ML20237G798

Intervenor Exhibit I-SC-109,consisting of Marked Up Pages 12-13,15,19,32-33 & 39 Re FEMA Std Exercise Objectives

ML20237G798
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/18/1987
From:	AFFILIATION NOT ASSIGNED
To:
References
OL-5-I-SC-109, NUDOCS 8709020415
Download: ML20237G798 (8)

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'In addition, in draf t GM EX-3, the 35 standard exercise objectives j

l are prioritized into two groups. " Group A," numbers 1-13, are deetgipd AUG 25. A9 :23; i)l

" core" objectives tbr are to be demonstrated in each biennial full partici-C pation exercise.' " Group B," numbers 14-35, are to be included in at lehsf e.

one exercise during a six year period. According to draf t GM EX-3, the

" core" objectives are deemed of a " fundamental nature" to emergency re-sponse. The others are regarded as being not so fundamental and may be tested over the course of six years. In this respect, draf t GM EX-3 forraal--

!. izes what has been long-standing FEMA pfactice. The proposed " Group A" objectives or their equivalent have tended to be tested at most or all exer-i cises to date, while the remaining objecti{es have b,een rolled into the six-i )

year FEMA exercise cycle.

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' Unless t e i al ersion of GM EX-3 is materially different from the current draf t, FEMA's exercise regimen will continue to contemplate that only the various " core" elements or " fundamental" objectives of an emer-I

gency plan need be tested in each full participation exercise. The re-maining observable elements of an emergency plan must, in fact, be tested, but can be spaced over a period of several years. As FEMA's testimony }

states, "the testing of all major planning and preparedness elements incor-I porated in the 35 exercise objectives is not required in every fpil scale ex-

!ercise. FEMA's policy permits that all exercise objectives be demonstrated within the six year cycle." FEMA Testimony at 125.

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'Does the NRC Staff agree with the interpretation of " full participation'Ees-J[

poused by FEMA and LILCO?

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l i: ( Daverio, Behr] Yes. LILCO requested the NRC Staffdo provide for dep-g h

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pition staff witnesses who were familiar with the NRC S taff's 1,

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requirements for full participation exercises. The Staff complied. When asked by I.ILCO counsel whether a full participadon exercise " required that i

every element cif an emergency plan be exercised," NRC Staff witness Schwartz stated "there's no NRC requirement." Deposition of Sheldon A.

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.q Schwartz and Bernard H. Weiss (January 14,1987) at 18 (Attachment I).

[ When asked whether all 35 FEMA standard exercise objectives need be-r j

demonstrated in any given full participation exercise, witness Schwartz replied "It is not my understanding," and witness Weiss concurred. Ld. at 18, 19 When asked whether the language regarding " core" objectives in draf t AX-3 was consistent with his understanding of 3C requirements as well as FEMA's requirements, witness Schwartz said yes. Id. at 22. And,

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when asked whether tnere is any specific number of otijectives from within k

the set of general objectives that must be observed for an exercise to be considered full participation, witnesses Schwartz and Weiss both said no.

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I_d. at 30.

Witness Schwartz added that the Staff can determine in a spe-

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Ij cific case that an exercise design contains sufficient objectives to render the exercise full partici -

because the NRC relles on the evaluadon of i

i e Regional Assistance Committee aato whether an exercise meets the j

criteria Ior_ a tuli panicipa ise. If the NRC representative on_

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RAC is satisfied, "then the NEC is satisfied." Ld. at 23. Witness Schwartz further stated that this process was followed in the development and con-',

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{ duct of the Shoreham Exercise. Ld. at 23.

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10. Q.

Is there any other document that attempts to identify which of the stan-dard FEMA exercise objectives are essential for a full participation exer-f

_. cise?

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(Daverio, Behr, Hockert] Yes. While not a regulatory document, an IEAL Report entitled "!mportance Ranking of Various Aspects of Offsite

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number to verify the capability to respond to an ac-cident scenario.

Furthermore, the February 13, 1986 exercise enabled FEMA to evaluate the inte-grated capability and a major portion of the basic elements existing within LILCO organization. The Shoreham exercise was eoual or greater in scooe comoared to any other full-scale exercise evaluated

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by FEMA Region II to date.

FEMA Testimony at 105 (emphasis added).

13. Q.

Does the NRC Staff agree with your conclusion that the Shoreham Exercise was a full participation exercise?

A.

(Daverio, Behr] Yes. When asked whether they considered the design of the Shoreham Exercise and the Exercise as actually conducted to be consis-I tent with the requirements of a full participation exercise under 10 C.F.R.

I Part 50, Appendix E, NRC Sta ness chwartz and. Weiss answered I

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l "yes." See Deposition of Sheldon A. Schwartz and Bernard H. Weiss at 36

(Attachment 1). Specifically, they answered affirmatively when asked l

1 whether they would consider that the Shoreham Exercise included "as much l

l of the licensee's state and local emergency plans as is reasonably

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~ achievable without mandatory public participation:"((2]Fwhether they would A v

i agree that the " integrated capability" to adequately assess and respond to an accident at a nuclear power plant was demonstrated; (3) whether the Shoreham Exercise tested the " major observable portions" of the on-site and off-site emergency plans for Shoreham; and etheTTFsHiwas mo-l bilization of licensee personnel and other resources "in sufficient numbers to verify the capability to respond to the accident scenarios." Ld. at 36-39.

I Finally, NRC Staff witness Weiss said that, in his opinion, he thought the i

absence of state and local personnel participation was compensated for in esign of the Exercise. Ld. at 39.

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. Thus, at 06:17 on the day of the Exercise an Alert was declared that l

caused the mobilization from the homes of 251 LERO personnel and 149 onsite personnel and the placing on standby of 41 additional LERO workers.

At 08:19 a Site Area Emergency was declared which required the mobiliza-tion of an additional 771 LERO workers.

I During the day 333 general population bus drivers were dispatched, of whom eight drove their routes in buses, and the remaining 325 drove their routes in cars.

One hundred-thirty traffic control points were manned by 165 traffic guides. An additional 30 vehicles were dispatched te perform route spotting, to respond to road impediments and to dispense fuel. Thirty-nine buses (two were real, the rest being simulated using cars),

were dispatched to assist in the evacuation of special populations. Three route alert routes were run in response to three simulated siren failures and sixteen actual deaf notification routes were run. Six actual ambulance and six actual ambulettes were run for the pickup of homebound handi f capped and special f acilities.

To observhthese events, FEMA used for the offsite portion 38 l

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federal evaluators,11 controllers and 11 simulators (simulators were feder-al employees simulating the activities of county and state personnel).

19. Q.

Are you fam*11ar with any FEMA or NRC Guidance regarding the mmmitude of resources, required to be deployed at an exercise in order to satisfy the regulations pertaining to full participation exercises?

A.

(Daverio, Behr] We are not aware of any. When Esked that same ques-tion, NRC Staff member Schwartz replied that there were, in his belief, no regulations or guidance regarding the magnitude of resources necessary to fulfill the requirements for a full participation exercise. See Deposition of Sheldon A. Schtvartz and Bernard H. Weiss at 27 (Attachment I).

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public notification system consists of esta lishing both the' administrative

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and physical means for notification of th public. FEMA-REP-10. " Guide I

l For the Evaluation of Alert and Notification Systems for Nue: ear Power Plants" (1985) at E-1 (Attachment M). Th 3 administrative elements include I

the decisions to inform the public of an emergency, to prepare an EBS mes-1 sage, to approve the message, and t begin o transmit.It to the EBS sta-tions and take the steps necessary to activate the sirens all within the 15 I

minute time riod specified in NUREG-0654. The mechanical aspects

.tonsist o testing the telephone lines dedicated to the EBS. station e si-l

. rens, and the electronic equipment needed for siren activation. During the

{ Exercise, LERO personnel demonstrated their ability to l

l i administrative elements of an EBS system, and took all' steps necessary to i

! activate the prompt notification system. Short of actually physicall

'ing the sirens and broadcasting an EBS message. What has been done to W

$date is sufficient under FEMA Guidance:

the pertinent document, FEMA REP-10, states that "[a] satisfactory exercise of an alert decision imple-lmenting chain can occur up to the point of actually activating the alert and I

notification system... " FEMA REP-10 at N-2. In any event, LlLCO has committed that, before operating above 5% power, it will test the re-maining mechanical capabilities of the system in a full test of the prompt notification system that will be monitored by the NRC Staff and FEMA.

Se Letter from John D. Leonard, Jr. to Harold R. Denton, SNRC-1269, En-closure 1 at 4 (June 20,1986)(Attachment N).

FEMA recognizes in REP-10 that it is not always advisable or possi-ble to sound the stren c 1 the day of the Exercise. See FEMA-REP-LO at N-3. f r F

_ ery/ of ten this is done as a separate effort. Indeed. NRC Staff V

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a-i members h ave stated that "many" exercises they consider to be full partici-pation did t have the sirens tested during the exercise. See Deposition of Sheldon A. S wartz and Bernard H. Weiss at 47-(Attachment I)) Moreover, the normal phys q means for informing the public about emergencies -

'Is tested on a weekly basis in any even) Finally, the the EBS radio t Regional Assistance Committee (RAC) Report of December 15,1986 finds l hat LILCO's commitment that the siren system will be activa t

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a prompt notification test prior to commercial operation "is an adequate response to this exercise issue."

See LILCO Transition Plan for Shoreham-Revision 8, Key to Consolidated RAC Review, Table 3.1 at 9.

40. Q.

Intervenora allege that the LILCO Plan is flawed because procedures for notification and issuance of protective action recommendations to persons i

in the water portion of the EPZ were not implemented during the Exercise.

l Interveners further allege that the Coast Guard did not participate in the Exercise beyond receiving a phone call. Is this correct?

A.

[Daverio, Behr] No. The fact that not every aspect of LILCO's plan to l

notify persons in the water portion of the EPZ was implemented on the day l

of the Exercise does not render the Exercise less than full participation.

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p-'Although the Coast Guard did not broadcast a message on. marine band i

radio it d!d receive notification from and communicate with LERO on both the primary and backup communications modes throughout the Exercise.

Se y e FEMA Testimony at 108.09.

The Coast Guard communicated with LERO from the Eaton's Neck Coast Guard Station by Marine radio and by telephone. Moreover, the Coast Guard simulated establishing a Maritime Safety Zone for the water part of the EPZ and simulated making emergency radio broadcasts.to all ships on the distress frequencies. Ld. at 109.

The Coast Guard also dispatched a patrol boat to the water part of the EPZ for access control at 10:20. Ld. The boat was on the scene at 11:27, reported

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45. Q.

Interveners allege that the absence of measures in the February 13 Exer-cise specifically intended for the ingestion pathway beyond 10 miles ren-ders the Exercise invalid, and demonstrates a flaw in the LILCO Plan. Do you agree?

A.

[Daverio, Behr] - No. Despite LILCO's willingness to include ingestion pathway activities in the Exercise, FEMA decided not to include them. In-gestion pathway protective action recommendations were not an Exercise objective, were they requiredlo be in order to constitute a full partici-pation exercise. Ingestion pathway protective action recommendations 1

l such as interdiction of the food chain have nothing to do with the first pri-I l

ority in an emergency, the immediate protection of the public within the 10-mile EPZ. In fact, there has been no full-scale test of ingestion pathway activities to date in New York State. See Deposition of Rpger B. Kowieski, l

Thomas Baldwin and Joseph H. Keller at 215-16 (Attachment B); Deposition of James Conrad Baranski, James Dominic Papile and Lawrence Bruno Czech (February 3,1987) at 78 (Attachment P).

e exclusion of ingestion l

{ pathway activities is, moreover, consistent with FEMA regulations. Which 1

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I do not require states occupying the ingestion pathway (50 milr.V EPZ l I around a nuclear plant, but not its plume exposure pathway (10 m' des) EPZ, ({

g to participate in every exercise for such plants. In fact, the replations re-Ij quire state participation only every 6 years in ingestion pathway activities.

1 44 C.F.R. S 350.9(c)(4). NRC regulations echo this FEMA policy. See 10 -

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. 5 IV.F(}3)(ef)

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C.F.R. Part 50 Appendix

[NRC Staff witnesses have stated

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ost" of the full participation exercises they are familiar with ex-4 cluded testing ingestion pathway response. See Deposition of Sheldon A.

l' Schwartz and Bernard H. Weiss at 54 (Attachment D.

In t.ny event, player logs from the Exercise indicate that attention was given by LERO to the risk of ingestion pathway exoosure.

See l

Attachment J.

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