ML20235V630

Testimony of F Kantor,Em Podolak & Rt Hogan of NRC Staff on Scope of Exercise.* Purpose of Testimony Is to Rebut Testimony of Intervenors Re Contention 1

ML20235V630
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/01/1989
From:	Hogan R, Kantor F, Podolak E Office of Nuclear Reactor Regulation
To:
Shared Package
ML20235V611	List: ML20235V608 ML20235V630 ML20235V649
References
OL-5, NUDOCS 8903100261
Download: ML20235V630 (55)

Text

i 03/01/89 9'

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!! W-y UNITED STATES OF AMERICA 89 tiAR -2 P1 :58 NUCLEAR REGULATORY COMMISSION OFU. . e .

00cn n"'y *,,,, e... r BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Mutter of LONG ISLAND LIGilTING COMPANY Docket No. 50-322-OL-5R

) (EP Exercise)

(Shoreham Nuclear Power Station, )

Unit 1)

TESTIMONY OF FALK KANTOR, EDWARD M. P0D0LAK, JR.

AND ROSENARY T. H0GAN OF THE HRC STAFF ON THE SCOPE OF THE EXERCISE

.I Q1. Please state your name and position at the NRC.

A1. My name is Falk Kantor. I am employed by the U.S. Nuclear Regulatory Conmiission as a Section Chief in the Emergency Preparedness Branch, Office of Nuclear Reactor Regulation. A copy of my professional quali-fications is attached.

Q 2,. Please state your name and position at the NRC.

A2. My name is Edward M. Podolak, Jr. I am employed as a Senior Emergency l

Preparedness Specialist in the Emergency Preparedness Branch, Office of Nuclear Reactor Regulation. A copy of my professional qualifications is attached.

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Q3. Please state your name and position at the NRC.  !

A3. My name is Rosemary T. Hogan. I am employed as an Emergency Preparedness l Specialist in the Emergency Preparedness Branch, Office of Nuclear Reactor  ;

Regulatory. A copy of my professional qualifications is attached. I i

l Q4. What is the purpose of your testimony?

A4. The purpose of our testimony is, in conjunction with the testimony provided by Federal Emergency Management Agency (FEMA), to rebut the j testimony of the Interveners regarding Contention 1.

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QS. Please state the general allegation of Contention 1.

A5. The basic allegation of Contention 1 is that the June 7-9, 1988 exercise i of LILC0's offsite emergency response plan for Shoreham was tno limited in scope to comply with NRC regulatory requirements, particularly 10 CFR Part 50, Appendix E, $1V.F.1. The Interveners allege that the exercise did not I test major observable portions of LILC0's plan and tested other portions insufficiently to allow verification of response capabilities. ~

1 Q6. What is the purpose of the pre-licensing, i.e., qualifying, emergency l preparedness exercise?

A6. The purpose of the pre-licensing emergency preparedness exercise is to determine that there is reasonable assurance that the radiological emer-gency response plans for a facility can be implemented.

I' Q7. What are the regulatory requirements regarding the scope of a pre-license l

emergency preparedness exercise?

A7. The regulatory requirements regarding the scope of an exercise are given in 10 CFR Part 50, Appendix E, SIV.F. which states:

" Exercises shall test the adequacy of timing and-content of

' implementing procedures and methods, test emergency equipment  !

and communications networks, test the public notification system, and ensure that emergency organization personnel are familiar with their duties."

In particular, 91V.F.1 provides:

A full participation exercise which tests as much of the licensee, State and local emergency plans as is reasonably

-achievable without mandatory public participation shall be conducted for each site... This exercise shall... include participation by each State and local government within the plume exposure pathway EPZ and each State within the 3 ingestion exposure pathway EPZ...

• " Full participation" when used in conjunction with emergency .

preparedness exercises for a particular site means appropriate {

offsite local and State authorities and licensee personnel j physically and actively take part in testing their integrated r i

capability to adequately assess and respond to an accident at a commercial nuclear power plant. ' Full participation' includes '

testing the major observable portions of the onsite and offsite emergency plans end mobilization of State, local and licensee personnel and other resources in sufficient numbers to verify the capability to respond to the accident scenario.

And, in 61V.F.6 of Appendix E:

The participation of State and local governments in an emergency exercise is not required to the extent that the applicant has identified those governments as refusing to participate further in emergency planning activities, pursuant to 10 CFR 50.47(c)(1).

In such cases, an exercise shall be held with the applicant or licensee and such governmental entities as elect to participate in the emergency planning process.

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Q8. What is the NRC staff position regarding the number of FEMA objectives to be evaluated for a " qualifying" full participation exercise, i.e., for a

! pre-licensing exercise?

i A8. The NRC position is that essentially all of the FEMA exercise objectives l

which are reasonably achievable should be demonstrated for the pre-licensing exercise.  !

09. What guidance documents exist regarding the scope of an exercise?

A9. FEMA Guidance Memorandum EX-3 " Managing Pre-Exercise Activities and Post-Exercise Meetings" dated February 26, 1988 (Attachment A), addresses the scope of an exercise. In this document FEMA lists 36 exercise objectives which functionally restate the intent of those evaluation criteria in HUREG-0654/ FEMA-REP-1, Revision 1, that can be demonstrated and observed in exercises. FEMA GM EX-3 was coordinated with and con-curred in by the NRC.

GM EX-3 was amended in a FEMA memorandum dated March 7, 1988 (Attachment B),

to accomodate the testing of utility offsite plans in qualifying exercises.

Amended GM EX-3 is intended to facilitate the implementation of 10 CFR -

Part 50.47(c)(1) and Appendix E, 61V.F, and the associated guidance in the form of evaluation criteria in Supplement 1 to NUREG-0654/ FEMA-REP-1, Revision 1. Both amended GM EX-3 and Supplement 1 to NUREG-0654 were developed jointly by the FEMA and the NRC.

Amended GM EX-3 states that since the purpose of the quslifying exercise

is to test as much of the emergency plans and preparedness as is ,

i reasonably achievable, without State and/or local participation, the l utility should demonstrate a total of 36 exercise objectives. This l consists of 35 of the 36 existing exercise objectives in GM EX-3 , plus an additional objective (37) that addresses a unique evaluation criteria of i Supplement-1; i.e., an objective to demonstrate the capability of utility offsite response organization personnel to interface with non-participating State and local governments.

Q10. Are all of the 16 planning standards of 10 CFR 50.47(b) related to at least one of the 36 exercise objectives?

A10. No. Planning standards 10 CFR 50.47(b)(15) and (16) which refer to the l training program and to the responsibilities for plan development are f not covered by FEMA exercise objectives because they are not directly demonstrable or observable in an exercise. (Lack of sufficient training may be cited as a cause for not meetirg other objectives, however, the training program is not directly observed during an exercise.) All of the other planning standards in 10 CFR 50.47(b) are related to at least one or more of the exercise objectives.

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A correlation of the planning standards with the exercise objectives of FEMA GM EX-3 (amended) is as follows:

• Objective 36, unannounced off-hours exercises and drills does not apply to a qualifying exercise.

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PLANNING STANDARD FEMAGMEX-3(AMENDED) 10 CFR 50.47(b) EXERCISE OBJECTIVE Assignment of Responsibility 3, 34, 37 Onsite Emergency Organization 35 Emergency Response Support 26, 28, 37 Emergency Classification System 1 Notification Methods and Procedures 2, 12, 13, 37 i Emergency Communications 4, 37 Public Information' 5, 13, 14, 15, 37 Emergency Facilities & Equipment 5 Accident Response 7, 8, 9, 10, 27, 29 (10)ProtectiveResponse 16, 17, 18, 19, 20, 21, 22, 27, 28, 29 ,30, 35, 37 i (11)RadiologicalExposureControl 6, 25 Medical Support 23, 24 Recovery _ and Reentry 31, 32, 33, 37 Exercises and Drills 1-35, 37 (15) Emergency Response Training --

(16) Responsibility for the Planning Effort --

i Q11. Did FEMA seek NRC's concurrence regarding the scope of the Shoreham exercise?

All. Yes. FEMA correspondence dated May 13, 1988, between Richard W. Krimm, i FEMA and Frank J. Congel (Attachment C), NRC requested NRC comment on the sufficiency of the FEMA proposed objectives for the Shoreham qualifyirig i

exercise. FEMA proposed to use all of the exercise objectives of amended GM EX-3 except for Objective 17, Objective 22, and Objective 36.

Objective 17 refers to the ability to make the decision, if the State plan so specifies, to recommend the use of potassium iodide to the general public. This objective was not demonstrated because the distribution and administration of potassium iodide to the general public is not a protec-tive action option in the State of New York.

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i Objective 22 refers to the demonstration of the adequacy of congregate care facilities. This was not demonstrated because the American Red Cross '1 did not participate in the exercise. The Commission, in CLI-87-5, 25 NRC 884(1987), recognized that the American Red Cross charter from Congress I and its_ national policy require it to provide aid in "any radiological or natural disaster," whether or not there are letters of agreement in connec-tion with a particular emergency plan. The NRC staff position is that the American Red Cross responds to natural and technological disasters as a routine and that it is not necessary to demonstrate this capability in a exercise if they decline to participate.

Objective 36, unannounced and off-hours exercises, as indicated previously, is not a requirement for a qualifying exercise.

Q12. How did NRC respond to the FEMA request?

A12. NRC responded to FEMA in a memorandum dated May 20, 1988 (Attachment D) that:

"We agree that the proposed objectives are sufficient to demonstrate the capabilities of the Long Island Lighting

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Company Local Emergency Response Organization (LER0) in a full participation exercise. Specifically, we believe that these objectives are sufficient to constitute a " qualifying" exercise under 10 CFR Part 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."

This conclusion was reiterated in an NRC memorandum to FEMA dated May 26, 1988 (Attachment E).

C Q13. What was the basis for the NRC staff conclusion regarding the sufficiency of the Shoreham exercise objectives?

A13. The NRC staff conclusion was based upon a review of the FEMA proposed exercise objectives in their May 13, 1988 correspondence using for guidance the exercise objectives in FEMA GM EX-3 and its amendment, and the evaluation criteria in NUREG-0654/ FEMA-REP-1, Rev.1, Supplement 1.

The fella proposal for the exercise included demonstration of the applicableplanningstandardsin10CFR50.47(b)andaccordingly constituted a full participation exercise as required by 10 CFR 50, Appendix E, $1V.F.1. The exercise objectives'provided for a demonstration of the major observable portions of the plan that were reasonably achiev-able as required by the regulation.

Q14. Regarding the exercise which was conducted at Shoreham on June 7-9, 1988, what is your response to the Interveners' allegations that the LILC0 public notification system was insufficiently tested, that the testing of school preparedness was deficient in scope, and that the testing of special facility preparedness was inadequate?

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.l A14. We have reviewed the FEMA Post-Exercise Assessment (PEA) report concerning the accomplishment of the exercise objectives related to the testing of the public notification system, school preparedness, and special facility preparedness. The demonstration of public notification methods and procedures is discussed primarily in relation to Objectives 12 and 13 on i pages 44, 45, 50, and 69 of the PEA. The demonstration of school prepared-ness is discussed primarily in relation to Objective 19 on pages 47, l

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i 102 and 110 as well as on pages 85, 105 and 113 of the PEA. The demonstration of specini f acility preparedness'is discussed primarily in relation to Objective 18 on page 46 for the E0C,_and on pages 73, 75, -

I 80, 82, 86 and 88 for each of the staging areas and the transfer points as well as on pages 85, 105, 110 and 112 of the PEA. 'The demonstration of 4 related activities such asLemergency management and protective action decisionmaking are discussed primarily on pages 41 to 48 of the PEA.

Based on our review of the findings and determinations of FEMA in the PEA' report, we concisde that the public notification system, school prepared-ness, and special facility preparedness were adequately tested.

Q15. Does the hRC consider the exercise which was conducted at Shoreham on June 7-9, 1988, to have met the requirements of the regulations, in particular 10 CFR 50, Appendix E, SIV.F.1, for a full participation exercise that provided for a demonstration of the major observable portions of the LILC0 offsite emergency plan that were reasonably achievable?

A15. Yes. The basis for the NRC conclusion is (1) that the objectives of the 1988 Shoreham exercise provided for a demonstration of the major observable ~

portions of the plan, and (2) the findings and determinations of the FEMA evaluation of the exercise. FEMA concluded in a report to the NRC dated September 9, 1988 (Attachment F): j

" ...the exercise demonstrated adequate overall preparedness on the j part of LER0 personnel, and therefore, based on the evaluation of the l plan and the exercise, and the recommendation of FEMA Region II, FEMA has reached a finding of reasonable assurance."  ;

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.c The NRC has reviewed the September 9, 1988 report from FEMA including the FEMA evaluation of the Local Offsite Radiological Emergency Response Plan for Shoreham and the FEMA Post-Exercise Assessnient report. The NRC agrees with the FEMA conclusion. We believe the fella report fully supports the j finding that'the Shoreham emergency plan is ade,quate.and.there is l reasonable assurance that it can be implemented.

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- FALK KANTOR EMERGENCY PREPAREDNESS BRANCH DIVISION OF RADIATION PROTECTION AND EMERGENCY PREPAREDNESS OFFICE OF NUCLEAR REACTOR REGULATION PROFESSIONAL QUALIFICATIONS I am employed as a Section Chief in the Emergency Preparedness Branch, Division of Radiation Protection and Emergency Preparedness, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. I have responsibility for supervising the review and evaluation of radiological emergency plans submitted by reactor applicants and licensees to ensure proposed plans meet the regulatory ]

requirements and guidance of the Commission. I also function as a team member j on emergency preparedness inspection teams engaged in the observation and i evaluation of nuclear power plant emergency drills and exercises. I have been i involved in the assessment of emergency planning and preparedness for nuclear power plants since March 1981.

I have been a member of the NRC (AEC) Staff since January 1973. From that time until June 1980 I held the position of Site Analyst in the Accident Analysis Branch. My duties included the review and evaluation of the radiological consequences of postulated design basis accidents, the effectiveness of pro-posed engineered safety features, the population density and growth character-istics in the site environs, and the possible adverse effects on plant safety of nearby industrial, transportation and military f acilities. From September 1980 until March 1981 I was a member of the NRC's onsite technical support section at the Three Mile Island facility. I have participated in the detailed review of over thirty nuclear power plant sites with the primary objective being to ensure public health and safety through the application of Commission regulatory requirements and guidance on reactor siting. I have presented testimony on siting and emergency preparedness issues at public hearings on the licensing of nuclear facilities, including Shoreham, and I have appeared before the Advisory Committee on Reactor Safeguards.

I entered graduate school in 1967 at the University of Pittsburgh on a  !

U.S. Public Health Service Fellowship and received a MS degree in 1968 in '

RadiationHealth(HealthPhysics). Following graduation I was employed by the NUS Corporation in Rockville, Maryland, and engineering and environmental consulting organizatSn. At NUS I was involved in the environmental aspects of siting both nuclear and fossil power plants. -

In 1963. I began employment with the Westinghouse Electric Corporation at the Bettis Atomic Power Laboratory in Pittsburgh, Pennsylvania. My duties included the design of radiation shielding for nuclear power reactors for both landbased and shipboard applicants. I participated in field tests at Federal reactor facilities to evaluate the effectiveness of shield design features on operating reactors.

I received a BS degree in Industrial Engineering in 1958 from the Pennsylvania State University. Upon graduation I entered the U.S. Air Force where I attended the Basic Meteorology Program at St. Louis University in St. Louis, Missouri. Following the completion of this program in 1959, I served as a weather officer in the U.S. Air Force.

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_in addition to my formal education, I have attended training courses sponsored by the NRC on reactor systems and operation and emergency preparedness. In 11ay of 19791 attended the course titled " Planning for Nuclear Emergencies" at Harvard University and in September 1980 I participated in the Radiological Emergency Response Operations Training course at the Nevada Test Site.

I am a inember of the Health Physics Society. I was a member for 25 years of the National Guard otid currently am a member of the U. S. Coast Guard Auxiliary.

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. . EDWARD M. P0DOLAK, JR.

l EMERGENCY PREPAREDNESS BRANCH DIVISION OF RADIATION PROTECTION AND EMERGENCY PREPAREDNESS '

OFFICE OF NUCLEAR REACTOR REGULATION PROFESSIONAL QUALIFICATIONS l

I am a Senior Emergency Preparedness Specialist, tmergency Preparedness Branch, Division of Radiation Protection and Emergency Preparedness, Office of Nuclear i Reactor Regulation, U.S. Nuclear Regulatory Commission.

In 1968 I graduated from Manhattan College, New York with a Bachelors of Science in Physics. I have taken numerous technical and management courses sponsored by the government.

From 1985 to date I have served as senior branch analyst and spokesperson responsible for major emergency preparedness issues affecting commercial nuclear power. I am the principal day-to-day liaison with FEMA and have served on three joint Task Forces with FEMA staff including one that developed Supplement 1 to NUREG-0654. I also coordinated NRC's review of FEMA documents including regulations and guidance memoranda. J l

From 1982-1985 I was Chief, Program Planning and Support Branch, Office of i Nuclear Regulatory Research, where I was responsible for long-range planning, l project monitoring and control, resouro management and administrative manage- '

ment for the office.

l From 1981-1982 I was Technical Assistant to the Director, Division of Health Siting and Waste Management, Office of Nuclear Regulatory Research, where I-cssisted the director in planning and evaluating research and standards programs 3 for radiological health, environmental protection, earth sciences and nuclear I waste management.

From 1975-1981 I was a Health Physicist and Senior Health Physicist in the~ )

Office of Standards Development developing regulations and policies for the j physicians use of radioactive materials on patients. )1 from 1970-1975 I worked for the Environmental Protection Agency and the Food and Drug Administration at the Northeastern Radiological Health Laboratory in Winchester, Massachusetts, calibrating low-level radioactivity standards and testing radiopharmaceuticals.

From 1968-1971 I coordinated and monitored the Reliability and Maintainability programs for the U.S. Navy Missile UHF Telemetry conversion programs while working for VITR0 Laboratories in Silver Spring, Maryland.

I have published in journals or presented papers before the American Nuclear Society, Journal of Clinical Engineering, Health Physics Society, and the Journal of Nuclear Medicine.

ROSEMARY T. H0GAN EMERGENCY PREPAREDNESS BRANCH DIVISION OF RADIATION PROTECTION AND EMERGENCY PREPAREDNESS OFFICE OF NUCLEAR REACTOR REGULATION PROFESSIONAL QUALIFICATIONS I am an Emergency Preparedness Specialist in the Emergency Preparedness Branch, Division of Radiation Protection and Emergency Preparedness, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.

In 1975, I graduated from Nazareth College in Kalamazoo, Michigan with a Bachelors of Science Degree in Chemistry and have taken graduate work in Toxi-cology at the University of Pennsylvania, Philadelphia. I have taken numerous technical courses related to my positions. i From 1984 to the present, I have served as an emergency preparedness special-ist. In my position I am responsible for coordinating NRC headquarters interface with the emergency preparedness inspection program for NRC Region I.

I am the primary emergency preparedness reviewer for Shoreham and all non-power reactors. I coordinate with FEMA to monitor the status of FEMA reviews of offsite emergency plans and exercises. I function as a team member for emer-gency preparedness appraisals, inspections and exercises to support the NRC Regions.

From 1983 to 1984, I was a radiation specialist in NRC Region I. In that capacity I conducted inspections in the areas of environmental monitoring, transportation of radioactive materials, emergency preparedness and chemistry at nuclear power reactors.

From 1975 to 1983, I worked for Radiation Management Corporation' in Philadelphia. From 1982 - 1983, I was the Manager of Quality Assurance and was responsible for assuring that all aspects of the program were followed including audits, training, procurement, laboratory activities, procedure preparation and review, document and equipment control.

From 1979 to 1982, I was assigned to project management. In this position, I was responsible for the day-to-day management of environmental surveillance programs at nuclear power f acilities.

From 1977 to 1978, I was the Supervisor of the Environmental Chemistry Labor-a tory . In this position, I was responsible for laboratory supervision, evaluation of analytical techniques and sample analysis, report preparation, review of data and laboratory response during an emergency.

From 1975 to 1976, I was a chemist responsible for analyzing environmental, bioassay and inplant samples for alpha, beta, strontium, radium, iodine, lead and uranium isotopes.

My professional memberships include the American Chemical Society, American Institute of Chemists and the American Nuclear Society.

7 ATTACM1ENT A I.

h i F ederal Emergency Management Agency Washington, D.C. 20472 i

FEB 2 61568 Guidance Memorandum EX-3 l e MANAGING PRE-EXERCISE ACTIVITIES AND POST-EXERCISE MEETINGS

, Purcose This Guidance Memorandum (GM) provides guidelines for managing pre-exercise activities and post-exercise meetings in support of the Federal Emergency Management Agency's (FEMA) Radiological Emergency Preparedness (REP)

Program Backcround l Under 44 CFR 350, it is the responsibility.of a State and its local governments to conduct joint exercises to test their

-REP plans as a condition of initial and continued FEMA approval of these plans. The predecessor GM 17, dated January 8, 1981, provided procedural guidance intended to improve the conduct of exerciser and to establish greater uniformity among the FEMA Regions in this activity. While ,

(. progress has been made, there is still diversity among Regions. This revision is a further effort at achieving .I uniformity in preparing for, conducting'and assessing y exercises. It. supersedes the January 8,'1981, GM 17 and the 35 ' exercise objectives contained in attachment 2 of the August 5, 1983, memorandum.

Guidelines I. Pre-exercise Activity Past experience has shown that joint exercises must be planned considerably in advance and each step scheduled. In ,

order to ensure optimum results, the following milestones ~

should be met, at a minimum. These milestones are predicated en the biennial exercise frequency. Since the )

milestone time frames have been changed, they should be implemented beginning calendar year 1989. Until then, the milestone dates in parentheses should be used. Beginning in 1989, if exercises are conducted more frequently than biennially, the milestone time frames placed in parentheses should be used.

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r MILESTONES EQE EXERCISE EVALUATION No Later Than Days Prior 12 Exercise ~ Recuired Action. ,,

90 days State and licensee. jointly develop (75) and submit exercise objectives'to FEMA and Nuclear Regulatory Commission (NRC) Regional' Offices._ ,

75 days FEMA and NRC Regional Offices (60) complete reviews of objectives and extent of play after meeting with i licensee / State, if necessary. l 60 days State and licensee submit exercise (45) scenario to FEMA and MRC Regions for review.

45 days . FEMA and NRC Regions contact or meet (35) with State and licensee to discuss modifications and complete the scenario. Agreed upon changes or modifications should be' documented

• and distributed.

( 35 days (optional)

(30)

Regional Assistance Committee (;RAC)

Chair calls Controller's meeting to develop coordination of exercise.

. 30 days '

FEMA and NRC Regions develop (25) specific post-exercise activity schedule for debriefings and ,,

meetings with the State. '

15 days The RAC Chair (and NRC team leader )

as available) develops evaluator l action plan (where stationed, how i many from each organization, what  !

to look for). ,

The product of this will be the exercise evaluator packet which includes the specific evaluation  !

location assignment. The packet '

should provide:

o Portions of the plan l applicable to their  !

L assignment; i

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' ' o -A' list of.all. exercise evaluators and their assignments; t

o A time-line of events; -

o Scenario summary; o Scenario technical data as required for those assigned; o Past exercise findings; o Applicable controller messages; o Applicable reference materials; o Logistic'information and o Log forms for taking notes.

I day All Federal' evaluators, both.onsite and offsite, meet in the exercise area to receive orientation and final instructions.- ,

Exercise Day (ED) Conduct Exercise. Evaluators hold Exit Interviews with participants

, (at assigned locations).

ED+1 Evaluator Debriefing conducted by,

RAC Chair.

ED+1 or 2 NRC holds onsite. Exit Meeting.

ED+ Public Meeting is held by the RAC chairperson and the State (s).

(Qualifying Exercise) -

ED+ Participants Meeting is conducted by RAC Chair. (Continuing Approval Exercises)

ED+30 Draft FEMA exercise evaluation report sent to State (s).

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Whenever an exercise is scheduled, the Region should promptly assure construction of a time line based on the above milestones and make it available to the State, RAC members, NRC Region, and FEMA Headquarters.

Where a plant j i is located on a Regional boundary, the Region in which the 1

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-plant is actually;1ocated is considered the lead Region.for purposes of scheduling, coordination and establishing the time-line. Adhering to the time line should permit. ample time to review and negotiate any changes to the . exercise

objectives and the exercise scenario. However, should delays occur which may affect the scheduled exercise date, the Regional Director shall so advise the State, the NRC

. Region, the RAC members and FEMA Headquarters. The FEMA Regional Office should make every effort to rectify slippage in the timetable to avoid rescheduling the exercise date.  !'

The objectives for the offsite portion'of the exercise should be taken from this document's list of 36 in Section III, Exercise Objectives. These exercise objectives functionally restate the intent of those evaluation criteria in NUREG-0654/ FEMA-REP-1 that can be demonstrated and observed in exercises. They are restated in order to l facilitate the use of these evaluation criteria for  !

evaluating exercise performance. They also constitute the l

" major elements" of offsite emergency planning. and preparedness that are to be tested at least once every six years as set forth in NUREG-0654/ FEMA-REP-1 evaluation criterion N.1.b. as revised in GM PR-1 (page 2). Therefore, the objectives should be selected in order to test all major elements at least once every six years. Some objectives, because of their importance to adequate emergency response, j are to be included in each biennial exercise for each ~

participating organization. This set of exercise objectives, referred to as the " core objectives," are listed i in Group A of Section III of this' document. The initial six-year period began on the date of the first joint exercise after November 3, 1980, the effective date of the NRC rule,10 CFR 50 (see GM PR-1). ..

The objectives for each exercise shall be reviewed by both the FEMA and NRC Regional Oftices before specific scenarios I are written. Once reviewed, the State and licensee shall develop a scenario for submission which will include, at a minimum:

o The exercise objectives; o The date(s), time period, place (s), participating organization (s) and extent of State and local government participation (i.e., full or partial);

o A time schedule of all key events; o Identification of simulated events and activities;

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o o A chronological narrative'of exercise events and  ;

activities and

. o Appropriate radiological offsite release data with appropriate values for dose calculations, dosimetry, L . field monitoring and meteorological data.

FEMA and NRC Regions will coordinate the review of the -

L scenario and notify the State and' licensee of any-necessary modifications. If necessary, a meeting to discuss modifications should be held. If agreement cannot be- reached, FEMA and NRC Headquarters assistance should be sought.

II. Post-exercise Debriefings and Meetinas A. Three audience groups may be involved in post-exercise meetings:

1. Evaluators,

2. Exercise Participants and

3. Public/ Media.

The timing and intent of the meetings may vary C'~ depending upon whether the exercise is conducted in advance of FEMA 350 approval (qualifying exercise),

for. continued 350 approval or after a remedial exercise.

B. The following chart illustrates post-exercise meeting requirements for qualifying exercises and v>

exercises for continued FEMA approval.

QUALIFYING EXERCISE CONTINUED APPROVAL EXERCISE Evaluator / Participant Evaluator / Participant Exit Interview Exit Interview

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Evaluator Debriefing Evaluator Debriefing Exercise Participants Exercise Participants Briefing Briefing Public Meeting Meeting to which public and media are invited C. Guidance on each type of debriefing / meeting follows.

1. Evaluator / Participant Exit Interview (for cualifyinc and spntinued approval exercises):

Immediately following the conduct of the exercise, 5

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an exercise evaluator exit interview withLthe participants should be held at their assigned ,

' locations,.as~ appropriate, to briefly provide a i preliminary _ assessment 'of ' the exercise participants' strengths :and weaknesses.' No. attempt shquid be made ]

to categorize exercise performance inadequacies as

" deficiencies" or:" areas. requiring corrective actions" (ARCA) . Also, no indication of,a_" bottom line" finding on emergency preparedness at these locations should be made.

2. Evaluator Debriefinct Soon after the exercise, the RAC-Chair should hold debriefings for all-evaluators. These debriefings may be conducted by

. team leaders selected by the RAC Chair. . The purpose of these debriefings is to secure accurate and complete information from the evaluators per their assignments to provide the RAC Chair with the basis for each finding as presented during the Exercise Participants' Briefing. During'this same. period, i the NRC team leader conducts a parallel meeting with '

the NRC evaluators of onsite performance.in the exercise. If exercise deficiencies are indicated which would trigger remedial action, the RAC Chair shall report same to FEMA Headquarters by  !

telephone.per GM EX-1.

Following the RAC Chair's

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telephone contact with FEMA Headquarters, this- .

debriefing can serve as the initial step in the consultation process required in GM EX-1.

3. Exercise Participants Briefine ffgr qualifyinc and continued-aoproval exercises)

a. As soon as possible after their independen,t interviews, the RAC Chair and the NRC team', 2 leader should meet to coordinate and arrange for Federal participation in the joint Exercise Participants' Briefing.

b. Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the completion of an exercise, a briefing involving the exercise -

participants, RAC Chair, NRC representative and other RAC members and Federal evaluators, as appropriate, should be held to discuss the preliminary results of the exercise. This briefing should be held in accordance with 44 CFR 350.9(a)(d).

c. Recommended agenda to be used is as follows:

1) Review of onsite actions presented by NRC; I 6

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11) Licensee presents their views-(clarifying questions or comments);

iii) Review of offsite actions by RAC Chair; l iv) State and local governments present their l views (clarifying questions or comments);

v) Review of Federal response (if applicable) by RAC Chair and vi) Opportunity for clarifying questions or comments by licensee, State and local l governments.

d. The presentations should comprise a brief, l integrated overview covering the highlights )

of the exercise. Included in the l presentation should be appropriate  !

commendation (s) for good performance and a l preliminary assessment of the participants'  !

strengths and weaknesses. At this stage, no l

attempt should be made to categorize exercise l performance inadequacies as " deficiencies" or ARCA's. Also, no indication of a " bottom ]

1

(. line" finding should be made as to whether - l

\ State or local preparedness is adequate. - -

e. As soon as possible after this briefing,.the h RAC Chair, through the consultation process, )

should provide the State with a tentative identification of the exercise inadequacies, I if any, by classification, i.e., e

" deficiencies" and ARCA's. Again, no indication of a " bottom line" finding should be made as to whether State or local preparedness is adequate.

4. Public Meeting (for cualifying exercises) ~.

a. A public meeting in accordance with 44 CFR 350.10 should be held as soon as possible after the exercise in the vicinity of the nuclear power facility. This meeting shall be noticed in the local media in accordance with 44 CFR 350.10. Exercise participants, 2 representatives from the NRC and other I appropriate Federal, State and local agencies should attend,

b. The meeting should acquaint members of the  !

public with appropriate State and local emergency plans and the results of the 7

i

exercise, including strengths and weaknesses observed. The meeting should also answer any questions about FEMA's review and evaluation and receive suggestions from the publ,1c for improvements or changes.  !

c. During this Public Meeting an assessment of the exercise participants' performance should be made. The timing of the Public Meeting ,

with relation to the post-exercise evaluation procedures will dictate the degree to which the RAC Chair can address the exercise participants' performance. When the consultation process has progressed to the point of agreement on the degrees of inadequacies in the exercise participants' performance, these inadequacies can be discussed in their proper categorization, i.e., " deficiencies" and ARCA's. When an agreement on the inadequacies in the exercise participants' performance has not been reached, discussions should be more general, i.e., in terms of strengths and weaknesses,

d. For situations in which a Public Meeting has been held during the 350 approv.al process

-(. .

and, thereafter, a plan amendment is -

submitted which significantly changes the context or nature of the planning (e.g., a change in the emergency planning zone (EPZ) results in the inclusion of additional jurisdictions], the FEMA Regional Director shall determine whether the amendment necessitates holding another Public Meeting.

5. Meetino fpI Continued FEMA Aporoval Exercises

a. Following an exercise for continued FEMA approval, a meeting involving exercise ,

participants, representatives from the NRC, -

other appropriate Federal agencies, the i public and the media should be held in accordance with 44 CFR 350.9(e) in the vicinity of the nuclear power facility. This meeting shall be noticed in the local j newspaper with the largest circulation in the 1 area, or other media as the Regional Director f may select, within five to seven days of the j exercise date. At the discretion of the Regional Director, this meeting may be combined with the exercise participants

( briefing.  ;

8 i

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O.

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b. .The public and media may attend the meeting -

as observers. At the discretion of the' Regional Director, written questions from the j public and media may be submitted at or. af ter . i the meeting for; consideration in the'* exercise I evaluation. The Regional-Director may-further use his/her discretion to solicit and

respond to oral questions and comments during this meeting. Under no circumstances should

it be indicated whether State or local preparedness is adequate or. inadequate. . j

c. ' During the meeting, the RAC= Chair 'should i offer an overview of the exercise and should l

. provide his/her observations. Comments from l the RAC members and FEMA evaluators may be solicited at the discretion of the RAC Chair. i

6. "Meetinas" far exercises conducted durino lia l accroval process: Requirements in 44-CFR 350  !

do not address the conduct of " meetings" for I exercises, held =after the initial qualifying exercise but. before the completion of the 350 i approval process.- For such exercises, a meeting as described in 350.9(e), i.e., a y meeting conducted for continuing FEMA approval

{ . exercises, should be held.

of such " interim" exercises is an integral part FEMA',s evaluation i of FEMA's . overall 350 approval process. Again, the Regional Director may exercise further discretion by giving the public and the media.

an opportunity to orally discuss the performance of the exercise and the preliminary '

evaluation. D j

7. "Meetinas" after remedial exercises: After remedial exercises required under 44 CPR 350.9 (a) (c) (5), it is necessary to hold a debriefing ]

j (item II.C.2. above) and may be necessary to hold '

a meeting (item II.C.3. above). Because remedial- -

~

actions may vary from remedial exercises involving many organizations to drills including only one or two organizations, discretion is given to the Regional Director to determine the need to convene a meeting to which the public and media are invited, in accordance with 44 CFR 350.9(e).

I I

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% _m.-___.____ . _ _ _ _ _ _._.m._._m _ _ _ _ _ - _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ . _ . _ _ _ _ _ . _

a.

III. Exercise Obiectives The following list of 36 exercise objectives is to be incorporated into the design of REP exercises. These

' objectives are correlated to the original 35 exercise objectives from the- August 5,1983, memorandum by the numbers. provided in parentheses following the text of each objective. For all 36 objectives, the need.for organizations to demonstrate these capabilities is 'j dependent upon their assigned plan responsibilities. ,

The objectives are presented in three groups. Group A, i numbers 1-15, are ' core objectives" that are to be  ;

demonstrated in each biennial exercise. Core objectives represent fundamental emergency preparedness capabilities needed by all organizations for effective response to  !

radiological emergencies. These objectives are scenario independent and, therefore, need to be demonstrated by all  !

organizations in each biennial exercise. H l

Group B objectives, numbers 16-25, also represent q fundamental radiological emergency response capabilities and should be demonstrated in each biennial exercise. However, l these objectives are scenario dependent and may only impact i some organizations. Scenarios should be varied'from i exercise to exercise to ensure that these objectives are

( demonstrated by each appropriate of.fsite emergency response organization at least once every six years. Some organizations may need to demonstrate these objectives more frequently because of factors such ass (1) Geographical location and size of jurisdictions, (2) use of 360 degree evacuation for a significant part or all of the plume Emergency Planning Zone and (3) need to retest capabilities ,

previously evaluated as areas requiring corrective action. 1 Group C objectives, numbers .26-36, while not as critical as the more primary and time-sensitive Group A and B objectives, also represent important emergency preparedness .

capabilities. For example, the ingestion-related objectives (27-30) include functions that generally would not have to be implemented immediately to protect public health and '

safety. Group C objectives need only be demonstrated once )

every six years.

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Each of the exercise objectives in Groups B and C should be demonstrated during an exercise within the initial six-year l_ period and then tracked individually to ensure inclusion in exercises within six-year intervals. For examp1.e, if the -

initial six-year period for an offsite response organization )

began June 1982 and a shift change (Objective 34) was l

' demonstrated during the June 1984 exercise, this objective  ;

must be demonstrated again at the latest by the end of }

calendar year 1990.

GROUP A - CORE OBJECTIVES THAT ARE SCENARIO INDEPENDENT f NUREG-0654/ i OBJECTIVS 1 FEMA-REP-1 '

EMERGENCY CLASSIFICATION LEVELS

1. Demonstrate the ability to monitor, D.3.4.

understand and use emergency classification levels (ECL)' through the appropriate implementation of emergency functions and activities corresponding to ECL's as required by the scenario. The four ECL's are:

Notification of unusual event, alert, site area emergency and general emergency.

MOBILIZATION QE EMERGENCY' PERSONNEL j

2. Demonstrate the ability to fully alert, E.1., i mobilize and activate personnel for both E.2.

facility and field-based emergency functions. (See Objective 34 for 24-hour, continuous staffing function within a six- .,

year time frame). (1) '

DIRECTION AND CONTROL

3. Demonstrate the ability to direct, coordinate A.1.d., _

and control emergency activities. (3) A.2.a.  ;

COMMUNICATIONS

4. Demonstrate the ability to communicate with F.

all appropriate locations, organizations (not F.1. f. )

and field personnel. (5)

FACILITIES EOUIPMENT &HQ DISPLAYS

5. Demonstrate the adequacy of facilities, G.3.a.,

equipment, displays and other materials to H.2.3.

support emergency operations. (4)

(

11

l a j

,, EMERGENCY WORKER EXPOSURE CONTROL

6. Demonstrate the ability to _ continuously 'K.3.a.b.

monitor and control emergency worker

-exposure. (20) .

, FIELD RADIOLOGICAL MONITORING

7. Demonstrate the appropriate equipment and

• I.8.,

procedures for determining field radiation I.ll.

measurements. (7)

8. Demonstrate the appropriate equipment and I.9.

procedures for the measurement of airborge radioiodine concentrations as low as 10-microcurie per cc in the presence of noble gases. (8)

9. Demonstrate the ability to obtain samples of I.10.

particulate activity in the airborne plume and promptly perform laboratory analyses.

(New Objective)

PLUME DQJE PROJECTION

10. Demonstrate the ability, within the plume I.10.

(

exposure pathway, .to project dosage' to the -

public via plume exposure, based on plant and field data. (10)

PLUME PROTECTIVE ACTION DECISIONMAKING 4

~

11. Demonstrate the ability to make appropriate J.10. m.  !

protective action decisions, based on ,,  !

projected or actual dosage, EPA PAG's, '

availability of adequate shelter, evacuation i time estimates and other relevant  !

factors. (10)  ;

ALERT, NOTIFICATION hED EMERGENCY

12. Demonstrate the ability to initially alert the E.6.

public within the 10-mile EPZ and begin dissemination of an instructional message within 15 minutes of a decision by appropriate State and/or local official (s). (13) 12 0

6

~

13. Demonstrate the ability to coordinate the E.5. .

formulation and dissemination of accurate G.4.b.

information and instructions to the public in a timely fashion after the initial alert and -

. notification has occurred. (14, 25)

.- 14. Demonstrate the ability to brief the media in . G.3.a. ,

an accurate, coordinated and timely manner. G.4.a. l (24)

15. Demonstrate the ability to establish and G.4.c.

operate rumor _ control in a coordinated and timely fashion. (26)

GROUP R - SCENARIO-DEPENDENT OBJECTIVES DBE QL EL

16. Demonstrate the ability to make the decision . J.10.e.f.

to recommend the use of KI to emergency- workers and institutionalized persons, based on predetermined criteria, as well as to distribute and administer it once the decision is made, if necessitated by radioiodine releases.

(21,22)

17. Demonstrate the ability to make the J.10.f. .

decision, if the State plan so specifies, to recommend the use of KI for the general public, based on predetermined criteria, as well as to distribute and administer it once the decision is made, if necessitated by '

radioiodine -releases (21,22) ,

IMPLEMENTATION QE PROTECTIVE ACTIONS

18. Demonstrate the ability and resources necessary J.9.,

to implement appropriate protective actions J.10. d. g.

for the impacted permanent and transient plume .

EPZ population (including transit-dependent persons, special needs populations, handicapped persons and institutionalized persons).

(15)

19. Demonstrate the ability and resources J.9.,

necessary to implement appropriate protective J.10. g.

actions for school children within the plume j EPZ. (19)

(

i 13

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TRAFFIC CONTROL

20. Demonstrate. the organizational ability. and J.10.j . k.

resources necessary to control evacuation .,

traffic flow and to control access to evacuated and sheltered areas. . (16,17)

RELOCATION CENTERS _(REGISTRATION, MONITORING, CONGREUATE CARE &HD DECONTAMINATION)

21. Demonstrate the adequacy of procedures, J.12.

facilities, equipment and personnel for the registration, radiological. monitoring and decontamination of evacuees. (27)

22. Demonstrate the adequacy of facilities, J.10.h.

equipment and personnel for congregate care of evacuees. (28)

MEDICAL SERVICES (TRANSPORTATION &HQ FACILITIES)

23. Demonstrate the. adequacy of vehicles, L.4.

equipment, procedures and personnel for q transporting contaminated, injured or exposed  !

individuals. (30)

( '

24. Demonstrate the adequacy of medical facilities equipment, procedures and personnel for L.1.

handling contaminated, injured or exposed

. individuals. (31)

DECONTAMINATION

25. Demonstrate the adequacy of facilities, K.5.k.b.

equipment, supplies, procedures and personnel for decontamination of emergency workers, ,

equipment and vehicles and for waste disposal. '

(29)

GROUP C - OTHER OBJECTIVESr TQ BE DEMONSTRATED &T LEAST QHCE .

EVERY SIX-YEARS

, SUPPLEMENTARY ASSISTANCE (FEDERAL /OTHER)

26. Demonstrate the ability to identify the need C.1.a.b.

for and call upon Federal and other outside support agencies' assistance. (32)

I 14

_ ______-____.-_____.___.-___________..-m. _ _ . _ _ _ _ _ _

a INGESTION EXPOSURE PATHWAY l

27. Demonstrate the appropriate use of equipment I.8.,

and procedures for collection and transport ., J.11.

i I

of samples of vegetation, food crops, milk, meat, poultry, water and animal feeds (indigenous to the area and stored). (9) .

28. Demonstrate the appropriate lab operations C.3.,

' and procedures for measuring and analyzing J.ll.

samples of vegetation, food crops, milk, meat, poultry, water and animal feeds (indigenous to the area and stored). (9) -

i

29. Demonstrate the ability to project dosage to I .10. ,

the public for ingestion pathway exposure and J.9.,

determine appropriate protective measures J.11.

based on field data, FDA PAG's and other relevant factors. (11)

30. Demonstrate the ability to implement both J.9., l preventive and emergency protective actions J.11.

for ingestion pathway hazards. (12) i RECOVERY. REENTRY AND RELOCATION

~

( 31. Demonstrate the ability'to estimate total population exposure. (34)

M.4.

32. Demonstrate the ability to determine M.1. l appropriate measures for controlled j reentry and recovery based on estimated total j population exposure, available EPA PAG's and a, i other relevant factors. (35)

33. Demonstrate the ability to implement M.1.

appropriate measures for controlled reentry and recovery. (35)

MOBILIZATION QE EMERGENC1 PERSONNEL (2 4 -HOUR. CONTINUOUS BASIS)%

34. Demonstrate the ability to maintain staffing A.l.e.,

on a continuous 24-hour basis by an actual A.4. j shift change. (2) I I

i EVACUATION QE ONSITE. PERSONNEL

35. Demonstrate the ability to coordinate the B.6. l evacuation of onsite personnel. (23) J.2.

1 1

15 l

t-l_.________.____._________--- - - _ - - - - - -

e ..

l

'[- UNANNOUNCED MID OFF-HOURS i

.36. Demonstrate the ability to carry out emergency N.1.b. '

response functions (i.e., activate EOC's, .

mobilize staff that report to the EOC's, establish communications linkages and complete

' telephone call down) during an unannounced off- {

hours drill or exercise. (New Objective)

IV. CORRELATION QE EXERCISE OBJECTIVES EITH LEVELS QE EXERCISE l As set forth in 44 CPR 350,2(j)(k), there are two levels of participation in exercises, full and partial participation.

In demonstrating exercise objectives in full participation ,

exercises, the objectives should be fully demonstrated in both facility and field operations. In demonstrating exercise objectives in partial participation exercises, the  !

objectives should be fully demonstrated in all facilities while field operations may be. simulated. i V. IMPLEMENTATION t

The provisions of this GM should be implemented 120 days from the date of this memorandum. There are two exceptions to this implementation time frames (1) The expanded '

C -

milestone dates (e.g., from 75 days to 90 days) for the initial milestone and (2) exercise objective 9. These should be implemented in all joint exercises to be held 4 beginning in calendar year 1989.

VI. COORDINATION This GM has been coordinated with and concurred in by hRC staff. ,

l I

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q

. f%R.07 'Brs 21:31 FEMA L$tSH FED CTR 1 ATTACHf1ENT B

[., Federal Emergency Management Agency Washington, D.C. 20472 MAR TIM MEMORANDUM FOR: Regional Directors .

Acting Regional Director FROM: Grant C. Peterson

/ Associate Director State and Local Programs and Support j

SUBJECT:

Guidelines for Regions to Use in Implementing I NUREG-0654/ FEMA-REP-1, Rev.1, Supplement 1 With Qualifying Exercises The attached guidelines are provided for comment and interim use in preparing for and evaluating qualifying exercises where State and/or {

local governments decline to participate in emergency planning and '

exercises. They are in the fom of an Amendment to Guidance Memorandum EX-3, issued February 26, 1988. This guidance should be used in i

conjunction with NUREG-0654/ FEMA-REP-1, Revision 1, Supplement 1. j t

The existing modular fomat should continue to be used in conjunction with the evaluation criteria of Supplement 1 until the modular fonnat is revised by Headquarters to incorporate the use of Supplement 1 and this amendment.

This guidance has been developed jointly with Nuclear Regulatory Commission staff and has been approved by Mr. Thomas E. Murley, Director, Office of Nuclear Reactor Regulation.

Comments should be provided to FEMA Headquarters, attention Technological Hazards Division, by March 31, 1988. Any questions concerning this matter should be addressed to Vern Wingert at 646 2872.

Attachment cc: Thomas E. Murley, Director, Office of Nuclear Reactor Regulation, Nuclear Regulatory Commission w

l

MAR.07 '88~21:32 FEMA WASH FED CTR 1 P.03 l

g. ..

Federal Emergency Management Agency Washington, D.C. 20472 ,1 l

Attachment Guidance Memorandum '

(GM) EX-3 Amendment .

Purpose

• 1. This document amends the guidance in GM EX-3 to accmodate the testing of utility offsite plans in qualifying exercises.

This amendment addresses the application of exercise objectives of GM EX 3 to exercises in which State and/or local governments decline to participate with the utility. It also specifically delineates what constitutes an adequate demonstration of those exercise objectives pertaining to functions for which utilities are dependent upon State and/or local goverments for legal authority to carry out their emergency responsibilities.

2. This amendment will assist evaluators in determining the knowledge

, and capability of the utility offsite response organization personnel to advise and assist State and local officials in implementing those portions of the offsite plan where State and local response is identified.

3. This amendment is intended to facilitate the implementation of the Nuclear Regulatory Commission (NRC) regulation,10 CFR Part 50.47(c)(1) and 10 CFR Part 50. Appendix E, section IV.F., dated November 3, 1987, 52 FR 42078 and the planning standards and evaluation criteria in NUR G-0054/ FEMA REP-1, Revision 1, Supplement 1.*

Guidance

1. The nature of the qualifying exercise is stated in 10 CFR 50 App.E.!V.

F. (1): "A full participation exercise which tests as much of the licensee, State and local emergency plans as is reasonably achievable without mandatory public participation shall be ccnducted for each site -

at which a power reactor is located for which the first operating license for that site is issued after July 13, 1982. This exerc'se shall be conducted within two years before the issuance of the first operating license for full power (one authorizing operation above 51 of rated power) of the first reactor, and shall include participation by each State and local government within the plume exposure pathway EPZ and each State within the ingestion exposure pathway EPZ..."

2. The amended NRC regulation in 10 CFR Part 50, Appendix E, Section IV.F.6.

provides that: "The participation of State and local governments in an emergency planning exercise is not required to the extent that the

• The guidance herein may be amended as the law develops and requirements er the evaluation criteria are changed or modified.

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- n_---- o v.m o * }

t 2 1 applicant has identified those governments as refusing to participate further in e.nergency planning activities pursuant to 10 CFR 50.47(c)(1).

In such cases, an exercise shall be held with the applicant or licensee and such governmental entities as elect to participate in the emergency planning process." l 1

- All qualifying exercises should have ingestion pathway I demonstration including the activation and operation of emergency operation facilities, field team functions (e.g., sampling and laboratory analysis) and the dissemination of agriculturally-related infomation and instructions. It may be necessary to have a separate )

scenario to drive sufficient ingestion pathway exercise play. .

- "The offsite response organization shall attempt to involve the non- )

participating State and local government in the exercises and drills, but their participation is not required." (Supplement 1, evaluation criterion N.6.) This provision also applies to ingestion-only  ?

exposure pathway states.

3. Since the purpose of this qualifying exercise is to test as much of the emergency plans and preparedness as is reasonably achievable, without State and/or local participation, under Supplement 1 the utility should demonstrate a total of 36 exercise objectives. This consists  !

of 35 of the 36 existing exercise objectives in 91 EX-3, plus an I additional objective that incorporates evaluation criteria of Supplement

1.  ;

- Objective 36, unannounced and off-hours exercises and drills, does not j

. apply to a qualifying exercise. j 1

- While implementation guidance in GM EX-3 pemits State and local l governments to delay demonstration of exercise objective 9 until e calender year 1909, it is necessary for utility offsite response ,

organizations tc test this objective for qualifying exercises held in calender year 1988. Objective 9 states, " Demonstrate the ability to obtain samples of particulate activity in the air-borne plume and promptly perfom laboratory analyses." (I.10.)

~

- The folloring is a new exercise objective thct parallels the ~

Supplement 1 guidance. This objective is as follows: " Demonstrate the capability of utility offsite response organization personnel to interface with non-participating State and local governments through their mobilization and provision of advice and assistance."

(N. I.b. , E.6. and C.5. )

4. The following is a subset of the 36 exercise objectives in 91 EX-3 that may be legal authority-sensitive and which should be demonstrated in qualifying exercises. They may be authority sensitive because some aspect of their implementation in an actual radiological emergency 1

1

~~ 7 .b r - ~ - - - -

. MAR.o? '88 21:33 FEf1A WASH FED CTR 2 3

=

may be dependent upon the authority of the non-participating State and local goverments. Thus, the demonstration of these objectives in an exercise could be dependent upon how authority-related thues are {

addressed in the utility offsite response organization plan. (See  !

l item 6 below.) Depending upon the provisions of the plan, demonstration d of these objectives might be limited to the offsite respo%e organization

' providing advice and assistance to controllers and evaluators who will a afford appropriate opportunities for the players to demonstrate their 'l l

knowledge and interf ace capabilities.

a. Objective 11. Plume Protective Action Decisionmaking (J.10.m.);

- b. Objectives 12,13,14 and 15. Alert, Notification and Emergency Infomatio.n (E.5. , E.6. and J.10.c.);

c. Objectives 16,17. Use of KI (J.10.e.f.);

d. Objectives 18,19. Implementation of Protective Actions (J.9.,

J.10.d .g . );

e. Objective 20. Traffic Control (J.10.j.k.);

f. Oojectives 21, 22. Registration, Monitoring Decontamination and Congregate Care (J.10.h., J.12.);

i. Objectives 23, 24. Medical Services (Transportation and Facilities)

(L.1, L.4. );

j. Objective 25. Decontamination (K.S.a.b.);

k. Objective 26. Supplementary Assistance (Federal /0ther) (C.1.a.b.);

1. ODjective 30. Ingestion Exposure Pathway (J.9., J.11) and

m. Objectives 32, 33. Recovery, Reentry and Relocation (M.1.).

5. The scope of the demonstration of the exercise objectives should ~

include emergency personnel, facilities and resources required by the scenario and exercise play, keeping in mind that the purpose '

of the qualifying exercise is to test as much of the emergency plans and preparedness as is reasonably achievable, without State and/or local participation. The degree of demonstration of individual exercise objectives should test the workability of that aspect of the plan. For example it will be only necessary to activate those relocation centers that are dictated by the scenario and axercise play and, therefore, net necessarily all other relocation centers. ,

, , MAR.07 '88 E'1:34 FEMA WASH FED CTR 1 P.06 4

6. The demonstration and evaluation of the objectives should follow the specific provisions of the plan being tested. For example, the activation and deployment of utility offsite response organization personnel should be perfomed at the emergency classification 1evel designated in the plan. If the plan, requires the utility offsite response organization to secure legal authority to carry out necessary functions, they should follow the procedures cont 1hed in the plan that would be used in the event of an emergency. Actions in an exercise simulating the securing of appropriate legal authority may include the following: A simulation of the general deputization of utility offsite response organization personnel, a simulation of the ad hoc securing of authority on a case-by-case basis or a -

simulation of the direct assumption of responsibility by State and local governments.

7. Consistent with the guidance in Supp.1, evaluation criteria N.1.b., ,

"An exercise shall include mobilization of offsite response organiza-tion resources adequate to verify the capability to respond to en accident scenario requiring response. This includes the demonstration '

of offsite response organization capabilities to interface with non-participating State and local government, but does not include the use of stand ins for the anticipated State and local response."

8. FEMA will evaluate the timeliness, completeness and effectiveness of interfaces between utility offsite response organization personnel through interactive communications and exchanges with controllers and evaluators. While the controllers will not function as stand-ins, they will provide appropriate opportunities for the players to demonstrate the knowledge and interface capabilities of utility offsite response organization personnel. The utility offsite response organization personnel in facilities will be expected to make telephone calls and forward information to ,

control cells. For utility offsite response organization personnel .

in the field, evaluators will use directed questions to determine their ability to carry out their interface capabilities. Thus.

FEMA will use information secured by both exercise controllers a and evaluators to assess the utility offsite response organization's interface and liaison capabilities. ~

9. This guidance has been jointly developed by the Nuclear Regulatory Commission (NRC) and the Federal Emergency Management Agency staff

- and has been approved by the Director of the NRC Office of Nuclear Reactor Regulation. -

l t

, ___----v ,_

, . ase UNITIO eTAfts NUCLEAR REGULATORY COMMIOl0N

• WAgNINeTON. D.S.30005 J March 3.1988 MEMORANDUN FOR: trant C. Peterson Associate Of rector State and Local Programs afid Support Federal Emergency Management Agency FROM: Thomas f. Murley, Director Office of Nuclear Reactor Regulation

SUBJECT:

NRC STAFF CONCVRADtCE IN FEMA GUIDANCE ON QUALIFYING EXERCI5Es WHERE STATE AND LOCAL 80VERNMENTS DECLINE TO PARTICIPATE I concur in the sub,1ect guid6nce (Enclosed) that will he issued to FDM Regional Directors as en amendment to FEMA Guidance Memorandua (SN) EX 3

' Managing Pre. Exercise Activities and Post.!xercise Meetings." I apprecfete the extensive effort expended by your staff during the joint development of this gufdance.

j -gw h u-th c. nurjay, b office of Nuclear Reacter Regulation Eactosuret Draft Guidance itd. 3/3/88 .

l

Contact:

Edward M. Podolek

<N 49E.3187 .

a , b .2 5' *e $ *f s-0ovJw

~ n a n.Ln 1x n 4 s -7

' k. . .w, u a., 8 u-XA-lf. .

ATTACHMENT C J

f Federal Emergency Management Agency I t' Egy[p) 1Q Washington, D.C. 20472 wa MAY I 31988 MEMORANDUM FOR: Frank J. Congel .

Director, Division of Radiation Protection and '

Emergency Preparedness Of fice of Nuclear Reactor Regulation .

Nuclea t -

l

-ffa/r Regulahor dC ". issionxmdA.l &

FROM: Richard W. Krimm Assistant Associate Director Office of Natural and Technological Hazards Programs l I

SUBJECT:

Objectives For The Shoreham Exercise On February 8,1988, the Nuclear Regulatory Commission (NRC) requested that the Federal Emergency Management Agency (FEMA) conduct a f ull-participation exercise of Long Island Lighting Company's (LILCO) offsite l preparedness plan for the Shoreham Nuclear Power Station.

Attached are the proposed objectives for the Shoreham exercise now scheduled for June 7-9, 1988. They have been reviewed by FEMA Region II, the Regional Assistance Committee, and FEMA Headquarters. Of the objectives identified in FEMA Guidance Memorandum EX-3 and its March 7,1988 Amendment, all objectives, except as noted below are proposed for demonstration, as shown in the attachment to this memorandum. The exceptions are:

Objective 17 - This is consistent with New York State Public Health Law, New York State Radiological Emergency Preparedness pract. ices and the Shoreham Radiological Emergency Response Plan, in that the distribution and administration of potassium iodide to the general public is not a protective action option in the State of New York. '

Objective 36 - This is consistent with the Amendment to Guidance Memorandum EX-3 which states that an of f-hours unannounced exercise is not a requirement for a qualifying exercise.

Objective 22 - T'e h approach to demonstrations associated with this .

objective is now under discussion between FEMA and NRC staff, due to l the non-participation of the American Red Cross in the upcoming Shoreham '

exercise. We request your written advice as soon as possible on how  ;

the utility should hardle these demonstrations so that we can make  !

appropriate arrangements for their evaluation.

It is our position that the proposed objectives are sufficient to demonstrate l the capabilities of the Long Island Lighting Company Local Emergency Response l Organization in a f ull-participation exercise. We hereby request NRC to l infonn us as soon as possible whether these objectives are sufficient to constitute a qualifying exercise under NRC's regulations and give us specific advice on Objective 22.

If you have any questions or comments, please feel free to call me at ,

646-2871.

Attachment

,Ag Stated _ ,

o o vu70 M7_13/Y - --

}

3

.i. - d4 Federal Emergency Management Agency Region II 26 Federal Plaza

.' New York, New York 10278 May 5, 1988 .

MEMORANDUM FOR: Richard W. Krimm Assistant Associate Oirector Natural and Technological Hazards Programs FROM: Iber W. )!u s a r , Chairman Regional Assistance Committee I SUDJECT: Objectives for Shoreham Exercise l The proposed exercise objectives for the June 7-9, exercise have 1988 Shoreham I members. been reviewed by FEMA Region II, and the RAC of the 36 objectives identified within EX-3, and the required 0064/ objectiveRev.

FEMA-REP-1, for qualifying exercises described in NUREG 1, Supplement 1, the Long Island Lighting June exercise. The only its Company has submitted intent to test 34 objectives during the three objectives which will not be demonstrated are: l Objective Health Law.17New - This in consistent with New York State Public York State Radiological E9trgency )

Preparedness practices and the Shoreham Radiological

. Emergency Response plan, that the distribution and administration of potassiua lodide to the general public is not an acceptable protective action. s 4 Objective 22 - This objective will not be demonstrated due to the refusal of the American Red Cross refusal to participate-in the upcoming Shoreham exercise.

Objective 36 - This is consistent with Guidance Memorandum EX-3a which not states that requirement for aanqualifying off-hours exercise.

unannounced exercise is '

l Our review indicates that the 34 objectives submitted are sufficient to amply demonstrate the capabilities of LILCO. It is our request that these off-site objectives be submitted to the Nuclear exercise"Regulatory under NRCCommission rules. for determination for " qualifying l

Attachment

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T Federal Emergency Management Agency

. Region H N Federal Masa New York, New York 10278 l E e ..

i 0 May 4, issa 8

Mr. Douglas M. crocker, Manager Nuclear Emergency Preparedness Long Island Lighting company *

Central Islip,RN.Y. 11722 2

j Dear Mr. Crockert 1

s As a result of your April 29th meeting with Gary Seidenfeld and your concurrence, we have reformatted your revised objectives i

which you submitted in your correspondence of April 19, 1988 to 3

coincide with the language of the objectives specified within Ex-3, dated February 26, 1988. The attached objectives have been divided into two components (plume pathway, and ingestion pathway) for the scheduled June 7-9, 1988 exercise. Objectives have beenforfurther activated identified within each location which will be the exercise.  !

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' Per your request, the following changes have been incorporated into the attached objectives

)

The demonstration of objective 7 has been added to the

[ Brookhaven Area' Office location.

The demonstration of objective 22 is being been removed.

This is the result of the American Red Cross refusal to L participate in the upcoming Shorehan exercise.

FEMA objectives 17 and 36 are the onl be demonstrated during the exercise. yThe objectives which for justification willL'not this is as follows:

Objective 17 - This is consistent with New York State Public Health Law, New York State Radiological Emergency Preparedness practices and the shoreham Radiological Emergency.

Response Plan, that the distribution and administration of I

potassium iodide to the general public is not an acceptable l protective action.

Objective 36 - This is consistant with Guidance Memorandum EX-3 which states that an off-hours unannounced exercise is not a requirement for a qualifying exercise.

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co e r xaoA rm n mess was a:s es, so Aw 4

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, objectives identified within your revised submission into the

• ' l during the upcoming exercise. exercise " extent of play" and they will be ev e deficiencies,that FEMA evaluators will verify the status of all previous a shoreham exercise.and areas requiring corrective action during the objectives be forward to the Nuclear ReI will be requesting to FEMA H )

determination for " qualifying exercise"gulatory commission for

under NRC rules. j Your cooperation throughout the plan review and exercise i process has been greatly appreciated i

4 Sincere ,

.9

hhorW.Musar V chairman, Regional t

J Assistance Cor.mittee 1*

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j I .' PLUME PATHWAY 0BJECTIVES

'A.

7 LERO EMERGENCY OPERATIONS CENTER (EOC) r

1. OBJECTIVE 1: Demonstrate the ability to monitor, i understand and use amargency classification levels (ECL) through the appropriate implementation of emergency functions and activities corresponding to ECL's as  !

required by the scenario. The four BCL's are.

,- Notification of unusual event, alert, site area emergency and general emergency. I L

2. OMECTIVE 2:

Deacnstrate the ability to fully alert,

!' nobilize and field-based activate personnel emergency functions. for both facility and

3. OBJECTIVE 3:

Demonstrate the ability to direct, coordinate and control amargency activities.

4. OBJECTIVE 4: Demonstrate the ability to CoEEunicate with all appropriate locations, organizations and field personnel.

j 5. OBJECTIVE 5:

. Demonstrate the adequacy of facilities, equipment, displays emergency operations.

and other materials to support

6. OBJECTIVE 7: Demonstrate the appropriate equipment and procedures for determining field radiation measurements.

7. OBJECTIVE 9

"- - Damenstrate the ability to obtain samples

• of particulate activity in the airborne plume and o - promptly perform laboratory analyses,

s. osIEcTIVE 10:

exposure pathwa Demonstrate tho' ability, within the plume plume exposure,y, to project based on plant dosage to the and field public via-data.

9. CBJECTIVE 11: Demonstrate the ability to make appropriate protective actions decisions, based on

l. projected or actual dosage, EPA PAG's, availability of adequa'te shelter, evacuation time estimates and other ~

relevant factors.. ~

10. CMECTIVE 12: Demonstrate the ability to initially alert the public within the 10-mile EPZ and begin dissemination e

of an instructional message within 15 minut6c of a decision by appropriate State and/or local officials.

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i 11. o&7ECTIVE 13 Detonotrcto the chility to coordinato tha

, formulation and instructions disecaination to the public in aoftimely cceurato information fashion after theand initial' alert and notification has occurred.

12. OBJECTIVE 16: Demonstrate the ability to make the decision to' recommend the use of KI to emergency workers and institutionalized persons, based on predetermined criteria, as well as to distribute and administer it once the decision is made, if necessitated by radiciodine releases. .

13. OBJECTIVE 18: Demonstrate the ability and resources necessary to implement appropriate protective actions for the impacted permanent and transient p]ume EPZ population (including transit-dependent persons, special needs population, persons). handicapped persens and institutionalized

14. OBJECTIVE 19: Demonstrate the ability and resources necessary to implement appropriate protective actions for school children within the pluma EPZ.

15. C&JECTIVE 20 Demonstrate the organizational ability and resources necessary to control access to evacuated and sheltered area.

16. C&JECTIVE 26: Demonstrate the ability to identify the need for and call upon Federal and other outside support agencies' assistance.

17. OBJECTIVE 34: Demonstrate the ability to atintain staffin change.g on a continuous 24-hour basis by an actual shift

18. OBJECTIVE 35: Demonstrate the ability to coordinate the evacuation of onsite personnel. ,

• 19. CBJECTIVE 37: Demonstrate the capability of utility offsite response organization personnel to interface with non-participating State and local governments through their mobilization and provision of advice and assistance.

O FEMA HQ (SLPS) memorandum, subjects Guidelines for Regions to Use in Implementing NUREG 0654/PEMA-RZP-1, Rev.1, Supplement 1 with Qualifying Exercises, dated March 7, 1988.

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C. EMERpENCY NEWS-CENTER (ENC)

.. 1. 0&JECTIVE-2 Demonstrate the ability to fully alert,

' field-based.eaergency mobilize and activate functions.

personnel for both facility and.

2. OBJECTIVE 4: Demonstrate the ability to coma'unicate with all appropriate locations, organizations and' field personnel.

3. CBJECTIVE $2 Demonstrate the adequacy of facilities, equipment, .

displays emergency operations.

and other satorials to support

4. OBJECTIVE 13: Demonstrate the ability to coordinate the formulation and dissemination of accurate.information and instructions to the public in a timely fashion after the {

initial alert and notification has occurred. -

5. OBJECTIVE 14:

Demonstrate the ability to brief the media in an accurate, coordinated and timely manner..

6. OBJECTIVE 15: Demonstrate the ability to establish and operate fashion. rumor control in a coordinated and timely ,

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7. OBJECTIVE 34: Demonstrate the ability to maintain ,

- staffing change. on a continuous 24-hour basis by an actual shift

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D. STAGING AREAS (SA) i

1. C&JECTIVE 1: Demonstrate the ability to monitcr, , j understand and use emergency classification levels (ECL) through the appropriate implementation of emergency functions and activities corresponding to ECL's as required by the scenario. The four ECL's are Notification of unusual event, alert, site area amergency and general energency.

i i 2. OBJECTIVE 2:

~

t Demonstrate the ability to fully alert, ~

l mobilize and activate personnel for both facility and field-based emergency functions.

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3' 3. OBJECTIVE 3: Demonstrate the ability to direct, l coordinate and control energency activities.

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4. OBJECTIVE 4 Damenstrato the ability to communicate

, , with all appropriate personnel. locations, organizations and field .

5. C&JECTIVE 5:

equipment , Demonstrate the adequacy of facilities, displaysandothermaterialstosupgort emergency operations.

6. OBJECTIVE 6 Demonstrate the ability to cont monitor and control emergency worker exposure.inuously

7. OBJECTIVE 34:

staffin Demonstrate the ability to maintain change.g on a continuous 24-hour basis by an actual shift E.

EMERGENCY WORKER DECONTAMINATION FACILITY (EWDF)

1. C&7ECTIVE 2:

mobilite and activate personnel for both facility andDamen field-based emergency functions.

2. OBJECTIVE 6: Demonstrate the ability to cont monitor and control amargency worker exposure.inuously

3. OBJECTIVE 25 equipment, supplies, procedures and personnel forDemonstra decontamination of emergency workers, equipment and vehicles and for vaste disposal.

4. C&7ECTIVE 34:

staffin Demonstrate the ability to maintain change.g on a continuous 24-hour basis by an actual shift F.

FIELD ACTIVITIES (FA) >-

I

1. Ca7ECTIVE 3:

Demonstrate the ability to fully alert, mobilite and activats personnel for both facility and field-bssed emergency functions.

2. OBJECTIVE 6 '

monitor and control amargency worker exposure. Demonstrate the

3. OBJECTIVE 7 Demonstrate the appropriate equipment and procedures for determining field radiation measurements.

4. OBJECTIVE 8 Demonstrate the appropriate equipment and procedures for the measurement of airborna radiciodine concentrations as low as 10 7 microcurie per cc in the presence of noble gases.

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5. OBJECTIvr 9: Damonstrato tho ability'to cbtain ocaploo of particulots cctivity in the airborne plume and promptly' perform laboratory analyses.

6. OBJECTIVE 12: Demonstrate'the ability to initially alert '

the public within the 10-mile Ep2 and begin dissemination of an instructional message within 15 minutes of a decision by appropriate state and/or local officials.

7. C&JECTIVE 13: Demonstrate the ability to coordinate the formulation and dissemination of accurate information and

' instructions to the public in a timely fashion after the initial alert and notification has occurred.

8. OR.7ECTIVE 16: Demonstrate the ability to make'the decision to recommend the use of KI to emergency workers and institutionalized persons, based on predetermined criteria, as well as to distribute and administer it once the decision is PAda, if necessitated by radiciodine releases.

9. OBJECTIVE 18: Demonstrate the ability and resources necessary to implement appropriate protective actions for the impacted permanent and transient plume EPZ population (including transit-dependent persons, special needs population, handicapped persons and institutionalized persons).

10. OBJzcTIVE 193 Demonstrate the ability and resources necessary to implement appropriate protective actions for school children within the plume EPZ.

11. OMECTIVE 20: Demonstrate the organizational ability and

, resources necessary to control access to evacuated and sheltered area.-

12. OMECTIVE 21: Demonstrate the adequacy of procedures, facilities, equipment and personnel for the registration, radiological sonitoring and decontamination of evacuees.

13. OBJECTIVE 23: Demonstrate the adequacy of vehicles, squipment, procedures and personnel for trans contaminated, injured or arposed individuals. porting -

14. OBJECTIVE 24: Demonstrate the adequacy of medical facilities equipment, procedures and personnel for handling contaminated, injured or exposed individuals.

15. CBJECTIVE 34 Demonstrate the ability to maintain staffing on a continuous 24-hour basis by an actual shift change.

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DISMCT _ OFFICES (Do)

1. CELTECTIVE 15:

Demonstrate the ability to establish and operate fashion. rumor control in a coordinated and timely

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INGESTION PATHWAY / RECOVERY RE-ENTRY DhTECTIVES

, A.

14 CAL EMERGENCY RESPONSE ORGANIZATION (LERO)

1. OBJECTIVE 32' coordinate and control maergency activities. Demonstrate th

2. OE7ECTIVE 4:

Demonstrate the ability to communicate with all appropriate personnel. locations, organizations and field

3. OBJECTIVE 63 Demonstrate the ability to cont monitor and control'energency worker exposure.inuously

4. OBJECTIVE 8:

procedures for the measurement of airborne radiciodine concentrations as low as presence of noble gases.10~7 aicrocurie per cc in the 5.

C&JECTIVE 133 Demonstrate the ability to coordinate the formulationto and instructions dissemination the public of accurate in a timely fashion after ths information 6

initial alert and notification has occurred.

OBJECTIvZ 25:

equipment, supplies, procedures and personnel forDemonstra decontamination of emergency workers, equipment and vehicles and for waste disposal.

7. OBJECTIVE 263 Demonstrate the ability to identify the  ;

, need for and call agencies' assistance.upon Federal and other outside support

8. C&JECTIVE 27:

Demonstrate the appropriate use of e, equipment and procedures for collection and transport of samples of vegetation, food crops water and animal feeds (indigenous, milk, usat, poultry, stored). to the area and

9. OBJECTIVE 28:

and procedures for measuring and analyzing samples ofDe ,

vegetation, food crops, milk, meat, poultry, water and .

anima 1\, feeds (indigenous to the area and stored). l

10. OBJECTIVE 29 to the pablic for ingestion pathway exposure andDemonstrate data, FDA PAG's and other relevant factors. determine a S

2 >idOA tGa II I40ID38 W3J yr:rt Be, S0*AW

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11. C&7ECTIVE 30: \

Demonstrate tho ability to implament both k

• pathway hazards.emergency protective actions for ingestion preventive and '

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12. OBJECTIVE 31: Demons population exposure. trate the ability to estimate total

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13. OBJECTIVE 32: .

Demonstrate the ability to determine appropriate measures for controlled reentry a i based on estimated total population exposure,ndavailablerecovery {

EPA PAG's and other relevant factors.

i 14. OBJECTIVE 33: Demonstrate the ability to implement appropriate measures for controlled reentry and recovery.

B. I DOE-RAP BROOKHAVEN ARIA OFFICE (BHO) I l

1. OBJECTIVE 2: Demonstrate the ability to fully alert, mobilize and activate personnel for both facility and field-based emergency functions. 1

2. OBJECTIVE 3: Demonstrate the ability to direct, '

coordinate end control' emergency activities.

3. OBJECTIVE 4: Demonstrate the ability to communicate  !

with all appropriate locations, organizations and field j personnel.

4. CBJECTIVE 9: Demonstrate the ability to obtain samples of particulate activity in the airborne plume and promptly perform laboratory analyses.

5. OBJECTIVE 27: Demonstrate the appropriat.e use of equipment and procedures for collection and transport.of samplse of vegetation, food crops water and animal feeds (indigenous,tomilk, meat,and the area poultry, '

stored).

6. CBJECTIVI 29: Demonstrate the ability to project dosage to the.public for ingestion pathway exposure and determine appropriate protective measures based on field data, FDA PAG's and other relevant factors. ,

9 ET'd 2 MMOA M3N II MOID3d t4GJ tt:rt 89, S0*A0W

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EMERGENCY NEWS CENTER (ENC) {

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• 1. OMECTIVE 4 3 - f with all a Demonstrate the ability to communicate j personnel.ppropriate locations, organizations and field

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2. oMECTIVE 13 .  ;

Demonstrate the chility to coordinate the 1 instructions to the public in a timely fashion.after thef{

initial alert and notification has occurred. 4 i

3. OMECTIVE 14:

in an accurate, Demonstrate the ability to brief the media j coordinated and timely manner.

4. j oMECTIVE 15:

Demonstrate the ability to establish and l operate fashion. rumor control in a coordinated and timely f

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PI'd 2 >tdOA M3J II IJOID3d W3J sp:pt es, S0*AW

c M UNITED STATES

> . ATTACHMENT D.

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-8 n NUCLEAR REGULATORY COMMISSION

'$ i ,E WASHINGTON, D. C. 20565 g p' May 20, 1988

'l v...<

i HENORANDUM FOR: Richard W. Krimm Assistant Associate Director 0ffice of. Natural and Technological q

Hazards Programs Federal Emergency Management Agency f

FROM: Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation

SUBJECT:

OBJECTIVES FOR THE SHOREHAM EXERCISE l

This responds to your May 13, 1988 memo requesting guidance concerning the proposed objectives for the upcoming Shoreham emergency preparedness exercise. "

We agree that the proposed objectives are sufficient to demonstrate the capa-bilities of the Long Island Lighting Company Local Emergency Response Organiza- j tion'(LER0)inafull-participationexercise. Specifically, we believe that these objectives are sufficient to-constitute a " qualifying" exercise under ,

10 CFR Part 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.  !

RegardingthedeletionofObjective22(FEMAGuidanceMemorandumEX-3)because <

of the non-participation of the American Red Cross, we believe that this ,fs appropriate. Tn a May 11, 1988 letter from Edwin Reis, Deputy Assistant ? General Counsel, NRC to William R. Cumming, Esq., Office of General Counsel, FEMA, we stated that the Commission had previously found that the American Red Cross charter from Congress and its national ?olicy require it to provide aid in " arty ,

radiological or natural disaster," whetier or not there are letters of agreement in connection with a particular emergency plan. We will support the position that the American Red Cross responds to natural and technological disasters as .

.a routine and that it is not necessary to demonstrate this capability in a j radiological emergency preparedness exercise if they decifne to participate, In this case we believe it is not reasonably achievable to gain their participa-tion in the Shoreham exercise.

CONTACT:

Edward M. Podolak, Jr., NRR 492-3167

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l Richard W. Krimm If you have any questions or comments, please call me at 492-I088. We appreciate the intensive efforts of FEMA Region II, the Regional Assistance Connittee, and FEMA Headquarters in preparing for the Shoreham exercise. i Original signed by frank J.Congel ,

Frank J. Congel, Director ..,

Division of Radiation Protection  ;

and Emergency Preparedness ,

Office of Nuclear Reactor Regulation k DISTRIBUTION:  !

JPMurray, DGC JLBlaha, NRR JScinto, OGC WTRussell, RI ,

GEJohnson, OGC RRBellainy, RI  :

EJReis, OGC WJLazarus, RI TEMurley, NRR EFFox, RI JhSniezek, NRR FJCongel, NRR FJMiraglia, NRR WDTravers, NRR FPGillespie, NRR RJBarrett, NRR RTHogan, NRR LJCunningham, NRR SWBrown, NRR CRVan NIel, NRR Central Files FKantor, NRR EDO R/F CWingo, FEMA PDR R/F MLawless, FEMA EMPodolak, NRR PEPB R/F i

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j BY PHONE g /f TO Ed Podolak l PEPh/NRR SC/PE[B/NRR C/>Ih/.'RR OGC D/DREP/NRR/%'

FJCongel EttPod61ak:lr CR#a'nliel WD DJVers EJReis l

)j /p/88 6 5 5/jg/88 5(1/88 5/19/88 5/to/88 V L

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.... ATTACHMENT.E .

. ,j ' ' May 26, 1988.

u S,. MEMORANDUM FOR: Richard W. Krimm Assistant. Associate Director-Office of Natural and Technological ,.

Hazards Programs Federal Emergency Management Agency .

FROM: Frank J. Congel, Director Division'of Radiation Protection .

and Emergency Preparedness ,

Office of Nuclear Reactor Regulation  ?

SUBJECT:

OBJECTIVES FOR THE SHOREHAM EXERCISE This documents a telephone conversation with'your staff on May 25, 1988:

1. We have reviewed the May 25, 1988 memorandum from the ' Appeal Board regarding the scope of the. February 1986 emergency preparedness exercise at Shoreham.

2. The view expressed in my May 20, 1988 nemorandum to you regardino the completeness of 'the present objectives for the June 1988 Shoreham exercise has not changed; i.e., we believe that these objectives constitute a

" qualifying" exercise under 10 CFR Part 50, Appendix E, Section IV.F.1.

3. The view expressed by NRC in the May 3, 1988 meeting in your office regarding the handling of the State of Connecticut's non-participation has not j changed; i.e., their' participation is not reasonably achievable and the i use of a control cell is appropriate. -f I

I believe that the Licensing Board's memorandum supports the NRC and FEMA 1 l

judgement that the Shoreham exercise test as much of the emergency plans as'is reasonably achievable. If you have any questions please call me at 492-1088..

, .] .

Original signed by Rich:td ), Battett Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation (

CONTACT:

Edward M. Podolak, Jr., NRR 492-3167 DISTRIBUTION:

See attached

• SEE PREVIOUS CONCURRENCE C/PEPB/NRR* OGC* D/DR RR PEPB/NRR* SC/PEPB/NRR*

EMPodolak:1r CRVan Niel WDTravers EJReis FJCongel  ;

5/26/88 5/26/88 5/26/88 5/26/88 5/F/88

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f. ' . DISTRIBUTION:

UPNurray, osc JLBlaha, NRR FJCongel, NRR JScinto, 03C WTRussell, RI WDTravers, NRR GEJohnson,-0GC RRBellamy, RI RJBarrett, NRR EJReis, OGC WJLazarus, RI LJCunningham, NRR TEMurley, NRR EFFox, RI. CRVan Niel, NRR JHSniezek, NRR EDO R/F FKantor, NRR

FJMiraglia, NRR PDR R/F EMPodolak, NRR FPGillespie, NRR CWingo, FEMA RTHogan, NRR-MLawless, FEMA SWBrown, NRR PEPB R/F Central Files I

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N TTACHMENT F ,

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- y 1' Federal Emergency Management Agency E Washington, D.C. 20472  ;

~.

SEP -91988 .

Mr. Victor Stello, Jr.

Executive Director for Operations Nuclear Regulatory Comission

• Washington, D.C. 20555-S

Dear Mr. Stello:

.On January 27,1988, 'the Nuclear Regulatory Comission (NRC) requested that the Federal Emergency Management Agency (FDiA) review Revision 9 of l

Iong Island Lighting Ccrnpany's (LIIro) offsite preparedness plan for the l Shoreham Nuclear Power Station (SNPS), under the provisions of the April 1985  !

FD1A/NRC Memorandum'of Understanding and the criteria and assumptions j

.of NUREG-0654/FD%-REP-1, Rev.1, Supplement 1. FEMA was also requested to .

l provide a finding, i.e., indicate whether in the framework of those criteria and assumptions, FD% had reasonable assurance that the plans can protect the health and safety of the public living in the vicinity of the plant.

hat finding was delivered to the NRC on May 31, 1988.

On February 8,1988, NRC requested that FD% evaluate a full-participation k exercise of LIIf0's offsite' preparedness plan for Shoreharn. On May 20, 1988, j and May 26, 1988, NRC staff agreed that the proposed. objectives submitted ';

by FD% on May 13, 1988, were. sufficient to demonstrate the capabilities of LIICO's Iocal anergency Response organization in a full-participation exercise.

Bey also stated their position that the objectives were sufficient 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.

On May 23, 1988, NRC requested that FDR conduct a review of Revision lb of the LIICO offsite plan against the criteria of NUREG-0654/FDR-REP-1, Rev.1, Supplement 1 and the three asstanptions stated below. NRC also requested that Revision 10 changes be incorporated into the exercise play of the upccaning Shorehan exercise. Since a full Regional Assistance Carnittee (RAC) review could not be conducted in the short time frame remaining before the exercise, 1 FD% Region II agreed to review the changes, coordinate with the RAC where .  ;

necessary, and incorporate them into the evaluation of the exercise. 'Ihe 1 asstanptions upon which the plan review and the exercise were based are that in an actual radiological ernergency, State and local officials that have c declined to participate in emergency planning will:  :

1) Exercise their best efforts to protect the health and safety i of the public;  !

2) Cooperate with the utility and follow the utility plan, and  !

3) Have the resources sufficient to implement those portions of the utility offsite plan where State and local response is necessary.

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. , It is further understood that in any subsequent hearings or litigation .

related to the plan review or exercise, NRC will defend the above assumptions.

On August 31, 1988, you.also requested that FEMA review certain updated letters of agreement in conjunction with FEMA's ongoing review of Revision 10.

. Enclosed is a report on the results of a full review of Revision l0 of the LIIf0 plan and the abovementioned letters of agreement, conducted by FEMA Region II and the RAC. The Shoreham exercise was conducted on June 7-9, 1988.

s Enclosed is a copy of the Post-Exercise Assessment , dated September 2,1988, containing the results of FEMA's evaluation. It was prepared by FEMA Region II.

'Ihere were no deficiencies identified in the exercise. However, there are sme areas requiring corrective action. FEMA is requesting LIIf0 to submit a schedule of actions that they have taken or intend to take to correct both plan-related and exercise-related inadequacies.

As indicated in the plan review, Revision 10 contains 94 plan elements rated l adequate and 7 plan elements rated inadequate. Sme of the inadequacies were revealed as shortcomings in the exercise requiring further implementing detail in the plan. However, the exercise demonstrated adequate overall preparedness on the part of LERO personnel, and therefore, based on the evaluation of the plan and the exercise, and the recamiendation of FEMA Region II, FEMA has reached a finding of reasonable assurance.

1 By way of clarification, we would like to note for the acord that the enclosed

{

plan review did not reevaluate Elements C.2.b, C.2.c, E.3 and E.4 a-n, since they are to be removed frm the final version of NUREG-0654/ FEMA-REP-1, Rev.1, Supplement 1. 'Ihe review also does not take into consideration any possible ramifications of ongoing litigation in the State of New York concerning LIIf0's reception center at Bellmore. Although the Supreme Court of the State of New j York, Nassau County, has ruled on that issue, it is our understanding that j LIIf0 is appealing that ruling. Finally, the review also did not consider the  !

so-called ministerial changes listed as part of Revision 11 of the LIIf0 plan, although incorporated in Revision 1 of the SNPS Prmpt Notification and Design l Report. You requested that FEMA review that revision to the design report on 1 August 16, 1988. Our consolidated report on the SNPS alert and notification '

system will contain our evaluation of those changes, unless a full RAC review ,

of any potential Revision 11 of the entire plan is produced first, We hope that the above information is useful. If you have any questions, please feel free to call me at 646-3692.

Sin e ,

I a .' terson Associate Director l Statq and I.ocal Programs ard Support {

i Enclosures I As Stated

_.