ML20235W183
| ML20235W183 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 10/05/1987 |
| From: | Latham S, Mark Miller, Palomino F KIRKPATRICK & LOCKHART, NEW YORK, STATE OF, SOUTHAMPTON, NY, SUFFOLK COUNTY, NY, TWOMEY, LATHAM & SHEA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#487-4601 OL-5, NUDOCS 8710160038 | |
| Download: ML20235W183 (66) | |
Text
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.CC.
H METED October 5, 19870MC E 14 P4 $8 u
UNITED STATES OF AMERICA NUCLEAR: REGULATORY COMMISSION' and Licensina Board h
.h Before the Atomic Safety
'l
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-5
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(EP Exercise)
(Shoreham-Nuclear Power Station,
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Unit 1)
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i SUFFOLK COUNTY, STATE OF NEW YORK, AND TOWN OF SOUTHAMPTON MOTION FOR LEAVE TO REPLY TO LILCO AND NRC STAFF EXERCISE FINDINGS The NRC Staff and LILCO have filed proposed findingsl.and l
4 reply. findings,2 respectively, concerning the February 13, 1986 Exercise.
Suffolk County, the State of New York, and the Town of Southampton (hereafter, the " Governments") have now completed a l
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1 NRC Staff's Proposed Findings of Fact and Conclusions of Law on the February 13, 1986 Emergency Planning Exercise, Sept. 11, 1987 (hereafter, " Staff Findings").
2 LILCO's Reply to Interveners' and NRC Staff's Proposed Findings of Fact and Conclusions of Law on the February 13, 1986 l
Shoreham Emergency Planning Exercise, Sept. 25, 1987 (hereafter, "LILCO Reply Findings").
Unless otherwise indicated, citations to the LILCO Reply Findings are to volume I thereof.
8710160038 871005 PDR ADOCK 05000322 0
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preliminary review of the Staff Findings and LILCO Reply F.indings.
For reasons specified below, the Governments move for leave to reply to these NRC Staff and LILCO pleadings.3 The Governments' proposed reply to the Staff Findings would be brief,' focusing primarily upon the fundamental flaw standard I
and the' Staff's discussion of Contention Ex 15/16.
The Governments' proposed reply to the LILCO Reply Findings would, however, be considerably broader -- it would need to cover virtually all matters and issues heard by this Board because LILCO, with unprecedented vehemence, has urged this Board to
" reject the Interveners' proposed findings in their entirety in j
f avor of LILCO's, which are more balanced and apply the -
appropriate legal standards."
LILCO Reply Findings, at 2.'
The Governments would do their best to refrain from the k'ind of.
intemperate attack contained in the LILCO Reply Findings.4 But LILCO's attack cannot in fairness go unanswered.
J 3
Consistent with the Board's Order of September 15, 1987, granting LILCO additional time to file its reply findings, the Governments have not submitted reply findings as an attachment to this motion.
Such findings will be prepared and submitted if the
. Board grants this motion.
4 The Board needs only to skim the LILCO Reply Findings to get a taste of LILCO's tone.
LILCO, for example, accuses the Governments of, among other things:
not attempting to file
" balanced findings," engaging in "one-sided argument," and failing to have " sifted the record" (LILCO Reply Findings, at 2);
"misus[ing] the record" (14., at 3); "mir(ing]" their findings "in trivia" (id., at 4); ignoring legal standards (id., at 7);
"tak(ing} evidence out of context, distort [ing] other evidence,"
f and "mak[ing) sweeping generalizations having little or no factual support" (id., at 30); and numerous other alleged errors.
LILCO's use of such words to color its Reply Findings is unbecoming and does not assist in moving the Exercise issues I
' closer to resolution.
The Governments assume that the Board will (footnote continued)._
l*
i*
s Mention must also be made of the length of the LILCO Reply Findings. -LILCO apparently believes that it carefully sifted the record: initially, and-filed on August ~3, 1987, 211 pages of findings (including its brief'on Contention Ex'19).
Now, in L.
l (footnote continued from previous page) do its best to deal with the merits; accordingly, the Governments do not propose'to reply to LILCO's unfounded accusations as such.
Rather, the Governments-would attempt to address only the legitimate issues'before-this Board.
It-is also absurd for LILCO to assert that it has submitted
" balanced" findings while the Governments have not.
Again, the
' Board'need only skim the LILCO findings to conclude that'LILCO's findings are structured to advocate only one thing - 'LILCO's point of view.
The Governments do not necessarily blame LILCO c
for that.
This was a sharply contested proceeding in which the parties advocated significantly different interpretations-(of
-facts and legal requirements.
LILCO wrote its August 3-Findings in the form of an initial decision which conformed to its. views.
The Governments cannot accept unanswered, however, LILCO's self-serving pronouncement.that it has set forth a balanced view of the issues, when it obviously has not.
Indeed, the Governments submit that LILCO's initial August 3 Findings were so skeletal and summary in format that they are clearly the least balanced of any findings submitted by the parties.
~
Further, the LILCO Reply Findings are no more balanced.
Fcr example, LILCO, in attempted rebuttal of the Governments' Findir.g 126 concerning the nonparticipation of WALK Radio personnel, argues that the radio station's actions would be largely mechanical.
Egg LILCO Reply Findings, at 20 (and at 3 via cross reference).
But LILCO's rebuttal fails to deal at all with the Governments' point that radio station personnel still need to demonstrate a capability to carry out their tasks, an ability which has resulted in failure at other exercises.
geg Governments' August 17 Findings, at 90, 130-31.
Moreover, the L
Board will note that LILCO also fails to deal with the substance of'the Governments' point that radio station participation is important.
Sag, e o., LILCO Reply Findings, Vol. II, at 35 (Response to Findings 182, 183).
LILCO's " response" is, in i
short, no response at all, since it asserts what FEMA might have done, rather than relying on any evidence of record.
We reiterate, therefore, that it ill-behooves LILCO to talk about
" balanced" findings.
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l reply, it has filed two volumes, a 72-page narrative plus a 225-
.page, single-space, tabular' rebuttal to almost every assertion made by the1 Governments.
If LILCO's Volume II'" table" were presented in a narrative, double-spaced version -- that is, if it
. complied'with NRC form requirements, 10 CFR S 2.708(b) -- the Governments believe that it would be far in excess of 500 pages.
It clearly does not represent the kind of " reply" findings contemplated under 10 CFR S 2.754(a)(3), and cannot be justified on the basis of the fact that the Governments' initial brief was 626 pages.- Rather, after filing its initial, limited version of findings on August 3, LILCO then took the next 39 days between the Governments' August 17 filing and the date for LILCO's reply, and put together expansive, new arguments on virtually all issues.
At a minimum, the Governments must be given an opportunity to respond to these many new LILCO arguments.
The Governments, however, do not petition for leave to reply primarily because of the length of the LILCO Reply Findings or because there are new arguments.
Rather, the Governments seek to reply because LILCO, and to a lesser degree the Staff as well,5 have presented arguments which are not accurate, both in 5
If the Governments were confronted only with the Staff Findings, they probably would not seek Board leave to reply.
While the Staff Findings contain significant errors (some of which are discussed below), they are not permeated with the kind of invective which makes it so difficult to parse the LILCO Reply Findings.
Thus, if the Staff Findings were standing alone, the Board probably would be able to compare the Staff Findings with the Governments' and other parties' findings without the necessity of further comment.
However, the Staff Findings do not (footnote continued) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - - _ -
, _ - _ - - - - _ _ = _ - _ _
1 1
4.
[
<g.
U terms of the facts and the law.
The Governments recognize that
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the-Board will'not unhesitatingly accept the LILCO and Staff
- pleadingsL(nor those filed by the Governments).
The Governments also:recognizeLthat a great deal of post-trial findings have already been filed and that a reply submitted inr the Governments would,: 'to some degree, further increase the work of the Board.
Nevertheless, the sheer volume of.the LILCO Reply Findings -- and the degree of confusion and misimpression which they create --
compel the conclusion'that the Governments' request to file a further,brief should be granted.
Such a filing would be of assistance to the Board in its task of resolving the Exercise issues.
The best means of demonstrating the Governments' need' to reply. is to provide examples of the kinds of statements and. '
i i
issues which must be responded to so that this Board will'have a more accurate portrayal of the facts and issues contested before
'i t.
The Governments stress that these are only a few examples, which are presented in summary form.
If granted leave by the Board, the Governments would develop these points, and many others, in greater detail.
'(footnote continued from previous page) i stand alone, they are there side-by-side on many issues with the
'LILCO Reply Findings, albeit very different in tone.
Given the need to reply to LILCO's numerous misstatements, the Governments believe it would be useful if brief reply were also made to limited portions of the Staff Findings. _ _ _ _ _ _
Ki
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fi X-o 1
1.-
Leaal Standard.
At page 3 of its Reply Findings, LILCO E
L states:
"(T]he. Interveners offer this Board no guidance on the legal standard the Board.should use when reviewing the Shoreham Exercise."~ This is not accurate.
While LILCO may disagree with j
the legal standard urged by the Governments, LILCO has no basis for suggesting that the Governments " offer this Board no guidance" on the legal standard the Board should use in reviewing the results of the Shoreham Exercise.
To the-contrary, at pages 6-13 of the Governments' August 17 Findings, the Governments address in detail their view of the appropriate standard to be applied by this Board.
If granted leave to reply, the Governments would address the appropriate " legal standard" to be used by the Board.
Fur'ther, the Governments would demonstrate that LILCO, in its Reply Findings, has urged the Board to depart from CLI-86-11 and UCS.6 6
The Governments stress that the " legal standard" issue has been settled and that, in essence, LILCO is seeking to reargue points which it has previously lost.
The Commission in CLI-86-11 defined " fundamental flaws in the plan":
the Commission stated they were " deficiencies which preclude a finding of reasonable" assurance that protective' measures can and will be taken.
23 NRC at 581.
This Board has previously accepted this standard, stating that a fundamental flaw is "that which precludes a reasonable assurance finding Prehearing Conference Order, October 3, 1986, at 2.
LILCO and'the Staff urge that the UCS Court approved the NRC's predictive findings / fundamental flaw standard.
Staff Findings, at 3; LILCO Reply Findings, at 9.
This is wrong.
The Court cautioned that such a standard, if adopted by the NRC, might still be challenged under the arbitrary and capricious standard.
Egg 735 F.2d at 1448, n.20.
This Board has recognized that the NRC in CLI-86-il was dealing with the specific issues then pending before it and did not purport to address all issues (footnote continued) _ _ - _ _ - _ _ _ - _ - _ _ _ _ _ _ - _ -
l E
! th'is Board must ignore For example, LILCO argues that difficulties'in LILCO's capability to implement the. Plan, even if 1
the-demonstrated implementation difficulties' preclude a-
. reasonable assurance' finding.
In LILCO's view, if the Plan is parfect'as written, but LILCO response personnel are unable tcf l
implement it, the Board should ignore.the implementation failures l
E.q,,
LILCO.
because these'do not' reflect defects in the Plan.
1
. Reply; Findings, at 11-12, 14-15.
This. argument must be rejected for multiple reasons.
First, this Board.already.has rejected this LILCO argument.
Thus,'for example, in its October 3, 1986 Prehearing
' Conference' Order (at page 8), the Board stated:
Inherent in the matter of adequacy and
' implementation capability are the issues of the sufficiency of the exercise and its evaluation.
i The Board obviously would not have mentioned (Emphasis'added).
such matters were
" implementation capability" if it thought
.outside the scope of the proceeding, as LILCO claims.
Similarly, the ECS Court recognized that serious implementation difficulties would be proper subjects for. post-exercise litigation because l
such difficulties clearly are material to the licensing decision.
_Sgg QCS, 735 F.2d at 1451 (exercises "are evaluatea to ensure I
'(footnote continued from previous page)
L that might arise in the context of ECS mandated post-exercise l
l adjudication.
Sgg Prehearing Conference Order, October 3,
- 1986, at 3. _-
~
I that they do not. reveal any" fundamental inadequacies in the j
nature orLimolementation caoacity of emergency preparedness plans") (emphasis added).
Second,=LILCO's narrow focus in its Reply Findings is irrational.
How could~this Board possibly ignore implementation r
deficiencies which preclude a reasonable assurance. finding?
It could not, without opening the NRC to summary reversal in the courts.. Even the NRC Staff agrees that implementation issues are important if they preclude a reasonable assurance' finding.
E.c.,
Staff Findings, at 83-84.
Third, LILCO appears to believe that serious implementation difficulties can be ignored under the " predictive finding" rubric.
See LILCO Reply Findings, at 7.
This is wrong.
In CLI-86-ll, the Commission addressed its predictive finding concept but then made clear that issues material to licensing decisions must be available for litigation.
See 23 NRC at 581.
LILCO's " implementation" argument begs this Board to rule that implementation difficulties which preclude a reasonable assurance finding are immaterial to licensing.
That clearly is not true, I
particularly since 10 CPR S 50.47(a)(1) embraces the reasonable assurance standard. _1_____________
c - - - - ___ - _ __
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2.
Trivia.
LILCO alleges that the Governments' findings "are mired in trivia."
LILCO Reply Findings, at 4.
By way of example, LILCO points to the Governments' request that the Board
" concern itself about whether one particular message during the or ' gas truck' and whether day of the Exercise said ' fuel truck' the difference is significant."
Id.
LILCO urges that this sort of detail is contrary to the predictive finding standard and the Appeal Board's decision in Waterford.
Id.7 k
This Board must not be taken in by such extravagant claims.
The example in footnote 200 on page 203 of the Governments' August 17 Findings was but one example of many LILCO communications errors that plagued LILCO's response to the road impediment free-play messages during the February 13 Exercise.8 The LILCO response to road impediments was identified as'a
" Deficiency" by FEMA (FEMA Ex. 1, at 39) and a fundamental flaw by the Staff.
Staff Findings, at 83-84.
It hardly is conducive to reasoned decisionmaking for LILCO to urge that communications difficulties which arose during the Exercise in connection with LILCO's response to the simulated road impediment messages constitute " trivia."
Indeed, LILCO's assertion underscores 7
Egg Louisiana Power and Licht Company (Waterford Steam Electric Station, Unit 3), ALAB-732, 17 NRC 1076 (1983).
8 We address herein the example cited by LILCO at page 4 of its Reply Findings.
Presumably, LILCO chose to highlight that example at the outset of its Reply Findings because LILCO thought it was the most persuasive one it could find.
As discussed in the text, however, this example did further confirm and demonstrate a significant problem which LILCO still does not comprehend. - - - - - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
.i
'V LILCO's inability.or refusal.to understand the importance of the errors. committed by its personnel.
Rather than passing off as insignificant the failure of its personnel.to convey complete and accurate information, LILCO should recognize.-- and emphasize to its personnel'-- the need to do so.
Failure, for example, to communica'ce properly the type of spill involved in the simulated fuel truck accident could have produced an improper response to the-impediment.
Furthermore, it must be recognized that, in order to' respond. predictably and in a correct manner, there must be discipline in effecting accurate and complete communi~ cations.
LILCO clearly failed to do this.during the Exercise, for the many reasons cited in the Governments' August 17 Findings, the FEMA Report, and the Staff Findings.
All the parties except fo,r LILCO have found that LILCO's response to the road impediment fr[ee-play messages constituted a fundamental flaw in the context of communications and implementation capability of the Plan.
It is untrue, therefore, for LILCO to assert that such communications difficulties constitute. trivia.
And clearly, Waterford does not stand for the proposition that this Board can ignore evidence which confirms fundamental flaws in LILCO's Plan.
If granted leave to reply, the Governments would demonstrate I
that LILCO's many assertions that particular errors committed by its personnel during the Exercise were unimportant and of no These assertions must be corrected to consequence are wrong.
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4 assist the Board in identifying those critical errors committed by LILCO which underscore the fundamental flaws demonstrated during the Exercise.
3.
Contention Ex 15/16.
The Staff Findings and the LILCO Reply Findings on Contention Ex 15/16 are replete with misstatement, omission, and needless rhetoric.
In this motion, we provide only a few examples.
In contesting the Governments' claim that whether or not FEMA followed its traditional approach in defining the scope of the Shoreham Exercise is irrelevant to deciding whether the Shoreham Exercise was a full participation exercise, LILCO asserts that:
[Ilt borders on the absurd to believe that FEMA, the agency given the primary function when it comes to reviewing and testing emergency plans for nuclear power plants, proceeds about that task in a manner which'is inconsistent with the NRC regulations It is all the more remarkable when one recognizes that FEMA uses RAC Committees, which include NRC members, to oversee those review and testing functions.
and that the Commission has licensed plants or allowed plants with licenses to continue to operate based on FEMA's review and testing.
LILCO Reply Findings, at 21 (citations omitted).
With respect to the foregoing, however, LILCO omits what is relevant on this record.
There is no evidence that any person -- including the NRC RAC member for Shoreham -
provided any input on Appendix E - - - - _ _ _ - _ _ _ _ _ _ _ -
e I
R 1
issues.
The Governments. addressed this matter at pages 122-124 f
i of their August 17 Findings.
LILCO's reply is a smoke screen of unsupported argument.
The Board must reject such efforts to divert attention from this record.9 j
l t
A second example of the errors committed on Contention Ex 15/16 is the Staff's suggestion that the FEMA witnesses testified that the Shoreham Exercise satisfied Appendix E.
Staff Findings, at 13.
The record could not be more clear that the FEMA j
l witnesses took no position at all on the NRC's regulations.
- Eeg,
]
l e.a., Governments' August 17 Findings, at 39, 81.10 9
If the Board reviews Volume II of the LILCO Reply Findings with care, it will find (to the extent that Volume II is understandable) that many of LILCO's " responses" do not deal with the issues which were being addressed in the Governments' August 17 Findings.
For example, at page 88 (Finding 123) of the l
Governments' Findings, it is argued that FEMA evaluation of
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particular activities is necessary in order to satisfy the
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Appendix E " verification" requirement, and thus ingestion pathway i
and recovery and reentry activities must be deemed to have been
]
omitted from the Exercise since there was no FEMA evaluation.
LILCO's response to Finding 123 is a nonsensical " unjustified inference," followed by "See FEMA Ex Exh. 1 at 3-5 (FEMA had l
observers in all major facilities.
All or virtually all LILCO i
personnel were evaluated)."
LILCO's " response," in fact, does j
not respond to the point made by the Governments.
Thus, the l
Governments' argument has not been contested, despite LILCO's j
declaration to the contrary.
Based upon the foregoing, which is i
but one of many examples that could have been selected, the l
Governments submit that they must have an opportunity to respond l
to the LILCO Reply Findings so that they can point out the many 1
instances of LILCO failing to dispute the matters asserted by the I
f 10 The Staff's Ex 15/16 Findings contain other serious j
misstatements as well.
For instance, the Staff states:
" WALK
/
Radio would not participate in the February 13, 1986, Exercise."
Staff Findings, at 19 (emphasis added).
The Staff cites page 107 h
of the FEMA testimony for this proposition.
That testimony, l
however, simply states that WALK Radio "did not participate."
FEMA Ex.
5, at 107 (emphasis added).
And the record is clear (footnote continued) l
! l 4
4 Another example supporting the Governments' request to reply to the LILCO and Staff Findings is LILCO's assertion that the Governments improperly relied in the Contention Ex 15/16 context on FEMA evaluations from other exercises.
LILCO states:
Where, for example, the Board limited or rejected information from other exercises contained in FEMA post-exercise assessments on the ground that the information was unreliable because it could be given a variety of interpretations, the Interveners now cite that information as though it were unchallenged, affirmative evidence.
- See, e.q,,
I.F.60 n.49, 72 n.68, 98 n.75.
LILCO Reply Findings, at 3; igg also LILCO Reply Findings, Vol. II, at'4-5, 12-13, 14-15.
LILCO also accuses the Governments of "misus(ing] the record in their findings..
LILCO Reply Findings, at 3.
These are serious accusations ~.
If given the opportunity to reply, the Governments will show that, in fact, it is LILCQ which has misused the record by citing
-evidence out of context and for purposes other than those for which the evidence was admitted.
For example, the passage quoted above implies that this Board struck LILCO's Contention Ex 15/16 other-exercises tectimony because the information in other FEMA reports "could be given a variety of interpretations."
When the record is (footnote continued from previous page) that LILCO's witnesses did not know why WALK had not i
k participated.
Egg Governments' August 17 Findings, at 44.
- Thus, there is no evidence that WALK Radio "would not participate" in i
f the Exercise.
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reviewed,ohowever, it is clear that LILCO has misstated the l
- Board's ruling.: The Board did not state that the underlying reports wereLunreliable.but that LILCO's testimony was unreliable, since,Lamong other things, the LILCO witnesses had not per' formed the review presented in the testimony.ll
,Further, it was proper for the Governments to have cited the j
I exercise reports as they'did.
The three' subjects -- EBS, ingestion pathway, and recovery and reentry -- were each
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supported by. testimony to the effect that FEMA has required more
= testing on these subjects during other exercises than was 11 Thus, for example,.when Mr. Zeugin asked the Board to explain'"why it decided'to strike all that material" (Tr...,6090),
the Board responded:
JUDGE FRYE:
We are concerned about -- I can't' i
say' reliability so much as we are about how' j
useful it would be, given the involvement of j
these witnesses in its preparation.
They have themselves testified that it involved judgment calls.
l s
They have a number of people who have, using i
their criteria,'gone through these exercise I
reports and exercised their judgment.
Those l
people are not here, and we have to rely on j
Mr. Daverio and Mr. Behr to indicate how they j
used that judgment.
j So, in our view the reliability of it, in the i
sense of how useful it would be in preparing a l
decision, was pretty slim.
I JUDGE PARIS:
There are six people identified, i
including these gentlemen, as being involved j
in the review, each of whom,'according to
]
their testimony, reviewed three.
And, that leaves 15, according to my figures, reviewed 4
by a person or persons unknown.
Tr. 6090-91. _
I Pe r accomplished ~for Shoreham.
- Eee, e.g., Governments' August 17 Findings, at1 1-42,.63-65, 68-69.
And notwithstanding LILCO's 4
rhetoric, it is clear that the Governments accurately cited the reports which they relied upon.
In Attachments 1, 2,
and 3 hereto, the Governments attach the exercise report pages.which-support the Governments' footnotes 49,168, and 75, respectively, i
Lthe three footnotes to which LILCO objects.
When the Board reviews these report pag'es against the Governments' footnotes,
-the Board wi.'. conclude that the Governments have'been fair and accurate.in summarizing the. evidence of record.
No interpretation-is required for the uses made ofLthis evidence by the Governments.
Thus,'LILCO's transparent effort to create confusion should
.be rejected.
LILCO's response to footnotes 49, 68,-a'nd 75 (LILCO
' Reply Findings, Vol. II, at 4-5, 12-13, and 14-15) does not b'asically dispute the accuracy of the Governments' Findings but, rather, generally argues about what.was not shown in the exercise reports.
That is simply not the inquiry before this Board.
l Notwithstanding LILCO's extensive discussion, the inescapable conclusion is that these data support the finding that the scope of the Shoreham Exercise was so limited that regulatory requirements were not satisfied.
1 - - _ _ - -
4 4
l Contention Ex 15/16 was hard-fought on the record.
The LILCO and NRC Staff post-trial briefs on this issue, however, l
ignore much relevant data and misstate and confuse the evidentiary record that was developed.
The Governments submit that there is an urgent need to set the record straight on Ex 15/16.
l 4.
Contention Ex 41.
LILCO misrepresents facts presented
{
in the Governments' Findings by stating, for. example, that the Governments "never directly address LILCO's argument" th'at the LILCO Plan contains an oversupply of Road Crews or that the slow mobilization of these Road Crews would not have affected the public health and safety.
LILCO Reply Findings, at 32.
Contrary to LILCO's misstatement, these issues were addressed by the Governments at length.
Set forth below are excerpts'from the Governments' August 17 Findings (hereafter, "G.F."):
o (G.F. 226 n.157)
LILCO's witnesses asserted that the LILCO Plan calls for more Road Crews to be mobilized in the event of an emergency than would actually be needed.
Thus, in LILCO's view, it could protect the public's health and safety even if, as was true during the Exercise, only some Road Crews were mobilized and prepared for dispatch when an order to j
evacuate is given.
We disagree.
. Even in the event of a partial EPZ evacuation (such as was the case during the initial portion of the Exercise), LILCO's Plan calls for all 12 Road Crews to be available for immediate dispatch into the field.
These Plan provisions presumably have a rational basis.
It is reasonable to conclude, for example, that serious accidents will likely occur early in the evacuation process, while vehicles are moving at relatively high speeds Thus, assuming that the public would await LILCO's evacuation advisory before attempting to evacuate (as LILCO would have us - _ _ _ _ - _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _
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believe), it is important.tnat LILCO follow its Plan and dispatch all Road Crews upon' advising the public to
' evacuate.- Dispatching.only some-Road Crews to Ohly some of.the pre-assigned fie1d locations (which/)tayo,r 3
may-not be near accident scepes)'is, unacceptable /
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lo; (G.F.'235) ~ LILCO admitted.that. delays in the Mobilization, d,ispatch, and' deployment of Road Cfeus occurred during'the Exercise.
LILCO contended,
'however, that these delays were unimportant, because the number:of Road / Crews which it mobilizes under its Plan f ar. exceeds the number of Road ' Crews that would brv i'
J, needed in an actual emergency.
y o
'(G.F.
236)
As noted earlier, we are".30t persua66d by LILCO's argument.
First'c i
(G]iven that Road Crews'are,'t o
(G.F. 237 n.167)-
it is apparent thJ.
positioned up to four miles apart, at least 12 Road Crews are needed if LILCO is to have any realistic chance of achieving its goal of removing impediments from various areas of the EPZ in an.
expeditious fashion.
. q.
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.(G.F.
238)
[W]e conclude that LILCO would. lip.Ely experience significant problemn in getting its R'oadt l
Crews.to'their posts in the field"in a timely l
As a. result, we'are unable to find that j
manner.-..
LILCO would be capable of implementing the protective N.y action of' evacuation in'the event of a Shoreham accident o
(G.F. 238 n.168)
As a result, LILCO's response j
to the simulated roadway impediments [wasji at best, ad-l hqq and inadequate to protect the public's-health and j
safety.
o (G.F. 239)
(A'Jn effective radiological emergency j
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response plan must be capable of detecting roadway obstacles and removing them promptly.
S II.J.10.k.
Failure to do so during an evacuation on
]
Long Island would, in our opinion, likely cause t
J substantially decreased rates of traffic flow and roadway capacities, thus lengthening evacuation times and increasing the likelihood that evacuees would be exposed to harmful radiation.
A failure by LILCO to deploy personnel promptly to remove obstructions on i
evacuation routes could make it impcssible to implement' ef fectively the protective act. ion of evacuation.
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v9 The above excerpts make clear that LILCO has seriously
'4.
d$storted'what the-Governments have said and argued.
Thus, the
![I Governments should be given an opportunity to correct the record.
Two other Contention Ex 41 examples underscore this need.
(
a First, LILCO '/biates that ' the Governments' Findings do not J
argue "that a giveh terbuting scheme was unique" or that "the ones chosen by LERI.i vere wrong."
LILCO continues by alleging that the Governments 40 not suggest that the reroutingfachemes of fered by Suf felli Coiinty's witnesses would have had a "significantly different effect on public health and safety."
LILCO Reply Findings, at 34.
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The Governments' Findings state quite the opposite; they demonstrate that LILCO's schemes were not the best and would'.have resulted in delays to people attempting to leave the EPZ.
As a
' result, the possibility of evacuees receiving increased radiation exposure was heightened.
'o (G.F. 307)
The County' witnesses were extremely I
critical of this LILCO rerouting scheme, contending that there war. an' obvious, simpler and better solution to the impedinent o
(G.F. 308)
The rerouting schemes proposed by LILCO and the County for the fuel truck impediment also were dramatically different o
(G.F. 310)
At the outset, we observe that the key to rerouting traffic properly around the gravel truck
' impediment would have been to have redirected traffic away from the impediment quickly, so that significant I
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congestion would'not have occurred at the impediment
site.
The same would have been true, of course, for the fuel truck impediment.
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'(G.F.'312).... [C]ontrary to LILCO's claim, Walt'ers Street presented the dovious and. logical way to reroute traffic around the grhvel tru2k impediment.
We reach this conclusion.primarily because the-impact of the-gravel. truck impediment could have been minimized by.
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using Walters Street (G.F. 312 n.219).
Using Walt 5rs Street would have had /
o the additional' advantage of sending traffic quickly toward the Long Island Expressway ortthe Sunrise j
Highway,-which are the ways, under LILCO's Plan, tha(
// l) traffic in this area is expected.to evacuate the EPZ j
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'(G.F.
K13 LILCO inexplicably failed Lo adopt this
' simple?rer) outing scherrp....
of l
4 3
o-(G.F. 314)
We theref6te agree that the obvious and best' solution to the gravel truck impediment.would.have abeen to have diverted c~raffic onto Walters Street and 5
Everett Drive Moreover, justlas,the rerouting scheme. advocated by Suffolk County had'many adva'ntages, so too did the rerouting scheme adopted by LILCO'have
]
(7]f LILCO's:rerou*.ing scheme.had
/ disadvantages
' ' actually been implemen6;ad fg a real emergency, hundreds of evacuees would likely have become lost or confused.
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o (G.P. 315)
(W]e conclude that the rerouting scheme proposed by the County's witnesses was a significantly bettcr scheme than the one LILCO adopted on the day of the Fxercise.
The County's scheme would have been easy a'nd dfficient.
LILCO's scheme was not
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only more difficult and time-consuming; it also would
'have resulted in traffic meandering without supervision.
This would have had serious ramifications for the evacuating public.
o (G.F. 316)
We also conclude that there were better ways than the way emp}oyed by LILCO to have rerouted 3 traffic around the ftel truck impediment
'o' (G.F. 31'8I j... (R]ah.her tnan directing traf fic onto the already congestedmNorth Country Road, as LILCO did during the Exercise,'we agree with the County's
^
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witnesses that traffic should have been allowed to continue west on Route 25A,.ugtil coming to its r
intersection with Radio Avenue.
We conclude that this would have been a better.,terouting scheme than the one adopted by LILCO
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LILCO claimed that, for a variety of reasons, its (fuel truck] rerouting scheme was at least as plausible as'the one articulated by the County..
'After reviewing both LILCO's and Suffolk County's testimony, we conclude otherwise j
o
.(G.F. 318.n.224)
LILCO's scheme also would have resulted in evacuees taking.much longer,to leave the
.EPZ o:
(G.F. 319)
.le addition to failing to employ appropriate' rerouting schemes during the Exercise'.
Second, LILCO claims that the Governments " attempt to dismiss with scant discussion" the impact of FEMA's method of inputting-and evaluating the impediment free-play messages --
u l factors which LILCO claims " contributed to the. delays in'LERO's response" to the roadway impediments. -LILCO Reply Findings, at 33.
LILCO. fails, however, to acknowledge (except in an odf-handed way; ggg LILCO Reply Findings, Vol. II, at 54-55) that the method employed by FEMA on the day of the Exercise to " input" the frea-play messages was consistent with the approach that has been used by FEMA during all other Region II exercises.
Egg, gzg2, 3
Governments' August 17 Findings, at 182 (Finding 254).
For this
.IJ reason, the Governments submit that LILCO's complaint is entitled to.little or no weight by the Board.
5.
Contention Ex 34.
LILCO misinterprets and distorts the record by claiming that the Governments' position in their
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Findings that NUREG-0654 requires, within 45 minutes of initial 1
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siren notification, backup route alerting to be completed,
' departs from their witnesses' testimony.
LILCO Reply Findings,.
1 at 36.
l LILCO is wrong.
The Governments ~ consistently asserted --
-throughout their pre-filed testimony, during cross examination,12 and in their Findings!-- that the completion of backup alert notification within 45 minutes is a regulatory requirement.
For 1
example:
(Pre-filed testimony, cited as Roberts and'Michel, ff.
o Tr. 1495, at 6-7)
It is our understanding that as of the time of the February 13 Exercise, LILCO was required to demonstrate that its route alerting personnel had the capability of providing notification, within 45 minutes after the simulated failure.of LILCO's siren system, to any segments of the EPZ population that would not have been initially notified of the emergency at Shoreham.
o (Tr. 1537)
(B]ackup system is a requirement (Roberts).
I agree with Chief Roberts (Michel).
o (Tr. 1538-39) 0654 requires that 100 percent of the people - minimally within the plume exposure area shall receive notification within 45 minutes (Roberts).
o (G.F. 353)
Further, the language of NUREG 0654 is clear and unambiguous:
it requires that, within 45 minutes of initial siren notification, any segments of the EPZ population who may not have received notification must be alerted to the emergency.
12 Although LILCO seeks to make much of the fact that there was some initial confusion on the part of the County's witnesses on Contention Ex 34 (agg LILCO Finding 247), the witnesses concluded their testimony by leaving no doubt that, in their view, it is required that completion of the backup alert notification function must be accomplished within 45 minutes.
See Tr. 1537, i
1538-39 (Roberts, Michel). l-L
f I
6.
Contention Ex 50.
On the training issues, the LILCO Reply Findings again misstate and distort the record.
Some examples include:
According to LILCO's witnesses, the distribution of box o
lunches contributed to delays at the Riverhead Staging Area,-but caused no delays at the other staging areas.
Tr. 2098 (Weismantle).
LILCO, however, ignores the record by claiming that the distribution of lunches was also responsible for some of the delays experienced during the Exercise in mobilizing Traffic Guides at the Port Jefferson Staging Area.
LILCO Reply Findings, at 65.
In pointing out that the Board has indicated t' hat it o
intends to use the Goodkind analyses only as background, LILCO claims that its " Proposed Findings do not press those arguments."
LILCO Reply Findings, at 71.
However, LILCO contradicts itself by using the Goodkind analyses to attempt to substantiate its claim that LILCO's performance in the Exercise was as. good as or better than that of other offsite emergency.r'esponse organizations.
LILCO's Proposed Findings, Aug.
3, 1987, at 188-189 (e,q,,
the analyses do provide some confirmation.
that the performance exhibited in the Shoreham Exercise showed a level of training and preparedness comparable to that of other exercises for operating plants in FEMA Region II").
LILCO attempts to back up its assertion that delays o
with Traffic Guide mobilization on the day of the Exercise were merely ad hoc occurrences by claiming that there were "no significant problems with Traffic Guide mobilization" in the post-Exercise training drills.
LILCO Reply Findings, at 65.
This is refuted 1
by LILCO's own witnesses, who testified under cross-examination that LILCO could not mobilize all its pre-staged, pre-equipped and pre-assigned Traffic Guides from the Port Jefferson, or the Patchogue, or the Riverhead Staging Areas within an hour during the December 2nd drill.
Tr. 2126-28 (Weismantle).
In the December 10th drill, not all the Traffic Guides from the Riverhead or the Patchogue Staging Areas were able to mobilize within one hour.
Tr. 2128-30 (Weismantle).
LILCO argues that the Governments use " selected o
incidents of inadequate performance" from the post-Exercise drills as a basis on which to argue that the l
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'LILCO training _ program is fundamentally' flawed.
LILCO further claims ~that.no pattern of problems was shown.
LILCO Reply Findings, at 69. 'LILCO is wrong.
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-Incidents of inadequate performance have consistently occurred during. post-exercise training drills at all
'three staging areas,-indicating that these problems are pervasive'and'that LILCO's training program is fundamentally flawed.- Sag, e q,, Governments' August 17' Findings, at 516.
'As noted at the outset, the examples cited herein represent
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only a few of.the many' instances in the LILCO Reply Findings and the Staff Findings where.an. opportunity to reply is essential'.
Given the magnitude of the LILCO Reply Findings, the Governments request two weeks from the date of a Board ruling.to prepare and file a reply.
Respectfully submitted, i
Martin Bradley Ashare.
Suffolk County Attorney Building 158 North County Complex Veterans Memorial Highway Hauppauge, New York 11788 Herbert H.
Brown Lawrence Coe Lanpher Michael S. Miller KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C. 20036-5891 Attorneys for Suffolk County _ __ ---
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Fabian G.
Palomino
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-Special Counsel'to'the Governor of-the State of New' York l Executive Chamber, Room-229 Capitol Building.
Albany, New York-12224 1
, Attorney for.Mario M. Cuomo, Governor of the State of New York' Dan &da6m as Ste1 hen B.
Latham 5
Twomey, La: ham & Shea P.O. Box 398 33 West Second Street Riverhead, New York 11901
. Attorney for the Town of Southampton I
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station performance on the basis of whether the initial EBS test
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message is aired within 15 minutes.
Tr. 7560, 7564 (Kowieski, Keller); 8655-56 (Kowieski).
It is also normal during exercises for FEMA to spot-check to ensure that tone alert radios are available at schools or other locations; on occasion FEMA has evaluated the activation of tone alert radios.
Tr. 8397-98 (Kowieski); 7591 (Baldwin, Keller).AE/
There is no evidence that FEMA has ever evaluated the performance of backup EBS stations.
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Egg, gtgt, SC Ex. 66, at xv (survey of six schools in Westchester County indicated all had tone alert radios, although one school reported its tone alert failed to sound), xviii (a sampling of recipients with tone. alert radios in Rockland County; l
all of those interviewed indicated that their tone alerts had activated during the Exercise), xxi (tone Elert radios at only two of the five schools visited in Orange County on the day of the Exercise worked); SC Ex. 63, at 27 (spot-check of schools, nursery schools, and special facilities including nursing homes and hospitals in Westchester County indicated that such institutions were equipped with tone alert radios that worked well), 39-40 (a number of facilities that were to receive tone alert radios were surveyed in Rockland County; many reported that l
the units functioned properly); SC Ex. 65, at 45 (two schools in i
Westchester County were equipped with tone alert radios), 63 (two schools evaluated in Rockland County; tone alert operated properly at one school, but failed to operate at the other);
SC Ex. 76, at xii (officials at four schools in Oswego County visited by the observer were aware of what to do when tone alerts sounded; all tone alerts activated simultaneously when sirens were sounded); SC Ex. 71, at 41 (officials of Bay Road School and Little Windmill Day Nursery indicated their tone alerts had sounded); SC Ex. 77, at 44 (spot-checks of public awareness included hotel / motel staff, schools with tone alert radios);
SC Ex. 75, at 41 (verification of tone alert activation was confirmed by the sheriff and fire and emergency medical services coordinators in the EOC). _
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ftnin the scenario time frame. In some instances, it may be necessary to evacuate
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feekskill prior to surrounding areas to ensure an orderly departure.
Due to efreumstances related to scenario events, the county was able to safely evacuate these
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p anning areas. However, it is suggested that an additional review be conducted to j
f determine whether there are more improved methods of evacuating Peekskillin times of rapidly escalating events.
Public information staff performed their assigned tasks well and displayec adequate training and knowledge. All EBS messages were issued within 15 minutes. It I
should be noted, however, that EBS messag.e #6 was not fully coordinated with the county and this impacted the county's knowledge of its content.
In addition, the County
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Executive restarted the EBS clock for EBS message #2 announcing school evacuations j
because of confusion at the Joint News Center over whether it was appropriate to issue
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an EBS message or a news release when a protective action recommen.dation called for
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school evacuation. The current county plan calls for public notification of school evacuations via news releases, not EBS. Finally, some information in EBS messages conflicted with information contained in the brochures distributed to the public.
A survey of six schools indicated all had tone alert radios and knowledge of j
procedures to be fellowed in the event of an accident, although one of the schools
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reported that its tone alert radio failed to sound on the day of the exercise and none of the school personnel interviewed w'ere aware of the rumor control telephone numbers.
Miscellaneous visits to other establishments, including those which are used heavily by transients, Indicated all had heard strens and most of them were. generally aware of the need to evacuate the area in case of an accident at IP-2, but that none remembered having received public information hbout what to do. No locations visited were aware of or posted transient notification information.
h.[ [x.
ROCKLAND COUNTY Initial and follow-up emergency notifications were received over the RECS telephone line. Notification of the Unusual Event and Alert emergency classification levels (ECLs) were received via the RECS telephone in the Rockland County Warning Point.
When the EOC became operational, the RECS communication function was transferred to the RECS telephone located in the accident assessment area. The county demonstrated appropriate communications links with the utility, state, most other counties and all county emergency response operations. A required telephone tie-line with the Bergen County EOC has not yet been installed. The RECS telephone line, executive hotline, RACES, radios, telefax and commercial telephones all functioned well throughout exercise. However, a backlog on the EOF telefax did result in delays in receiving some hard copy data at the Rockland County EOC.
All protective action decisions were discussed and coordinated with the State and the other three counties. The Rockland County Director actively participated in the four-county decision to sound the sirens as demonstrated during the Alert ECL.
EV
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Local police personnel responded to the simulated impediment on the evacuat route.
Response to the scene was timely and efficient. The problem was quick evaluated, appropriate decisions were made at the scene and promptly communicated to the EOC. Arrangements were made to obtain the equipment necessary to clear the
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impediment, but equipment to handle the impediment problem was not actually deployed I
to the scene. Additional personnel were requested to reroute the evacuation traffic.
l Two (2) traffic control points were established by State and local police personnel.
Both traffic control points were established in a timely and efficient manner. All personnel were well aware of their assignments and were knowledgeable of all appropelate actions.
1 Interviews were conducted at two nonpublic schools in the Rockland County portion of the 10-mile EPZ. Neither school had any procedures for early dismissal or evacuation. Furthermore, the school principals were not aware of plans fo'r the potential l
i evacuation of schools including knowledge of where to' get bus transportation, or the location to which children would be evacuated.
According to school officials no radiological emergency information and instructions have been provided to parents of students at these schools for three (3) years. The two principals expressed concern over the lack of planning for the schools. The principal of one of the schools has documented requests for maintenance of the tone alert radio which has not been performed. After the exercise Rockland County provided written evidence that assistance had been offered to all schools within the 10-mile EPZ. Neither of the schools Interviewed had requested planning assistance nor had Rockland County followed up on their letter offering assistance.
Emergency worker radiological exposure control was generally adequate although some corrective actions are necessary. Adequate dosimetry and K! was provided to the field monitoring teams and they were well trained in their use. Bus drivers for the school and general population evacuation routes were equipped with adequate dosimetry, however, one bus company was substantially underequipped with dosimeters to outfit all the drivers that may be needed in an actual emergency and less than 10% of those drivers had training in dosimetry use. While state police were well trained and equipped, local police units demonstrated Instances of missing or unprepared equipment and lack of training in dosimetry use, exposure limits and proper use of KI.
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7 A sampling of recipients with tone alert radios indicated there was an adequate
)
knowledge of procedures for their use and maintenance.
All of those interviewed Indicated that their tone alert had activated during the exercise, and each understood the meaning of the stren and tone alert signals. However, seven of those interviewed did not have or had not seen a current emergency information brochure.
Based on a limited number of spot-checks of motels and residents of the 10-mile EPZ, additional public information efforts are needed. Three of the five motels visited on the day of the exercise did not have any public information available for visitors.
I.ess than half of the residents who were interviewed understood the meaning of the sirens.
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The tone alert radios at only two of the five schools that were visited on the day,
of the. exercise worked when the notification system was activated.. The Provost Marshall of the U.S.-Military Academy stated that they have tone alerts but do not know s
how to properly utilize them and would appreciate training. Ten people in the EPZ who were Interviewed did have the informational brochures and knew what the sounded sirens meant.. Two hotels visited did have information on emergency response posted in the -
rooms and one, the Hotel Thayer in West Point did not.
Three ' schools were visited.
In one, emergency response procedures were available and the authorities were knowledgeable.
In the other two schools, the individuals interviewed were only vaguely aware of emergency response procedures.
The Orange County medical drill never took place because a s,imulated victim was never provided.
Two ambulance crews were at the scene, but, they could not demonstrate the ability to monitor and treat a contaminated, injured person. In addition, the hospital (Herton Memorial) did not demonstrate their procedures because they were never alerted that a patient was on the way. However, a remedial medical drill was held on July 22,1986.
PUTNAM COUNTY 1
Facilities and resources, including Internal communications, displays, and security adequately supported emergency operations at the EOC. However, some events
[
were not posted promptly on the stat 0s boards in the operations area and the radio area and there was no key events status board in accident assessment. All personnel were
. promptly alerted and mobilized, and 24-hour continuous emergency response capability was demonstrated.
The County Executive was in charge and made decisions on protective action recommendations af ter consulting with appropriate staff members.
The Civil Defense Director had the responsibility for activating the EOC. The EOC was operational at about 0827, around 12 minutes after the Alert notification had been received at the EOC.
Communications at the EOC were generally excellent. The RECS line was functional and the executive hotline was used to coordinate decisions with the other three plume EPZ counties and the State. Each agency representative in the operations area monitored telephone contact with their counterpart. All necessary locations and agencies were contacted. Radios and RACES were available as backups and RACES was used to communicate with the county fleid monitoring teams.
P!O functions were handled well'. The Courity Executive dictated summaries of EBS messages to the lead PIO for transmittal to the Joint News Center (JNC) after decision makers had reached concurrence on implementing protective actions. The County Executive also informed the P!O of decisions such as the opening of congregate care centers and this information was checked prior to being relayed to the Joint News L
Center ' for release to. the public.
The PIO also em'ised initiative in requesting information from operations staff and responded to retuests for information from her counterpart at the JNC. It should be noted that when thc /10 requested an EBS message 1
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-.-_._._____.._________________.__g
27
,. 4 the ' cxceptien' of populations at Kings College in Briarcliff Manor' and St.
Augustine School in Ossining, most of the people interviewed in the field on.
the day-of the exercise reported to federal observers that they heard the alerting' sirens. However, based on spot-checks by the federal observers, most of the public interviewed did not understand the asaning of the sirens nor. did l
they know that they were to listen to EBS messages broadcast over WABC (AM 770).
(See Sec. 2.3.5 for a discussion of public education issues. )
A spot-check of schools, nursery schools, and special - f acilities including nursing homes and hospitals. indicated that such institutions were equisiped with tone alert radios that worked well.
The successful notification of. schools with tone. alert radios was verified by. federal observers in the i
field' and staff at the county EOC.
The EBS worked well.
PIO staff at t he' Westchester. County EOC coordinated the preparation of EBS asssages and simulated their dissemination through the joint media center in Verplanck, New York.
.hb 2.4.5 Public and Media Relations overall public and media activities need improvement.
However, the system for. handling media relations through the joint media center in Verplanck, New York, was very effective; no inquiries were received at the Westchester County EOC.
(See Sec. 2.3 for further discussion of joint media center operations. )
Despite efforts by Westchester County in recent months including releasing public service announcements and newspaper advertisements, there was little evidence that the public understands what they should do in a radiological emergency.
The new public information brochure has not yet been distributed to the public, nor was there evidence that notices had been posted to inform transients of the alert and notification system and action.s they should take in the event of a radiological emergency at the Indian Point Nuclear Power Station.
Although the public education program is on going in Westchester County, a new instructional brochure that is being finalized had not been distributed during the last year p rior to the March 9 exercise.
Spot-checks on the day of the exercise of hotels and motels showed that signs or notices ' had not been distributed to or posted in hotels and mocals to provide emergency information to, transient. populations within the IO-mile plume exposure pathway EPZ.
The lack of awarenes's among some Westchester County residents regarding what they should do in the event of a radiological emergency limits the effectiveness of the prompt alerting and notification systems.
(See Sec. 2.4.4.sbove.)
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The rumor control telephone number was tested by federal observers in Westchester County and the information obtained was excellent.
i j
7-39 g - p-(
e Deficiency:
DOH personnel based in Monticello were unfamiliar with procedures for 24-hour continuous emergency response operations-(NUREG-0654, II.A.4).
e-Recommendation:
DOR personnel with duties in Rockland a'ditional training in Rockland d
County should be given County plans and procedures.
e Defielency:
The bus company cotenunications which were activated for the exercise to communicate with both the EOC and its drivers depend on commercial telephone lines exclusively; these. lines may be unreliable during an actual emergency (NUREG-0654, II.E.1, II.E.2).
e Recommendation:
Each Rockland County transportation company with an emergency response mission should acquire equipment to permit radio communications with its vehicles and with the transit coordinator in the EOC.
2.5.3 Emergency Operations Management Emerge.;ty operations management by the state management team in the EOC was good.
The state DPC representative demonstrated effective control of l
emergency response and held s:sff briefings on a regular basis. The emergency I
classification system was used correctly.
The state established field monitoring teams, PMCs for monitoring and decontaminating emergency workers, and a reception center for evacuees.
State personnel at these facilities demonstrated good capabilities.
2.5.4 Public Alerting and Notification Public alerting and notification in Rockland County were good.
The systems used for prompt notification of the public included outdoor sirens and tone alert radios at special ' f acilities.
The siren system and tone alert radios were activated at the Site-Area Emergency classification in a timely f ashion.
FEMA currently is develop $ng guidance and regulations that will constitute the requirements for fully testing alerting and notification systems.
Until this process is complete, only spot-check observations can be made of the effectiveness of these systems.
Field observers reported, on the basis of personal observation and interviews with residents, that the sirens generally were audibis within the 10-mile plume exposure pathway EPZ.
This is a marked improvement from the 1982 exercise, at which the siren system was reported by many observers to be -
inaudible. A number of facilities that were to receive tone alert radios were
.(.
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e 40 7
surveyed.
Many reported that the units functioned properly.
However, g
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locations have not yet received their radios, and other facilities where thd radios had been installed reported that their personnel had not been trained
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in cheir use.
Activacion of the EBS system was coordinated with the sounding of sirens within the 10 m11e plume exposure pathway EPZ and it functioned in an acceptable menner.
However, the public has not yet received the new brochure containing instructions to turn to the EBS station for information when the sirens are sounded.
This may limit the effectiveness of public alerting and notification in Rockland County.
(See Sec. 2.5.5 for a discussion of public education issues.)
During the exe rcis e,
the early dismissal of school children was simulated at the Alert classification.
This activity was ' reported in a (simulated) press release at 9:45 a.m., and in the first rumor-control tape shortly thereaf ter.
However, early school dismissal was not announced in an EBS message until 11:38 a.m.
The state's compensating measureJ and the school evacuation procedures should clarify procedures for notifying parents of early dismissal of school children.
2.5.5 Public and Media Relations Public and media relacions in Rockland County need improvement.
The 1982 post-exercise assessment questioned the effectiveness of the public education program in Rockland County.
As the Rockland County plan has not been complaced, no public education brochure has been distributed to Rockland County residents during the last year.
Spot-check interviews with residents
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on the day of the exercise indicate that, although the sirens were heard, the i
public is not-aware chac instructions are to be transmitted via EBS, and have l
no understanding of what protective actions may be required.
Several hotels in Rockland County within the lo-mile plume exposure pathway EPZ were visited on March 8 and 9,1983; none were equipped to advise their guests on steps to take during a radiological eme rgency at the Indian Point Nuclear Power Scacion.
Thus, the public education program for the permanent and transient populacion in the 10-mile plume exposure pathway EPZ needs to be improved.
The limited public education program in Rockland County impacts the effective-ness of the prospc alarcing and notification systems (see Sec. 2.5.4-u ve ).
Communications between c'he 'Rockland County 'EOC and the joint media center in Verplanck, New York were good.
State personnel demonstrated a good capability to replace county Pios at the Rockland County EOC and the joint media cancer in Verplanck.
State Pios at the two facilities coc:municated over a celephone line that was kept open chroughout the exercise.
Hard copy press releases and EBS messages were exchanged over the celefax.
At the joint media cente, che telef ax machine was not operating at one point. but this situacion was rectified..(See Sec. 2.3 for further discussion of joint media center operations.)
i Y
&,(. & $ V reception center locations. Traffic control personnel sh6uld be trained to know the
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location of reception centers since they would likely. be asked by evacuees-in an emergency. Barricades and.other traffic control equipment were available, but were not brought out to the TCPs for the exercise.
Personnel.at all TCPa had radio cornmunications with their command posts and with other patrol cars.
4 Principais of two schools. In We,stchester County were interviewed regarding radiological emergency procedures for Indian' Point. Both principals were famillar with their' procedures and with the information in the public education brochure (F 3). Both schools were equipped with tone alert radios. Officials at one of the schools interviewed, planned to use early dismissal as an emergency procedure. Officials at the other scho would prefer to evacuate to a designated school in Port Chester, New York, and parents have been so informed by school officials.
The organizational ability to effect an early dismissal of schools and an orderly evacuation of schools within the 10-mile EPZ was adequately demonstrated (F 4).
Westchester County announced the early dismissal of schools in ERPAs 1,2,4, and 6 at 0937 during the Alert stage, following consultation with county health, transportation, and school officials at the EOC. Buses were deployed and completed their routes in a timely manner. County officials activated the emergency notification system to all affected schools during both the early dismissal stage and a subsequent sheltering notification at 1320 for ERPAs 2,3,4, and 7.
Capabilities of five bus lines were demonstrated for the evacuation of the general population and schools within the 10-mile plume exposure EPZ (F 5).
At
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approximately 0930 the dispatch offices for the bus companies received notification of the need to implement resources to simulate the evacuation of schoolchildren which, according to the agreed-upon off-site scenario for the exercise, was to be demonstrated out of sequence. Soon after this notification had been completed in response to a controller message, the decision was made at the Westchester County EOC to dismiss school early. Personnel and equipment were promptly activated and deployed in a timely manner. Prior to their dispatch, bus drivers were properly briefed on evacuation routes, emergency worker exposure control, including dosimetry and the use of KI, the location of the reception center where schoolchildren would be delivered, and communication
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procedures. This corrects a deficiency observed at a previous exercise.
]
Buses were d!spatched from company garages and proceeded to the assigned schools in a timely manner. Fo!!owing the simulated loading of schoolchildren, the buses continued on to the various reception centers (at Harrison, High School, Fishkill Plains, j
and Solomon Schecter School). In general the bus drivers exhibited an adequate ability to find the pick-up points, follow the predecirmined routes, and deliver the students to the appropriate relocation centers. However, two bus drivers experienced some difficulties navigating in the field. In one instance, an incorrect location for the reception center I
was noted on the map provided, but the. driver had no difficulty in finding the proper location. Another instance observed a bus driver who was unfamiliar with the assigned routes. The driver was aided by the RACES operster on board the bus and managed to find all the stops correctly.
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the siren area map and the mobile unit was delayed in arriving at the field location until approximately 1220. Route alerting was initially demonstrated in the wrong area. Af ter police officers were told of the error and directed to the correct map of the area to be alerted, the unit completed their route alerting responsibilities, covering the appropriate area in a satisfactory manner. It is recommended that local organizations with backup
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route alerting responsibilities should be familiarized with the stren area maps and trained to complete this function in a' timely manner (i.e., within 45 minutes of the init!al notification). Standard operating procedures are recommended.
The capability to establish traffic control points in a timely manner to direct traffic and maintain access control to a potentially evacuated area was adequately
' demonstrated in Rockland County (F 2). State and local police units were dispatched to traffic control points (TCPs) and set up their posts in a timely manner. The officers observed at two of the three TCPs established for purposes of this exercise understood their responsibilities and were capable of managing access control with flares and cones or by using their police vehicle as a barricade. Both units were equipped with mobile radios for communications with their base stations if additional resources had been needed.
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The objective to demonstrate a sample of resources to effect an early dismissal of schools within the 10-mile EPZ was mixed, based on a small sample of two schools (F3). Tone alert radios had been issued to both schools. This receiver worked properly at one school, but failed to operate at the other school where school officials did not know how the unit should be set up and installed for operation. All tone alert receivers that have been issued to schools and other institutions should be checked to ensure that they are properly installed and operationally tested periodically. One of the schools has written procedures for the early dismissal of schoolchildren and these procedures have ~
been used in other situations (e.g., snow, boiler failure). A handbook which is provided to parents early in the school year advises parents to establish an alternate plan for where their child is to go in the event no adult is home. No telephone calls to parents are initiated when an early dismissal is effected by this school. The principal has attended several workshops and planning seminars on radiological emergency planning for schools.
The other school, with the inoperable tone alert radio, has no written j
procedures for the early dismissal of children. The informal procedures that are in place
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do not call for parents to be telephoned when an early dismissal of school is initiated.
I School officials at this school have not bean trained or received guidance on radiological j
emergency planning for schools and the prircipal was unawn re of a distinction between
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the early dismissal of students to go hor".e and the evacuation of students to a reception I
center. Training should be given 'to more than one official from each of the schools within the 10-mile EPZ to familiarize them with off-site radiological emergency planning j
in Rockland County and the interrelationship of the Rockland County plan with existing j
school emergency plans.
There is a-need for further evaluation of the level of j
preparedness of schools and staff in Rockland County.
]
The demonstration of resources necessary to effect an orderly evacuation of schools within the 10-mile EPZ was partially met (F 4). Per the off-site scenario, this demonstration involved activation of transportation resources to simulate the evacuation of students when the decision was made to implement an early dismissal of schools at the l
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n 2/13/86
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- s The ambulette used to evacuate the noninstitutionalized mobility-imp dispatched quickly, and the driver knew tne location of all four pickup poin was well-trained in the use of dosimeters and knew that only his supervisor c authorize the use of Kl.
i The County Department I
of Public Works responded quickly to the actual from the road. Both county personnel at the site o l
l dosimetry and knew that only their supervisor could authorize the use of Kl.
l The officers who' responded to conduct route alerting, due to the siren fa demonstration, performed their task in an efficient manner.
l The officers knew: the I
streets very well and traveled the area simulating use of their mobile public add system.
I
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j Officials at the four schools visited by the observer were all aware of wha when the tone alert radio sounded. All the tone alerts activated simultaneousl sirens were sounded during the exercise.
evacuation routes were posted in all the school offices. Maps of Emergency Plann Oswego County Police deployed from the U.S. Coas patrol was staffed by two County Police Officers, both of whom were knowle about special considerations for notifying the boating public.
School District of Oswego Bus Garage.The message ordering sc school enildren at the designated school. The bus was officially dispatched to pick up he initially drove the bus to the wrong school.Due to a misunderstanding on the drive radio, redirected the bus driver to the proper destination.However, the dispatcher, There were two demonstrations of general population evacuation bus route Prior to this demonstration, both drivers had been issued all materials n out their assignments.
designated pickup points, and called in dosimetry readings.The radio communications between the buses and dispatchers was experienced Public information brochures were displayed in the hotels visited during t exercise and the managers knew that information would be broadcast by a local E station.
Jefferson County The Jefferson County EOC has adequate space, lighting, telephones, kitchen and back up power.
Maps were well organized and a clearly visible status board was used.
There was ample and varied radio communication equipment including the availabil a hard copy device.
Overall, the Jefferson County EOC is an outstanding host county EOC.
i J
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risks developed by the county's accident assessment team and of technical information on plant conditions as a standard operating procedure.
the director and the radiological of ficer immediately briefed the county manager on the changing status and the radiological officer then briefed all agencies in the EOC.
As a result, the precautionary evacuation of pregnant women and I
children in ERPAs M2, M3, and M4 was initiated at approximately 10: 30 a.m.
during the site area emergency with no radiological release following the Wayne County evacuation of ERFAs W1 and W2.
At the county level, the county's own dose assessment information should be f actored into the protective action decision-making to a greater extent.
2.5.4 Public Alertine and Notification The public alerting sirens and tone alert radios used to alert schools within the 10-mile plume exposure EPZ were activated at the alert classifica-tion level at approximately 8:25 a.m.
Activation of this system was coordi-naced with Wayne County and was monitored at the Monroe County E0C using a i
All of the people interviewed in spot checks of the general '
population on the day of the exercise indicated that they had heard the sirens.
Of ficials of the Bay Road School and the Little Windmill Day Nursery indicated that their tone alert radios had sounded.
Both the tone alert radio and siren tone wsre heard at the Windmill Day Nursery, i
f The EBS was activated and the airing of the test notification message was well coordinated with activation of the public alerting sirens.
Airing of the EBS message was monitored by radio at the Monroe County EOC and in the field by federal observers.
These observations indicated that deficiencies vich EBS noted last year have been corrected.
EBS messages were good and 1
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contained necessary information.
However, EBS messages referred to public
)
education brochures for information on reception centers.
Some EBS messages also referred the public to telephone books for emergency information and EP.PA maps.
The referenced insert available in the latest Rochester telephone book was ince=plete because it did not include a map showing ERPA locations.
j Backup route alerting of the public using mobile public address units was not tested as an objective of this year's exercise.
2.5.5 Public and Media Relations Public and cedia relations were acceptable in Monroe County.
The l
calendars and public information brochures observed at the county ECC were infor=ative and could be easily understood.
These materials contained inf or-mation on emergency terminology. public alerting and notification devices and procedures, ERFAs, sheltering, evacuation routes, and bus pick-up points.
On the basis of spot checks of the general population in Monroe County, no one interviewed on the day of the exercise remembered receiving information brochure or knew that they should tu rn to the EBS station for a public 1
44
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s :.
Recommendation The Ontario Fire Department personnel that perform route alerting should be given additional training in emergency worker radiologist exposure control.
Description Bus drivers from the Williamson Center School drove Dosimetry buses ' that were not equipped with 2-way radios.
4.-
readings and requests for emergency information could not be
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promptly related to emergency managers (NUREG-0654, II, K.3.b K.4).
1 l
Buses to be used for evacuations should be Recommendattom equipped with 2-way radios.
' AREAS RECOMMENDED FOR IMPROVEMENT There were no areas recommended for improvement observed in Wayne County's Emergency Worker Radiological Exposure Control.
(DA 2.2.5 Public Awareness Strens were sounded at approximately 0925 and the duration wa l
minutes. Sirens were heard by federal' observers at 4 locations in th of steen soundings at other locations were receive EBS based on simulated stren failure was conduct interviewed.
1008 and later on the same station.
Spot checks of pubtle awareness regarding emergency meas Nuclear Power Station were conducted in Wayne County and in Fif teen of the twenty schools with tone alert ' radios, and the general population.
h respondents in the 10-mile EPZ said they had received the public s
calendar and maps of evacuation routes and location of reception ce d ts mixed interest in becoming familiar with emergency measures. Howe All but five were willing to cooperate and would evacuate if instructed to do so.
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respondents heard the sirens sound. Five of the twenty respond progress.
Based on limited interviews of local residents, some individua This exercise public information and they were not certain of emergency measures.
cise is objective was partially met (WCFleld 6) and i
- lation, l
While particularly migrant workers who may include o t.
The exercise objective involving transients was partially met (WCFleid 7) e L
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supplemental telephone and its designation in the county plan as a direct link
'C between the county nuclear facility liaison officer and the county EOC corrected two deficiencies identified at last year's exercise.
Several telefax machines were available for sending and receiving hard copies of RECS communications and other information to and f rom the state EOC and the EOF.
The radio system in the dose assessment room that was used for communications with the field monitoring teams has. been greatly improved since the 1982 exercis e.
In addition 'to the primary radio system, RACES operators were available for backup communications with the field monitoring teams.
Status boards in the dose assessment. room were used to varying degrees.
During the early stages of the exercise, plant parameters were not posted on the RECS message board until hard copy of the information was received via telefax.
This caused some confusion but was remedied by the early af ternoon when the radiological officer decided that the information should be posted on the RECS board as soon as it was received verbally. After this decision was made, the RECS message board was always promptly updated immediately af ter verbal transmissions had been received. The dose projection board and the field team status board were not updated throughout the entire course of the exercise. An effort should be made to update all status boards in the dose assessment room with the same ef ficiency with which the RECS message board was updated in the af ternoon.
The Oswego County EOC played the primary role in alerting the public.
At approximately 0930, the County Director activated the outdoor siren system from the county EOC and coordinated activation of the tone alert radios through the National Weather Se rvic e.
Spontaneous verification that the sirens had sounded was provided via feedback from a sherif f's mobile radio in the field.
Verification that all 37 ' outdoor sirens had sounded was received from the utility at approximately 1120.
Verification that activation of the tone alert radios had been successful was confirmed by the sherif f and fire and emergency medical services coordinators in the E00.
These coordinators received confirmation from their department offices, which are equipped with tone alert radios.
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The Oswego County public education program continues to be very effective.
Spot checks made by federal observers on the day of the exercise revealed that about two-thirds of those questioned remembered receiving the revised brochure that was mailed in August.
About two-thirds of those questioned also knew that the sounding of the outdoor sirens is a signal to turn their radios to an EBS station for' additional emergency information.
Airing of the test EBS message was closely coordinated with activation of the outdoor stren system and tone alert radios at 0931.
This initial notification and additional EBS messages were prepared by the Oswego County public information officer at the joint media center, who was in direct communication with the public information officer at the county EOC. A.11 EB S messages followed the prescribed message formats in the county plan and were supplemented with specific emergency details.
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f Shoreham Exercise and FEMA conducted no eval uation of any ingestion pathway activities.
FEMA omitted ingestion pathway objectives primarily in-reliance on the NRC suggestion that FEMA
-concentrate its evaluation on the 10-mile plume exposure pathway EPZ.
FEMA Ex. 5, at 125; Tr. 7525, 7539 (Kowieski); NY Ex.
1, at 147-48.
l 92.
It is feasible to conduct ingestion pathway testing without mandatory public participation and there is no conceptual reason why ingestion pathway testing could not be included in an exercise.
NY Ex. 1, at 149; Tr. 6003-005 (Hockert); 7537-38 (Kowleski).57./
Some ingestion pathway testing was conducted in early New York State exercises.
These activities exceeded the very limited ingestion activities (described below) which took place during the Shoreham Exercise.
Thus, they included matters such as reviewing the source term, calculating potential de' position, assessing potential food chain impacts, collecting samples of milk, vegetables, fruits or vegetation, and transporting samples.5.8/
5.7./
LILCO witness Hockert developed a draft guidance memorandum for ingestion exposure pathway testing.
LILCO Ex. 12, at 3; Tr. 5966, 6003-005 (Hockert).
FEMA's modular format for the conduct of exercises also includes. guidance for ingestion pathway EOC. observations.
NY Ex. 1, at 149 n.69.
5.8/
S.g.g., n, SC Ex. 63, at 17 (ingestion pathway samples were to be collected), 20 (demonstrated capability to obtain and analyze surface water sample; information on location of dairy farms within the 50-mile ingestion pathway EPZ was used in deciding how long farmers should keep cows on stored feed);
(footnote continued) e
In recent. Region II exercises, ingestion
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pathway. testing was omitted because FEMA has issued no' guidance on how it will evaluate ingestion pathway performance.
New York State.recently. refused to accept ingestion objectives absent such guidance.
However, that refusal was communicated to FEMA after FEMA had already' decided to have no ingestion pathway objectives in the Shoreham Exercise and thus played no role in the decision not to have such objectives.
NY Ex.
1, at'148-49; FEMA Ex. 5, at (footnote continued from previous page)
SC'Ex. 64, at 21 (decisions to recommend protective actions for ingestion pathway EPZ were good at,the SEOC; information was available showing location of dairy farms, food processing-
- plants, and water supply intake points; local agencies were provided with information to assist in implementation of protective actions, and ingestion pathway sampling was ordered);
SC.Ex. 65, at 22 (State was to exercise a limited demonstration of analysis and decisionmaking process for selection of ingestion exposure. pathway. samples consistent with problem posed by exercise parameters); SC Ex. 70, at 33 (monitoring teams from
. State agenc es enacted their plans to obtain measurements that i
would be important for longer term exposures, including doses through the ingestion pathway); SC Ex. 71, at 26-27 (the field response was good when SEOC ordered ingestion pathway sampling; field. sampling teams were dispatched to collect samples of fruits, vegetables, soils, milk and foliage; the teams were
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knowledgeable and collected samples in a timely manner; samples
]
were labeled, appropriate forms filled out, location of each j
sample.noted on a chart, and samples were given to State Police i
for express delivery to laboratory); SC Ex. 73, at 34 (ingestion pathway sampling consisted of collecting one milk and one crop s
sampler collection of other samples was simulated); SC Ex. 74, at 22 (timely and appropriate guidance concerning protective j
- measures in the ingestion EPZ, including dairy facilities, was given to local government by State agency representatives);
SC Ex. 75, at 30-31 (performance'of ingestion pathway sampling teams was. excellent; sampling was simulated and correct
. procedures were demonstrated), 25 (good protective actions for ingestion pathway EPZ were developed promptly; commercial produce embargoed; residents were advised to abstain from eating their
. garden produce).
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y Ingestion Samoling V
('b.
The state was to demonstrate the analysis and decision naking process for selection of ingestion exposure pathway samples consistent with the
' hypothetical problem posed by the exercise parameters.
Ingestion pathwa7 samples were to be collected primarily from open sources of public drinking water. Analysis of the samples was to be simulated.
S.C. Ex,63 j
L i
volunteer Organizations Volunteer response organizackons identified in the plans were to participate in the exercise.
However, f or purposes of the exercise, the staffing of these volunteer organizations was to be on an as available basis. -
t e
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l 2.1.4 Publie Alerting and NotifieAtton s.-
These functions were not. obse rved by federal observers reviewing activities at the state facilities in Albany and Poughkeepsie, New York, which are.both outside the 10 mile plume exposure EPZ.
2.155 Public and Media Relations At the state EOC in Albany, the PIO was well informed and provided evidence of 24-hour coverage in the EOC.
The PIO apparently had personnel
- available to circulate within the EOC to gather information.
At the joint, media center, state Pios assumed the lead PIO function af ter-the Governor's declaration of a state disaster emergency.. The emergency "I
public-information system functioned well.
State PIDs had access to pertinent information and there - were adequate channels for obtaining additional information to meet press inquiries.
All EBS mes. sages were approved by lead government of ficials on hot lines.
(See Sec. 2.3 for further discussion of joint media center operations.)
2.1.6 Accident Assessment Staffing for the radiological assessment unit was adequate to process and analyze the. data te.1emetered to the state EOC by the utility. Meteorolog-ical data were used to estimate the plume location by computer.
The EOC accident assessment staff was in constant contact with the utility.
In addition, the capability in the use of county and utility field data for locating and monitoring the plume boundaries has been improved compared to capabilities demonstrated at the 1982 exercise.
Programmable calculators are now available to expedite che calculations of projected dose to the general population.
In the 1982 exer-14e the absence of this equipment was identified as a minor impediment to the speedy analysf s of technical data.
f 2.1.7 Actions to Protect the Public Adequate staff was available to implement protective action procedures.
based on needs at the state EOC.
7 The state demonstrated the capability to obtain and analyze a surface water sample.
Plans were also in place to continue analysis until acceptably low levels of radiation are reached for recovery and reentry.
f Information on the location of dairy farms within the 50-mile ingestion exposure pathway.EPZ was used in deciding how long farmers should keep cows on stored food.
S.C. Ex, 69
- i 21 ga..
2.1.5. Actions to Protect the - Public The recommendation. of actions to protect SE0C.. ' The decision the public were good at. the to recommend evacuation and sheltering of various ERPA was evaluated on' the basis of the degree of s
'available ' alternative protective actions as well as the protection. afforded by the l implementation. ~of, the : alternative actions.
risks associated with duration of the release,' and anticipated ' changes in related fWeather con projected.
I
- considered.in determining. the most actors were all appropriate recommenda tion.
Changes in conditions.were carefully and 5pecific ' agency responsibilitiesrepeatedly examined for possible consequences.
were also reviewed by decision makers to
. assure that there. were sufficient' resources. to implement - the actions.-
1The' decision to recommend evacuation of ERFA recommended sheltering in ERFAs. 30 and 31 was implemented in a cisely fashi
. planned procedures.
on utilizing were also good at the SECC. Decisions.co recommend protective actio athwayEPD'
. dairy farms, food processing plants, and water supply intak were ' used in determining whether to place animals on scored feed.
I.ocal Criteria agencies - were : provided with information to assist in the protective actions, and-ingestion pathway sampling was orderedimplementation~
SC, Ex. WV 2.1.6 Health, Medical, and ' Exeosure control Measures Health, medical, and exposure control seasures at Personnel 'in command and control questioned whether the usthe SDEOC we'\\
authorized.
The decision makers and accident e of KI should be
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necessity for using KI and correctly concluded that assessment staff reviewed the given the. lack of radiciodine its use was not warranted PACS for authorizing in the postulated release.
Knowledge of the
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Noble gas exposures to emergency field worke discussions.
ese positioning verkers at the edges of. the plume and thus authorization to ex zed by
- PACS was. not required during the exercise.
ceed The RERIP does, however, indicate that the representative of the New York State Department of Health car.
authorite exposures in excess of PACS.
2.1.7.Recoverv and 9eent-v Goerations Recoverv and reentry operations'at on August 25, participants at the SEOC were. good.
At about OL:!O the SECC were verbally informed that recovery could be gin.
A discussion reentt/ and ensued needed to be taken.
'Jritten plans and procedures were followed by the centering on the actions which participants in the exercise during the development of a plan fo reentry.
The established procedures addressed all tecessary concerns r recovery and recovery and reentry planning, decision makers had complete access to al During participating agencies, both within the SECC and in the field
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' Relocation Centers'
,y At least one reception or congregate care center was to be opened and staffed for evacuees from each of' the four counties in accordance with respective local emergency response plans. Supplies required for long-term mass care '(cots, blankets.
food, etc.) did not need to have been acquired or brought to the centers. However, the center personnel should have obtained estimates on how many evacuees would be arriving -
l had the exercise been a real emergency. The center personnel should have then made the necessary estimates of supplies required for the-potential evacuees. Sources of the i
required supplies should then have been located and the means for transportation of the-l supplies should have been determined. A limited number of volunteers 'were to be processed through the registration procedure.
Procedures for monitoring and i
decontamination of evacuees were to be demonstrated at reception centers. Federali evaluators may have introduced free play problems of procedures for handling evacuees.
I arriving at a congregate care center without appropriate documents from the referral reception center..
Because of logistles and the need to make prior arrangements to gain access to relocation centers during an exercise, these centers were selected prior to the day of the exercise.
County Facility i
Westchester 1 - reception and congregate care 1 - congregate care (located in Putnam County)
Rockland 1 - reception 1 - congregate care (Bergen County, N.J.)
Orange 1 - reception and congregate care Putnam 1 - reception and congregate care (located 1
in Dutchess County)
Medical Drills There was to be a medical drill involving demonstration of handling and treatment of contaminated injuries at a hospital in Westchester County. The injured and contaminated individual was to be a licensee worker. The medica.1 drill was to involve treatment at the scene, transport by an off-site ambulance and subsequent diagnosis and treatment at an off-site hospital.
x Ingestion Sampling b>b bb [#6 The state was to exercise a !!mited demonstration of the analysis and decision-making process for the selection of ingestion exposure pathway samples consistent with l
tne hypoteetica1,,obiem,osed by the exe,cise,a,amete,s.
The state may have l
w-______-_______-__-_____-______
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1, 7 7.. Actions to Protect the Public L
- l.I State
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Actions to protect the.public were based on timely decisions made
.s.
L1 by.the; state.
The'actionsluere then.earried out on a local level.
The' I
state EOCs were kept : well-informed on the sheltering operations from the-counties.
Evacuation-plans were ef fectively made by the state, using current
,d Ey, 70
. information ' on ' road conditions and evacuation times.
t
/l State monitoring teams from the Departments of Health and Environmental Conservation enacted their plans to obtain measurements that would be impor-i tant for, longer-term exposures, including doses through the ingestion pathway.
This was in compliance with the emergency plan.
Total reliance on predicted doses for sheltering and evacuation planning and does, however, raise concern over the accuracy of such calculations.
Honitoring data obtained by the county were not effectively used
- by the state for accident assessment.
This may be due in part to the'short duration of the scenario.
l The absence of pre-planning between state, local governme.:.t, railroad, and Coast Guard was evident.
Recommendation:
e The s t acea should review the role'that short-term field j
monitoring data obtained by the NFO should have for such decisions as planning evacuation routes, and determine whether changes should be made in the way data are obtained and communicated to emergency planners. The state should also improve its means of access to data collected by the county.
(Re ference NUREG-065% H.12).
Honroe County The Honroe County personnel demonstrated a good capability to remove
- an injured contaminated individual from a simul ated traffic accid ent and to transport to the Rochester General Hospital.
The health physicist from the l
plant did not appear at the Rochester General Hospital, as planned.
The i
hospital's health physicist performed the necessary functions.
l L
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26 o
i officer.
This avoidable delay meant that unnecessary doses 'would have been ig received by people evacuating through the plume if the simulation had been a
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real event. In another instance, according to poncings at the soc, the field measurement of 100 mR/hr at 3 SW from Wayne County was received 45 minutes after the release.
If the state had utilized the county data p'd oeptly, there would have been sufficient time to calculate the whole bodjl ose at plume centerline and' thereby avoid the undue exposurt to field workers that would have occurred had the nimulation been a real event.
Additional training in the use of all field data should be undertaken to improve the state'f, capability to comprehensively assess the situation.
Other technical calculations were good and 'the state demonstrated the estimation of doses from raw counts-per minute data and. concentration data in uCi as reported from the plant.
It appears that the deficiency for not using county field data noted '
in last year's exercise has not been fully rectified.
The capability to locate and track the plume-and define its boundaries on the basis of the data utilized was good.
On 1.he basis of the dose rates actually calculated, the state radiological assessment team cembers showed a good working knowledge of protective action guides.
State laborawry f acilities were good and should be capable of h.Andling the volumes and typ is l
of samples expected.
During the exercise FDIA. was kept informed of the situation.
2.1.7 Actions to Protect the Public The state showed a good capability ta previ6s protective actions in the ingestion pathway EPZ.
However, as noted in the' hiscussion of Wayne County's request to euacuate ERPAs V3 and V4 in Sec.
2.1.6, the state does not fully utilize county field-monitoring dart in reaching its protective action decisions for the plume exposure pathway EPZ. This had also been noted during the 1982 exercise.
At the SECC, information was available on the locations of dairy f arms, food processing plants, and water-supply intake points.
Hovever, crop infor:ation was not available at SEOC and should be available for refertence.
Similar information for the western district, including crop informar.ior., was available at the WDEOC.
Seasonal crop information is needed to determine where ingestion pathway field-monitoring tea =s should concentrate their I
efforts.
Reservoirs in the plume path up to 50 miles cut were told by Health Depart =ent personnel at the WDECC to top off so chat er:tra supply of unconta:inated water would be available.,
The field response was good when the SE0C ordered inge s t i o,n pthway y
sa=pling during the recovery and reentry phase of the excecise.
De W =ent of Ag ricul t ur e and Markets personnel at both the L.DEOC and the WDE0C pro =ptly dispatched field sampling tea:s to collect sa=ples of fruits. vegetables,
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27 soils, milk, and foliage.
The teams were. knowledgeable and collected the
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w samples in a timely manner.
All samples were labeled, the appropriate forms j were filled out, the location of each sample was noted on a chart, and che e N ' samples were given to the New York state
- 6. state's laboratory at Albany.
police for express delivery to the g 33 I
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wf 21.8 Health, Medical, and Exoosure control Measures y
' Currently, the state permits potassium iodide (KI) to be distributed only to - emergency workers.
Af ter - the Governor has declared a state of emergency, the commissioner of the State Department of Health or a designee of the commissioner can authorize exposures in excess of the protective action 4
guides for emergency field workers.
However, deficiencies were noted in the
[i:
application of the current KI policy at the SEOC.
In this exercise, the
[
4-radiciodine release was relatively low, so the use of KI was not authorized by
,f{g DOH for emergency workers in general.
However, the state DOH should have
~
authorized precautionary KI use sooner for the one Wayne County field r
monitoringct, cam that received a 5-Fem whole-body dose. Wayne County followed procedure / tu request authorization from DOM for exposures to emergency workerr, ' At? excess of. EPA protective action guides.
On the basis of data avai[ahie ? a:: the state at the time of the request, the authorization was
- l de51ed. 'Upon receipt of the original request for authorization to exceed protective action guides, the state should have contacted Wayne County to ascertain worker doses, worker time spent in the plume, and other relevant information to support a recom=endation to the decision maker about the need 4
for authorizing excess worker doses.
The inclusion of captive populations (e.g., prisoners) under the state KI policy is under consideration; the decision to include or exclude them should be made.
The de=enstration of health, medical, and exposure control measures at the state personnel =onitoring center in Newark was good. The center was well managed and equipment was available for monitoring workers and vehicles.
Showers and wash basins were available for decontaminating people, hoses were
. y'y in place for decontaminating vehicles, and containers lined with plastic were ava13able for contaminated wastes.
Personnel at the center were well trained ij and' knowledgeable.
They de aonstrated a good ability to monitor and d
('y.)
deconta:.ina t e people and vehicles in a ticely =anner and e= ployed the pro-p cedures specified in the plan.
4 Appropriate state personnel had been trained in the use of dosimeters l
as siiggested af ter last year's exercise.
The = embers of the ingestion-pathway sampling team were equipped with dosi=eters, had received dosi=eter training, and properly demonstrated desi eter use during the exercise.
The state police hv y and fire prevention and control personnel at the WDEOC had recently been fi.
traine:d in the use of dosi eters and, according to personnel, dosieeters were available for distribution if workers had to go out into the field.
Members tl
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3.9 RECOVERY AND REENTRY OPERAT70N3 7-3.9'.1-State of New York and 1
3.9.2' oswero county Recovery and reentry procadures were only partially demonstrated due to the limited time available during the exercise.
The decision to relax
.i Oprotection measures and to proceed with recovery and reentry was made jointly 4
by the state and county af ter careful deliberation.
Operations personnel contacted appropriate response agencies to simulate relaxation of p;or.1ctive 9
Ingestion pathway sampling consisted of collecting one silk and one measures.
crop sample.- Collection of other samples was simulated.
I h.b h, 3.9.3 EOF This function was not observed at the EOF.
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' 3.10 RELEVANCE OF THE EXERCISE EXERIENCE 1
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j N
g 3.10.1 State of New York and t
3.10.2 _ oswego county 1
Three groups of participants nee questioned; personnel in the I
1 Emergency Operation Center (EOC), EOF and the field.
The majority of EOC and EOF personnel responses were poiiitive.
A notable faction of the responding participants indicated satisfaction with available resource materials.
Participants in the field indicatAd that the scenario was inadequate to test I
their capabilities.
The scenario was an adequate cert of most of the op6ra-tional organizations.
Howeve r, the relatively conecant wind direction and k
speed (lack of wind shif c), and small simulated radionuclides release did not l
provide a thorough test of accident assessment capability. The scenario was a
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good test of decision making consultation among state and county officials.
Federal" observers agreed that the scenario was clearly beneficial to the participants.
3.10.3 EOF l
All participants felt that the exercise experience was beneficial and allowed a variety of response actions.
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Accident Assessment STATE
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The State staf f desling with radiological matters was of high professional caliber, and sufficient in number for effective operations.
Nevertheless, enviornmental assessment was weakuned by a lack of environmental data in support of dose projections.
Timely and appropriate guidance concerning
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proevetive measures in the ingesciun EPZ, including dairy facilities, was given to local government by Stato agency representatives at the State EOC (e.g.,
j agriculture).
$( 6XGy The direction of the plume covered both land and water (lake) areas east c the plant.
There was no consideration given to or at least no mention of the condition over che watcr portion of the EPZ.
There was no mention of the Coa.
Guard, and no notification of the Coast Guard was made by the State. '(The assigned observer contacted the Coast Guard District C'ommanders' staff on the day following the exercise and confirmed that the Coast Cuard had not been notified).
The State did not deploy any monitoring teams, ostensibly because it was requested by the local government and chore was no declaration of disaster l not by the Covernor.
However, the State reportedly does not maintain a capability 3
l to field monitoring teams since it is fostering the development of an automati' l L
system of field detectors linked to a computer at the State.
LOCAL:
In accordance with the pisns, the local jurisdiction takes an active role in accident assessment and the developing of recommendations of protective 4
actions. The technical espability to ssucss and uvaluste radiological data at l
the county EOC appeared ' adequate.
However, the lone County RADEF Officer (CRI was continuously interrupted in his calculationsby the need to respond to the hotline link to the EOF, A qualified technician could be used to perform the secondary calculations.
1 There was almost no field monitoring capability demonstrated.
Equipment l
was limited and what there was is normally sorted at the County and not readil accessible for those assigned to do the monitoring.
Actually, only one e
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l 30 Decontamination procedures, which were simulated, followed those in the i
plan.
- Showers, soap,
- towels, and clean clothes were available for g
persennel. Contaminated wash water from the showers would go into the regular sewer system. Vehicles and equipment would be washed with hoses in an outside area away from the parking lot.
Plans had been developed to control contami-nated wastes generated by vehicle decontamination.
These plans correct a Previous deficiency.
Contaminated water would soak into the ground.
Other contaminated wastes would be placed in plastic bags and sealed.
Trash cans were available for contaminated clothing and other contaminated wastes.
4 Deficiencies No deficiencies were observed at the state personnel monitoring center in Pulaski, New York, during this exercise.
.l 2.1.4 Ingestion Pathway Samuling SC & 76 OVEWIEW Sampling for the ingestion pathway was carried out by personnel from the State Department of Agriculture and Markets who were dispatched from the Os.iego County EOC. Their sampling performance was excellent. Members of the,
state ingestion pathway sampling team said they had been activated 7 telephone and had arrived at the EOC by about 1000.
The team was dispatched to the field at about 1545.
At this time, other personnel at the Oswego County EOC took over the sampling team members' duties as representatives of the state Department of Agriculture and Markets.
The team was equipped with plastic collection bags, containers, writing materials, and identification labels for sampling crops, milk, and water.
However, the team should have a Ceiger counter to monitor for heavy surf ace contamination before sampling and thus reduce the risk of unnecessary personal exposure.
Soil samples were not taken by this team.
Ingestion pathway sampling was simulated and the correcY procedures were demonstrated.
The team was highly knowledgeable and well,,
versed in collecting samples.
This particular team did not have or need written sampling procedures.
However, the state may want to consider including written procedures with the standard equipment for ingestion pathway sampling in case less-knowledgeable personnel are involved in the sampling.
In a real emergency, collected samples would be dropped off at the police station and then taken to the state laboratory in Albany for analysis.
The team could not locate two of th'e three sampling locations to which they had been dispatched.
A radio might have been useful in obtaining directions to these two locations.
In addition, the sampling teams had no way to report their actions or any dose exceeding the maximum permissable without authorization. Radios should be considered for the ingestion pathway sampling teams. With regard to exposure control, the team members did have KI but did not know the procedures for its use, although they knew that instructions were s
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5 included in the KI container.
They were equipped with low-range (0-200 mR) dosimeters, record-keeping cards, and film badges.
They knew how of ten to read their dosimete rs but did not know the maximum dose allowed before authorization would be required.
Additional training is needed in standard radiological protection procedures, including the use of KI, and the reasons for these procedures.
The team did not have the proper personal protective equipnent, e.g. anticontamination suits, gloves, tongs, and respirators. They did have boots that they use in normal work duties.
Protective equi pment should be furnished.
The team had been instructed to report to the sample drop-of f point for monitoring and possible decontamination af ter sampling had been completed.
The team did not finish participating in the exercise until 1800.
Dispatching the team earlier should be considered to permit more time for collecting ingestion pathway samples.
i De*iciencies that Would Lead to a Negative Finding No deficiencies that would lead to a negative finding for the state ingestion pathway sampling team were observed during this exercise.
Other Deficiencies 1.
Deficiency:
The ingestion pathway field monitoring team did not have a Geiger counter so they can monitor for heavy surf ace contamination before sampling.
( NUREG-0654 K.34a J.11).
Re commendation :
Ingestion pathway sampling teams should be equipped with Geiger counters so they can check for heavy contamination before sampling and thus reduce the risk of unnecessary personal exposure.
2.
Deficiency:
The ingestion pathway sampling team did not have written procedures. (NUREG-0654, J.11).
Re co= mend a t ion:
The state should consider including written procedures in the standard equipment for ingestion pathway sampling as backup guidance.
3.
Deficiency:
The ingestion pathway saepling team could not i
report its actions or any invel of exposure exceeding the exposure action level. (NUREG-06 54, K.4).
Re com=e nd a t ion :
Radios should be considered for the ingestion pathway sampling' teams.
4 Deficiency:
Although members of the ingestion pathway s ampling team knew that the KI container contained instructions for use. they did not know the procedure for using KI.
They did not know how often to read their
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The state EOC 'sade. prompt protective action' recommendations after carefully considerating various options 'and coordinating with county officials. After the' state of emergency had been declared, the state notified the county of protective action decisions and gained county concurrence.
Command personnel _ performed well in keeping their protective eetion decisions current with the changing status of the plant. The state acted responsibly in recommending protective actions and, af ter the Governor had declared a state of energency, ordering such actions to be taken.
Evacuation time estimates were available from the evacuation assessment staff and were used by command
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personnel in their decision making.
Until a release was reported by the plant, protective action recommend-ations were precautionary, based on plant conditions. Evacuation of the ERPAs closest to. the plant was. prudent.
All other protective actions were ordered af ter the' plant reported. - a total uncovering of the core through a loss of coolant. On the basis of this situation, with the exception of the' last ERPAs to be' sheltered, all of the protective actions were ordered before an actual release.
The actions were effected to prevent the population from evacuating through the plume should a release occur.
Once the release was known to contain primarily. noble gases, sheltering was ordered for the~ remaining ERPAs.
The use of potassium iodide (KI) was discussed in the command room but the amount of radiciodine released did not warrant orders for its use.
Good protective actions for the ingestion pathway EPZ were develo promptly.
Maps showing locations of dair) farms, produce farms, and water resources were available at the state EOC.
(n the basis of plant conditions, dairy cattle within 10 miles of the plant. were placed on stored feed at the alert emergency classification level as a precautionary measure. Later, after the 'staf f learned that the release included some radiotodine, commercial produce was embargoed on the basis of the ingestion pathway protective action guide for child thyroid until sampling and analyses could be completed.
Residents were advised to abstain from consuming their own garden produce, especially rough-surf aced and leafy vegetables, until the commercial embargo had been lifted.
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The state EOC could contact the joint news center from both the command room' and the public information room.
Important information on the progress of the event and protective actions could be forwarded from the command roon directly to the state representative at the news center.
This procedure appeared to be satisfactory.
Personneil in the public information room screened reports from the agency representatives in the operations room and forwarded what they considered to be useful information to the state public information of ficer at the joint-news center.
However, the news center staff indicated that little useful information was being received. At one time, the Commissioner of the State Department of Health came to the public information room to inquire about this lack of information. The state should determine.the
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nature of the problem perceived by the staff at the news center and determine
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' interposed.no objection to the omission of these objectives.
FEMA Ex. 5, at 128; Tr. 6841-42 (Daverio).
98.
Early FEMA Region II exercises included recovery and reentry testing,25/
However, it was consistent'with recent (footnote continued from previous page) which to allow reentry into evacuated areas.
Other recovery and reentry activities unrelated to dose levels could have been performed and evaluated.
Tr. 7673-79 (Keller).
25/
Egg, g g, SC Ex. 62, at 46 (simulation of recovery and reentry was carried out'well at EOC; each agency was given cpecific responsibilities; no field simulations were observed, due partly to short duration of exercise); SC Ex. 64, at 35-36 (plans and procedures for recovery and reentry operations were outstanding; each agency gave comprehensive reports of activities to be undertaken before evacuees could return; plans were made to prepare EBS message; reentry was delayed to permit time for campling and analysis); SC Ex. 70, at 38-39 (recovery and reentry procedures simulated at State and County levels and considered adequate; County participants' highly proficient in their areas of responsibility and indicated good understanding of need for an integrated reentry response; examples of recommendations made for eheltered individuals, the aged, and infirm, continuation of livestock on stored feed; Monroe County appointed committee to otudy effects of radiation on the population); SC Ex. 71, at viii (although recovery and reentry simulated, State demonstrated good cbility to identify requirements and assess situation governing l
damage assessment and recovery), 28 (recovery and reentry task force established at SEOC, reached decisions, issued appropriate recommendations to Counties, and a message for the public was drafted and approved), 37 (Wayne County EOC operations officers gave briefing on recovery and reentry planning; dose assessment group proposed reentry. actions, drafted final EBS message), 46 (describes Monroe County EOC recovery and reentry planning);
SC Ex. 73, at 13 (plans and procedures for reentry operations were demonstrated; joint decision made by State and County to relax protective measures after caref'ul deliberation, appropriate egencies contacted by response personnel to simulate relaxation of protective measures); SC Ex. 75, at xi (dose' assessment staff cvaluated data; protective actions relaxed and reentry began when radiation levels were reduced; provisions made through various l
cgencies to provide for safe and orderly return of people to l
svacuated area, and a detailed tabletop of the necessary arrangements was held).
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f The Rockland County Psychiatric Center provided ex cellent f ac ilit ie s,
I supplies, and equipment.
Additional training could improve operation o f.the g
s center.
Exposure of emergency workers was monitored by self-reading dosimeters.
Field wo rke r s we r e trained in their use and recorded dosimeter re ad ing s at 15-minute interv al s.
However, no permanent-record devices (e.g., film badge, TLD) were provided.
Procedures for obtaining appropriate authority for i
emergency exposure of workers were well demonstrated.
Decontamination level guidelines we re well displayed.
Good decontamination facilities were avail-able.
Food contamination monitoring was carried out at the EOC.
State polic e simulated control of evacuated areas by setting up one roadblock, a less extensive response than called for in the scenario.
Recommend ations :
On-the-job training would make procedures flow more e
anoothly at the congregate care centers, Use of TLDs or film badges should be bnplemented for e
recording of doses.
(Re f arence NUREC-0634, II. 3.a. )
Reco.verv and Reentry Oeerations The capability of the EOC for recovery and rentry operations was eval-usted as good; only minor deficiencies were noted.
M Simulation of tecovery and reentry was well carried out at the EOC.
Each agency was given specific re s po ns ib ilit ie s.
No field si=ulations were observed, due partly to the short duration of the exercise.
J 25(1, d5, d?[2 K
Relevance of the Exercise Exeerience The exercise was felt to be of benefit to county participants.
Limited involv ement by the local police, fir ( departments, and ambulance teams reduced the e f f ec tivene s s of the ex erc ise.
Re pr esent at iv es frem these depar tment s were present at the IOC and gained some experience with emergency operations.
The local police reported that training and involvement of the police prior to the drill had been inadequate to allow ef fective participation.
35 Dosimeters were read every hal'f hour at the reception center and at the personnel monitoring center.'
in adequate quantities for all personnel at both locations.Both 0-5R and 0 Based on questions asked of some of the emergency workers, additional training is.needed in the procedure to be followed for obtaining authorization to exceed protective action guides.
One : bus driver who was-questioned did know the action level for contacting the dispatcher for special instructions. '
However, state police troopers at two different traffic control points I
reported action levels of 2R' and' 5R while the utility driver on the route for mobility-impaired persons thought the action level was ' 1R.
State Department of Transportation personne1' at the roadblock were untrained in the procedures emergency workers should follow' in contacting their supervisors and obtaining instructions for exceeding protective action guides.
On the other hand, members' of' radiological field monitoring teams were aware of the procedure for
. authorizing excess doses and the levels appropriate for requesting such an authorization.
Action levels for decontaminating equipment (0.1 mR/hr) have been specified in the RERIP. These levels were known to personnel at the reception and personnel monitoring centers.
There was also an understanding of what'to do in cases involving a contaminated individual requiring medical attention.
Facilities ~ for decontamination at the reception center and the PMC. were good.
The layout inside the reception center was very good.
- Outside, however,- the traffic pattern required people to walk in areas that been traversed by contaminated vehicles.
could have It should be determined whether the outside traffic pattern ' at the reception center can' be changed to avoid the possibility of cross-contamination.
Liquid wastes at the PMC were acceptably disposed of in a lined trench.
At both the reception center and the PMC, contaminated solid wastes from a real emergency would be placed in appro containers and turned over to the utility when the emergency was over. priate Control of access to evacuated areas was good and was implemented in a timely manner.
Access was controlled early as a precaution when the sheltering order was given.
This action was taken to reduce the number of people ' in the sheltered ERPAs and to assure a : spic response by e=ergency personnel for traffic control if evacuacion becsee necessary.
j 2.3.9 tecoverv med teent v Ooerstions 1
Plans and procedures for recovery and reentry operations were l
outstanding.
At 00: 59 on August 25 the L!eutenant cove rnor informed all agencies that recovery could begin.
Each agency gave a comprehensive report on the activities to be undertaken before evacuees could return to their homes.
Plans were made to prepara an EBS message.
A task force consisting of one ' member from each agency was formed to monitor recovery and reentry until l
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complete.
Special provisions were made for route alerting for people who
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might have been sheltered and who might not have access to a radio to receive EBS messages.
In consultation with SEOC, reentry was delayed until 16:00 to permit time for sampling and analysis.
i The dose assessment and N.Y.
Department of Health staff considered j
1 confirmatory measurements needed for the ingestion pathway EPZ and open water I
Outstanding discussions between the staff led to the establishment sources.
of a realistic schedule for making the necessary measurements.
These meaningful discussions led to recommendations for the decision r.akers.
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i 2.3.10 Relevance of the Exercise Exoerience i
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The scenario provided an outstanding test of the state's capability to I
compensate for Rockland County's lack of participation in the radiological emergency response.
The scenario required notification, activation, and
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mobilization of all elements of the NY/RC emergency response.
All NY/RC EOC participants interviewed indicated that the exercise had been a good training exercise for them.
The exercise was also a good test and learning experience for the volunteer workers at the Armory.
The scenario provided a good test of evacuation procedures and training.
State and local police, the state Department of Transportation, bus companies, and RACES operators participated fully.
The extensive participa-(
tien by these and other agencies corrected a deficiency noted at the last I
exercise.
The scenario was a good test of the ability to establish a reception center and a personnel monitoring center.
Except for performing an actual decontamination, all aspects of emergency procedures were tested.
The scenario was a good test of the ability of the radiological field monitoring teams to respond to an amergency.
2.4 BERGEN COUN??, NEW JERSZ"'t
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2.4.1 Emertenev Oeerstions ?seilities ind Resources Eeergency operations facilities and resources at the Bergen County e=ergency operations center (BCECC) were geners11y good.
The working space was adeouate and, in the event of s real emergency, additional space can be made available.
Access to the coerstions room was controlled and a log of ingress / egress was kept.
Maos showing evacuscion routes from Rockland County i
reception centers were disolayed, correcting a deficiency noted during the last exercise.
Co=munications systems were adecuate to contact contiguous state / local 3
governments within the 10-mile EPZ.
The primary communication system was by
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telephone with radio as a backup, correcting a previous deficiency.
- However, 1
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Recovery and Reentry Operations g
State 9
. Recovery and reentry procedures were in formally simulated at both the state and county levels and were considered adequate.
Reentry procedure were not observed due to rapid time compression of the exercise. The trigger-ing event permitting initiation of the recovery phase was a message from the radiological; health officer indicating that the release of radiation ~ had ended and the downgrading of the emergency to an alert ' stage.
Subsequently, dis-cussions were held between the state, EOCs, and the utility indicating that there was no contamination in Wa yne and Mohroe counties, and recovery pro-cedures could begin.
Since the termination of the exercise was generalized, the actual demonstration of capabilities such as continued estimation. of population exposure and issuance of a close-out press release were not per formed.
Recommendation:
a Future exercises should allow additional time to demonstrate rather than simulate key reentry and recovery procedures (Reference NUREG-0654, N.1).
Wayne and Monroe Counties Participants at both county EOCs discussed their respectiv e roles for reentry operations.
All participants appeared highly proficient in their particular area of responsibility and indicated good understanding of the need for an integrated reentry response with follevup responsibilities.
Several examples of this were:
1.
The state police indicated that sheltered individuals should be delayed 30 minutes before release so as to permit the roads to be cleared of snow and to lessen the potential for initial traffic congestion.
2.
The offices for the aged and nursing indicated that patients in need would be referred to other agencies, if necessary.
3.
The USDA planned to instruct livestock owners to keep
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their animals en stored feed until the county RDO j
l determined the surface radiation levels to be safe.
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Wayne County EOC workers remained beyond the exercise termination i
to assure a full understanding of reentry operations. Monroe County appointed a' committee. to study the effects of the radiation on the population.
Recommendation:
o Future exercises should allow additional time to demonstrate rather than simulate key reentry and recovery procedures (Reference NUREG-0654, N.1).
Emergency Operations Facility (EOF)
The utility, state, and county representatives conferred on reentry plans at the EOF.
Although written procedures for reentry were not evident, the actions taken appeared to be appropriate.
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1 With regard to expos.ure control measures, the utilize county data in determining 'whether to authorize excessstate should more fully the use of potassium iodide (KI) by emergency workers.
exposures and
$Q, Although the recovery and reentry were simulated, the state demon-v strated a good capability to identify requirements and assess the f
situation governing damage assessment and recovery.
A task force was established and input was evaluated from radiological intelligence, the Department of AgriD culture and. Markets, and other relevant agencies.
Ingestion pathway sampling teams were deployed from the district EOCs.
Members of these teams should have protective clo t hi ng, pa rticularly hand and foot coverings, available.
Based on input received, appropriate recommendations were issued to the
. counties and a message was prepared for dissemination to the public.
Emergenc y Ooerations Facility State and county officials dispatched to the emergency operations facility (EOF) arrived in. a timely fashion and performed their assigned functions in a professional and competent manner.
Communications between state and county of ficials in the EOF were adequate. Facilities and resources were used ' ef f ectively.
Alerting and mobilization of staff and emergency J
operations _ management were also adequate, as were dose assessment and recommendations for actions to protect the public.
(However, coordination r
with the off-site agencies could be improved.)
Delsys were obs erved in obtaining information and receiving answers to questions from the utility over gf s
the RECS line by other jurisdictions, and some utility field-monitoring data transmitted via the RECS line were in error.
In addition, the format for t ra nsmit ting radiological information from the nuclear facility operator to other jurisdictions should agree with the standard sente format.
Joint Emergenev News Center Overall, emergency information was provided to the general public in a timely and accurate manner.
The sounding of the sirens was well coordinated with the airing of the first emergency broadcast system (ESS) message.
EBS messages were written and issued from the JENC by state and county ?IOs based on information received from their res pec t ive EOCs.
Coordination of public information was ac hieved through regular contact between the PIOS located at the."iNC, at the state EOC, and at the two county EOCs.
The content of both the ESS messages and the news releases was accurate in most respects and was screened prior to release; however, some discrepancies were identified.
Some EBS messager cont ai ned the statement. "This is a test," while other EBS messages contained the statement, "This is not a test."
In addition, some EBS messages referred to telephone books and public inf ormation brochures for additional informacisn.
(Complete information was not available in the latest
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28 t-of the ingestion pa rhway sampling team did not have protective clothing
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available.
Hand and foot coverings would be particularly desirable.
The WDEOC is not in the 10-mile plume exposure EPZ.
However, at the security check point, persons entering the facility were asked where they had been.
Had they been in the plume, they wo uld have been monitored for contamination.
Decontamination showers, separate from dormitory showers, and clean clothes were available for use by contaminated individuals.
2.1.9 Recoverv and Reentrv Ooerations_
In response to a recommendation based on last year's exercise, recovery and reentry procedures were demonstrated by the state and a marked improvement in capability was observed.
Both district EOCs dispatched ingestion pathway sampling teams when so requested by the SEOC.
The planning and control functions exercised at the SEOC for recovery and reentry operations were good.
A recovery and reentry task force was established at the SEOC.
ID reaching its decisions, the task force considered input from Radiological Intelligence, the Department of Agriculture and Markets, and other agencies.
On the basis of this input, appropriate recommendations were issued to the counties and a message for the public was drafted and approved.
SC. 6.7/
2.1.10 Relevance of the Exercise Exeerience
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The exercise was beneficial to almost all participants.
Participants the SEOC, the LDEOC, and the WDEOC mobilized and carried out their required at functions.
Backup decision making and recovery and reentry procedures were demonstrated at the SEOC; this is an improvement over last year's exercise.
2.2 DIERCENCY OPERATIONS FACILITY 2
The size of the facility and number of resources at the EOF adequately provided a continuous flow of information. The RECS dedicated telephone line, backed up by commercial telephone and state police radios, was available to contact the state and Wayne and Monroe counties.
However, delays were observed in obtaining information and receiving answers to ouestions f rom the utility over the RECS line by county j uris dic t ior.s.
Some utility field-cionit o ring data transmitted via the RECS line were in error and data concerning ground deposition and iodine release were not received in a timely manner.
The cause of these problems should be reviewed and action taken to improve the accuracy and timeliness of utility information transmitted over the RECS line.
RACES was available to contact the county =onitoring teams.
The state and the two counties had adeouste space and resources.
All necessary status boards and
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were displayed; they were visible to all personnel and status information was kept current.
The EOF was slightly crowded with observers, controllers, and visitors present.
Security at the k
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9 37 23.S ' Health, Medical, and Excosure Cont rol Measures i.L c i
Emergency' workers. observed within the EPZ - ' field monitoring teams, bus ' drivers, and police of ficers - were all equipped. with exposure control kits,. containing low-range (0-5' R) and hig h-ra ng e (0-200 R) self-reading dosimeters, thermoluminescent. dosimeter (TLD) badges, exposure record logs, and KI; the availt'cility of both low-and.high-range dosimeters corrects a j
deficiency noted 'during last year's. exercise.
Emergency workers' use of their dosimeters had improved since the 1982 exercise.
They read their dosimeters.
15-to 30-minute intervals, recorded the results, and called in dosimeter at readings to. the EOC.
However, not all bus drivers and police of ficers were familiar with~ the worker exposure limits in the plan ~or with the procedure for requesting authorization to rec eive ex posu res in excess of that limit.
1 Training of emergency workers should em pha size radiation exposure limics; a card should be inserted in the exposure cont rol ' kit as a reminder.
KI was available for use by emergency workers when authorized by DOH.
Sheriff's deputies and. s tat e troopers were effective in ' controlling
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1 access to evacuated areas.
Of ficers had a list of personnel authorized to
. enter evacuated areas.
Capabilities at the personnel monitoring center were barely acceptable.
The staff at this center were not familiar with the criteria for requiring decontamination of personnel, equipment, and vehicles, ' although the director was familiar with these criteria. No one at the personnel :sonitoring center was aware of proc edures to be followed if contamination could not be reduc ed below 0.1 mR/ hr or if an emergency worker was both injured and
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contaminated.
Lack' of knowledge aoout decontamination proc ed u res was also not ed during the 1982 exercise.
The personnel monitoring center director j
indicated t ha t he would contact the county EOC for direction concerning the criteria and procedures for decontamination.
2. t. 9 Recoverv and Reentrv Ooerations the Wayne County EOC, the operations officer gave a good briefing on At reentry and recovery planning, a nd c oo rdi na to r from each agency reported cn activities planned by their agencies to prepare for reentry and long-term recovery operations.
The Jose assess =ent grouo prooosed reen:ry ac: ions to the Chairman of :he County Boa rd of Supervisors for use in consultation with state of ficials and draf:ed the final E35, message.
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2.4.10 Relevarce of the Exercise Exterience Pa r:icipa nt s in the ex e rc i s e saw it as a useful learning ex peri e nc e.
The majori:y of par:icipants thought tne exercise po i nt ed out the need for additional training.
.r 46 A
a their standard - operating procedure for handling radiologically contaminated v-pacients and a copy of - this procedure was readily available for reference.-
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Contaminated areas of the hospital were roped off and secured. The hospital radiological saf aty officer and_ a nuclear medicine technician monitored the injured person. and the treatment area.
A New York State radiological health specialist monitored the ambulance personnel and the vehicle.
S'C.e w /
2.5.9 Recoverv and Reentrv
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J In accordance with the objectives established for the exercise, ' Monroe County demonstrated a good capability to identify reentry procedures.
During this phase of the exercise, the county director of OEP conducted a final roll-call of agencies whose representatives described actions they would be take during the recovery and reentry phases of a radiological emergency at the Ginna plant. The Health Department representative revf ewed the need for field surveys to insure that_ contamination levels are below the guidelines that have been established for allowing the general population to reenter an evacuated area within the county.
In a closing statement to the EOC staff, the County Manager mentioned the recovery committee and the subcommittees (i.e.,
public health effects, economy and social effects) that would continue to evaluate the impact of the incident on the county.
As mentioned above, a shift change of personnel was demonstrated at the - EOC during the earlier phases of the exercise.
Given the short period of time for recovery and reentry in this year's exercise, a second shif t ' change to increase the depth of understanding g
g of reentry procedures could not be accomplished in response to a recommenda-tion from last year.'s exercise.
2.5.10 Relevance of the Exercise Exoerience The exercise was seen as a good training experience for all of the Monroe County emergency response personnel who participated.
The scenario provided_ a good test of capabilities to coordinate the response to a radiological emergency and there was extensive participation by both paid and volunteer workers.
Monroe County's commitment of personnel and resources to the exercise is to be applauded.
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Actions to Protect the Public
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I, State implementation of protective action responses was not required by the scenarlo.
State decision-making capabilities are discussed in Section 3.3.1 under Emergency Operations Management.
Haalth, Medical and Exposure Control Measures Although the state plan as amended calls for the use of potassium iodide (KI) for emergency workers, observers found no evidence that a supply of KI was available or that workers were provided with information on its use.
Personnel dosimetry was adequate.
Racovery and Reentry h.h Plans and procedures for recovery and reentry operations were demon-strated.
The decision to relax protective measures and to proceed with recovery and reentry was made jointly by the state and county after careful deliberation.
Operations personnel contacted appropriate response agencies to simulate relaxation of protective measures.
Although sampling of milk and crops in the 50-mile ingestion pathway zone was called fur in the scenario, only a few samples were taken or simulated due to time constraints.
Relevance of the Exercise Experience Three groups of participants were questioned:
personnel in the Emergency Oper,ations Center (EOC), in the EOF, and in the field.
The majority of EOC and EOF personnel responses were positive.
The scenario was an ade-quate test of most of the operational organizations.
Many of the responding participants indicated satisfaction with available resource materials.
Participants in the field indicated that the scenario did not fully test their capabilities.
The relatively constant wind direction and speed (lack of wind shift) and low level of simulated radionuclides release did not provide a thorough test of accident assessment capability. The scenario was a good test of decision making consultation among State and County of ficials.
Federal observers agreed that the scenario was clearly beneficial to the participants.
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e A
e This initial notification and subsequent EBS messages were prepared by the Oswego County public information officer (PIO) at the joint news center, who was in direct communication with the PIO at the county EOC. EBS messages and l
news releases were generally accurate, complete, and prepared in a timely manner.
Closing of the Me xico School District schools and the B.O.C.E.S.
School were announced in EBS messages. County PI0s at the county EOC and the joi'.st news center demonstrated a high degree of professionalism.
Protective action recommendations were developed at the county EOC through close communication with personnel at the state EOC in Albany. Free-play problems were introduced at the county EOC and the coordination of responses to these problems was generally very effective.
Representatives of all agencies were able to accurate ly assess and anticipate emergency conditions.
Field personnel and resources were deployed as necessary on the basis of technical information presented throughout the exercise.
Howe ve r,
the sheriff's coordinators did not always consider alternative evacuation routes nor did they inform the public of actions being taken to deal with impediments to evacuation.
By staging necessary equi pse nt along the evacuation routes, the highway department coordinator demonstrated an outstanding capability to monitor evacuation.
r7g Recovery and reentry procedures were simulated at the Oswego Coun g EOC. The dose assessment staff evaluated data that were provided by the state and the utility. Protective actions were relaxed and reentry procedures began when the radiation levels were reduced to levels which would not be a threat g
to public health.
Provisions were made through various agencies to provide g
for the safe and orderly return of people to the evacuated area and a detailed tabletop discussion of the necessary arrangements was held. Oswego County, g cooperation with the state, established a joint coc:mittee to coordinate long-term recovery activities.
The field monitoring team coordinator quickly mobilized the field teams and began collecting background data before a release occurred.
Alt hough communications between the dose assessment staff at the EOC and the field monitoring teams were greatly improved since last year's exercise, some field monitoring data were not communicated back to the EOC in the proper units.
The radiological monitoring teams were well-equipped and able to perform their responsibilities.
Both teams demonstrated a good knowledge of the area and reached their monitoring locations quickly.
Howeve r, the two field teams varied in their technical knowledge of monitoring procedures and in the use of their equipment. Both field monitoring tea =s were well-trained in the use of personal dosimetry and the procedure for the use of KI.
The demonstration of actions to protect the public included the activation, mobilization, and deployment of personnel and equi;xsent for five traffic control points, two bus routes for the evacuation of the general population, one ambulance for the evacuation of nor. institutionalized mobility-impaired persons, and one personnel monitoring center for county emergency workers.
All traffic-control-point personnel were generally familiar with b.
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BSCHETED
/
V5NRC October 6, 1987
'87 BCT 14 P4:08 l
UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
.n(
E ef.5Egit 7pN Before the Atomic Safety and Licensino
'I
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In the Matter of
)
)
LONG 2_ LAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
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(EP Exercise)
(Shorehan Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY, STATE OF.,
NEW YORK, AND TOWN OF SOUTHAMPTON' MOTION FOR LEAVE TQ REPLY' TO LILCO AND NRC STAFF EXERCISE FINDINGS have been served on the following this 6th day of October 1987 by U.S. mail, first class, except as otherwise noted.
J John H. Frye, III, Chairman
- Dr. Oscar H. Paris
- 1 Atomic Safety and Licensing Board Atomic Safety and Licensing Board
)
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Frederick J.
Shon*
William R. Cumming, Esq.
Atomic Safety and Licensing Board Spence W. Perry, Esq.
j U.S.' Nuclear Regulatory Commission Office of General Counsel
{
Washington, D.C.
20555 Federal Emergency Management Agency J 500 C Street, S.W.,
Room 840 Washington, D.C.
20472 I
l 1
l i
i i
l 1
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b Anthony F. Earley, Jr., Esq.
Joel Blau, Esq.
General Counsel Director, Utility Intervention Long Island Lighting Company N.Y. Consumer Protection Board 175 East Old Country Road Suite 1020 Hicksville, New York 11801 Albany, New York 12210 Ms. Elisabeth Taibbi, Clerk W. Taylor Reveley, III, Esq.**
Suffolk County Legislature Hunton & Williams Suffolk County Legislature P.O. Box 1535 i
l Office Building 707 East Main Street l
Veterans Memorial Highway Richmond, Virginia 23212 Hauppauge, New York 11788 Mr. L.
F. Britt Stephen B. Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
195 East Main Street 1717 H Street, N.W.-
Smithtown, New York 11787 Washington, D.C.
20555 Mary M. Gundrum, Esq.
Hon. Michael A. LdGrande
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New York State Department of Law Suffolk County Exec &tive 120 Broadway, 3rd Floor H.
Lee Dennison Building Room 3-116 Veterans Memori.al Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, Esq.
Fabian G.
Palomino, Esq.
Suffolk County Attorney Richard J.
Zahnleuter, Esq.
Bldg. 158 North County Complex Special Counsel to the Governor Veterans Memorial Highway Executive Chamber, Rm. 229 Hauppauge, New York 11788 State Capitol Albany, New York 12224 Mr. Jay Dunkleburger Richard G.
Bachmann, Esq.*
New York State Energy Office Oreste Russ Pirfo, Esq.
Agency Building 2 George E.
Johnson, Esq.
Empire State Plaza U.S. Nuclear Regulatory Commission Albany, New York 12223 Office of General Counsel Washington, D.C.
20555
I 9
W David A. Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W.
43rd Street New York, New York 10036
/ M N
' Lawrence Coe Lanpher ~
j KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 l
l By Hand 10/7 By Federal Express
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