ENICD-1105, June 1982 P. G. Voilleque, L. G. Hoffman, and J. H. Kaller, "Wat narrwition PIcoasses for Radiciodinas", NURIIG/CR-2438, ENICD-1111, August 1982 B. J. M "- r cn, o L. G. Hoffman, R. J. Honkus, and J. H. Kaller,
" Guidance en offsite E ms cf Radiation Measurement Systams -
Phase 2 - Milk Pathway", WINCD-1009, April 1984
W. J. -)tiack, R. J. Ecmkus, J. H. Faller, aM P. G. Voilleque, .
"T=F-- r ey Measurements of Paramstars affecting Wet Depositicut of Methyl Iodida", NOREWCR-4041, WINCO-1023, Septauber 1984 B. J. Salacnson, L. G. MMYann, . R. J. Mcmkus, aM J. H. Faller,
" Guidance at offsite Emergency Radiation Measurement Systems -
Phase 3 - Matar and Non-Dairy Food Pathway", WINCO-1012, October 1984
- B. .J. Salacmscrl, R. J. Henkt:s, and J. H. Faller, " Guidance en offsits h ,01 Radiation Measurement Systems'- B ase 1 -
Ai h e Release", FDBM2 (Rev.1), WINCD-1029, namnhar 1985
.?
Papers:
F. O. Cartan, H. R. Board, F. A. Duce, and J. H. Faller, " Evidence fee the Existance.of Hypoidous Acid as a Volatile Iodine Species Produced in Matar Air Mixtures at Tur*h AEC Air M==nf2m Ocmference, New York, NY, ?='M 1968, M 680821 J. H. Faller, F. A. Duce, D. T. Ponce, and W. J. Maack, "Hypoidous Acid: An Ain us Lepiic Iodine apar 4M in Staast-Air Mixtures ;
at Eleventh AEC Air Cleanim Conference. Ri+1mnd, M, i
$eptember 1970, CCMF 700816 J. H. Faller, F.. A. Dum, and W. J. leneck, "A Selective Mem4 wit
7149 g for Differentiating Aih. .e Iodine F4a= at Eleventh AEC Air Cleanim Cmference. - Pi+1mnd, M, Segf=niw 1970, CIEF 700816 J. H. Faller, T. R. 2xzmas, D. T. Ponce, and W. J. Maack, "An Evaluation of 18tterials and W_ir- Used for Mczlitoring Air-Borne PadiciM4w apar ima at Tt.=1fth AEC Air M eanincr Ocnference, Oak Ridge, DT, August 1972, CCNF 720823 J. H. Faller, T. R. Dxznas, D. T. Pence, W. J. Maack, " Iodine Chemistry in Stasa Air Ah--f- .e at Fifth Arrm=1 halth Physics _
Society Midyear Svsposium. Idaho Falls, ID, November 1970 J. H. Faller, L. L. Dickerscri, F. W. Spartkas, and W. J. Maeck, Determinaticr1 of the Natural Abundance of Krypton in the Ah- -p - . at Am. &=n- ce. Mv laar &=n4 =try and %+ncicey l Division Meeting, Newport Beach, CA, February 1973 J. H. Faller, " Iodine *=-faa Measurements", invited paper at Mv 1==* Safety Analysis cantar LM= en Iodine Relamama in Reactor Accidents, Palo Alto, CA, November 1980 l
gl .GVoilleque and J. H. Faller, "Alr-to-Vegetation Tmieport of I as Hypoiodcus Acid", Health Physics 40, p 91-94,1981 O
O' J. H. Faller and L. G. Hoffman, "Fu,-::d Federal Guidance cm Emergency It:nitcring in the Milk Pathway", at 13th Anrnaal National ?
Ccnference cm PM4*4m G ha, Little Rx:k, AK, May 1981 i
J. H. Fallar, "Updata en Radioicdina Manitoring", at the 14th Annual National Cmference m Radiatica Ocmtzol, Portland, MA, May 1982 J. H. Kaller, "Iodina M14% Under h e fcCanditions",
e invitari paper at IE22 Nuclear Science Sy-4tm, Orlando, FL, November 1984 O
e f
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ m
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
, y 9.r p:"
' Q'
(( BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'89 ER -3 P4 :05
)
. In the Matter of )
) Ort u .
"I LONG ISINND LIGHTING COMPANY ) Docket No. 50-322-OL-5R EIhjg
)
(Shoreham Nucle'ar Power Station, )
Unit 1) .)
)
r CERTIFICATE OF SERVICE I hereby certify that copies-of " FEMA's.Prefiled Testimony dated March 1, 1989" in the above-captione,d proceedings have been served on the following by deposit in the United States mail, first class, this 1st day of March 1989, or were served this date upon the following by Federal Express as indicated by an asterisk, or by hand delivery.
John H. Frye, III, Chairman
- Adjudicatory File Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Docket East-West Towers, Fourth Floor U.S. Nue16ar Regulatory Commission 4350 East-West Hwy. Washington,.DC 20555
/D Bethesda, MD 20814 j
.(,,/ Edwin J. Reis, Esq.
- l Dr. Oscar H. Paris
- U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board One White Flint North U.S. Nuclear Regulatory Commission 11555 Rockville Pike East-West Towers, Fourth Floor Rockville, MD 20852 4350 East-West Hwy.
Bethesda, MD 20314 Lawrence Coe Lanpher, Esq.
- Karla J. Letsche, Esq.
Mr. Frederick J. Shon
- Kirkpatick & Lockhart Atomic Safety and Licensing Board South Lobby - 9th Floor U.S. Nuclear Regulatory Commission 1800 M Street, N.W.
East-West Towers, Fourth Floor Washington, DC 20036-5891 4350 East-West Hwy.
Dethesda, MD 20814 Fabian G. Palomino, Esq.
- Richard J. Zahnleuter, Esq.
Secretary of the Commission Special Counsel to the Governor Attention Docketing and Service , Executive Chamber, Room 229 Section State Capitol l U.S. Nuclear Regulatory Commission Albany, NY 12224 Washington, DC 20555 Alfred L. Nardelli, Esq.
Atomic Safety and Licensing Assistant Attorney General l
Appeal Board Panel 120 Broadway U.S. Nuclear Regulatory Commission Room 3-118 Washington, DC 20555 New York, NY 10271 l-l .
[
l l
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( W. Taylor Reveley, III, Esq.
- Ms. Nora Bredes
) Executive Coordinator k/ Scott D. Matehett, Esq.
Hunton & Williams Shoreham Opponents' Coalistion 707 East Main Street 195 East Main Street P.O. Box 1535 Smithtown, NY 11787 j Richmond, VA 23212 Evan A. Davis, Esq Mr. Phillip McIntire Counsel to the Governor Federal Emergency Madagement Agency Executive Chamber 26 Federal Plaza State Capitol New York, NY 10278 Albany, NY 12224 m
Mr. Jay Dunkleberger C. Thomas Boyle, Esq.
New York. State Energy Office Suffolk County Attorney
_d Agency Building 2 Building 158 North County Complex Empire State Plaza Veterans Memorial Highway Albany, NY 12223 Hauppauge, NY 11788 Stephen B. Iatham, Esq. Dr. Monroe Schneider Twomey, Latham & Shea North Shore Committee i 33 West Second Street P.O. Box 231 P.O. Box 298 Wading River, NY 11792 Riverhead, NY 11901 Jonathan D. Feinberg, Esq.
New York State Department of
[ Public Service, Staff Counsel V} Three Rockefeller Plaza Albany, NY 12223 m
, ~n a f. f& w= j #
William R. Cumming Federal Emergency Management Agency 500 C Street, S.W.
I Washington, D.C. 20472 Dated: March 1, 1989 i
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