ML20247G451

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Intervenor Exhibit I-MAG-59,consisting of 880302 Memo Re Author Visit to Site to Discuss Listed Issues,Draft Review & Evaluation & Discussions Re Current Scheduled Exercise
ML20247G451
Person / Time
Site: Seabrook  
Issue date: 04/07/1989
From: Donovan R
Federal Emergency Management Agency
To: Hock J
Federal Emergency Management Agency
References
OL-I-MAG-059, OL-I-MAG-59, NUDOCS 8905300405
Download: ML20247G451 (8)


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- Memorandum for Dr.Joan C. Noek i

Chief, Technological Hazards Division, 8L-NT-TH A 91,/.h From Richard W. Donovan RAC Chairman for the Review of Beabrook Flan for Massachusetts Communities j

Subject Boabrook Site Visits Status Report and Issues The purpose of this memorandum la to belof you on my trip to Seabrook and discussions that were held. I attempted to brief you last Friday but missed you each time 1 ealled. I briefed Mr. Sanders la his espacity as acting NT-TH and this memorandum w!!!

being FEMA HQ up-to-date.

In neoordanee with the conference call between Dave McLoughlin, Richard Erlma and myself on February 18, I continued to follow the normal FEMA review process as presortbed by 44CFR888, guidance memorandum GM 18 (Standard Reviewing and Reporting Procedures) and GM 17 (Joint Exercise Procedures). That conference call and follow-up discussions with you on February 17 authorised me to (1) release the draft-FEMA Review and Evaluation of the Seabrook Plan for the Massachusetts Committees to the Regional Director, FEMA R1, and the FEMA RI RAC (2) authorised me to Drief the New Hampshire Yankee organization (NNY) on the status of our reviews and (3) authorised ~me to be responsive to requests from NHY for technloal assistance. Note:

Dave Me!Aughlin requested that R. Erima document the above two authorizations in writing to me and as of yet, I have not received any written authorisatlop(s) from FEMA HQ.

Following is a list of partleulars and issues relating to my site visit, briefings on the Draft Review and evaluation, and discussions relating to the current scheduled esereise (5/23/88).

At the publie meeting on 18/31/87, Mr. Erimm eommitted FEMA to complete the review and evaluation of the Seabrook Plan for Massachusetts j

Communittee in 4 months with the review date commencing on 1/4/88.

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in the NHY's letter of 5/18/87, 12/18/87, 12/80/87, 2/12/08, 2/18/48, i

e 2/18/08 and in the statements at the 11/22/07 public meeting, NHY has

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consistently requested NRC and FEMA to secommodate a two track process:

Jg e.g., plan review and spring 1888 graded exercise.

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l Eg At the 12/22/87 public meeting, Mr. 8tello (NRC) said that the Federsi go Government would secommodate NHrs request for two track (s). FEMA did not object to Mr. Stello's statement.

ou gg On 1/7/88 C. Wingo (FEMA HQ) requested that I develop a plan review o<

schedule to accommodate the 6/1/88 milestone and inform him on 1/8/88 of Q

my schedule.

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$$o On 1/8/88, ! Informed TEMA HQ that I would produce 2 first draft to the RAC by 2/18, a second draft to the RAC by 3/10, a RAC meeting 3/38-4/1, and a final review and evaluation to FEMA HQ by 4/15/88.

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.1 0:.b.3 The purpose of my site visit = was to determine the adequ Communttles and to brief the NHY on the

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. FEMA Review and Evaluation of the Seabrook Plan.

Mr. Dolan) on the lesues identified. In th a

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Evaluation. Mr. Ylekers confirmed that he wanted me to person for all aspects of the eserclae evaluation process reg Seabrook Plan for Massachus tts Communities responsible for the New Hampshire and Maine evaluation / e the graded exerelse.

the week when I briefed the NHY on the lasues i

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and Evaluation.

were a non-participating organlaation.I and my staff <is by NRC HQ and Region I staff.I and my staff visited the Ya n

organ!sation where we reviewed the item and I established two meetin discuss outstanding issues. gst 2/28 to review the draft review, and 2/26 to We proceeded to visit the Joint Media Center, the NHY 'ORO EOC, the 8everly Reception Center, the MS Hospital, the North Andover Reception Center, and the Stagin day.

A speelal belefing was given to us on the Status of Preparedne Speelal Populations that evening.

Separately and parallel to our visits (briefing and dieeussion), a member of my staff conducted a v 1

l the Lettsr of Agreement '(Planning Standard c) with the 44 diffe ooneerns between 2/24-28.

system. Note, NHY stated that the FEMA o

for formal evaluation would be mailed by 5/1/88.

status report on the Congregate Care Cent radiological seenario to NNY ataff and I requested the staff to pe plume and ingestion dose profeetton based on the scenarlo. W evaluated this dose projection process. We visited the EBS 8tatio a briefing on the status of preparedness, and discussed the statu Preparedness.

1; During the afternoon, I gave a beleting on inadequacies identif FEMA Draft Review and Evaluation.

evaluations made during my visit, I added 4 Inadequaeles 3

j 110, J10h, M4.

Note, since 110 had already been rated inadequate, but for different reasons the revised total number of inadequaeles is 43 requested a copy,of FEMA HQ's briefing (2/18 script) to NRC y

I had verify that I had properly categorized the inadequacies into the Note, only NRC HQ and NRC RI and my staff had access to.th 4

script.

The only question ratsed by NHY was in response to the brie the Inadequacy was Alb; e.g., remove Mode 3 from their plan. I info i

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them that FEMA HQ had Inslated on this element be rated inadequate and would not consider the plan la comp!!ance with the criteria unless Mode 3

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was removed. For the record, I do not consider element Alb inadequate because Model8 Is la the plan. I informed NHY that FEMA's position was that group 1 Inadequacies had to be corrected before FEMA would agree to a graded exercise. Mr. Ylekers and Mr. Dolan (Region !) attended the briefing session and several questions were raised regarding the preparedness status of New Hampshire and. Maines.

e.g., whether there were any sim!!ar Impediments in preparedness to the scheduled exercise. Region l's position was that there were no Impediments la New Hampshire or Maine to a graded exercise to be held in May,1988.

3 That evening, we visited two transfer dispateh points, Flum Island, and the -

Farker River Wildlife Refuge.

'I On 3/38, we receivois briefing on the training program and progress to

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date, on MS-1 backup hospital, and on ambulance arrangements. I requested NNY to provide documentation on the Congregate Care arrangements, MS-1 backup hospital procedure, ambulanee procedure, good faith training attempts for non-participating organization, parking tot sizes, and the completed Ingestion pathway data base.

On 2/28, I met with NRC HQ and NRC R1 to discuss issues and schedules related to FEMA's plan review and esereise preparation process. I note that

' 44CFR350 establishs polley for FEMA Regions to follow. In addition, GM 18 and GM 17 set speelfte requirements: e.g., GM 18 estab!!shes the procedure and proeems for FEMA Region (s) to review plans, to maintain files, and to report findings to FEMA HQ. This proeems is documented in the Overview of the REF Program, stent memorandum, 10/22/87. Under GM 18, the Reg!cn is to prepare and maintain a complete site specifle f!!e by jurisdiction of the Region's findings. When the Region had completed its aview or when FEMA HQ's requests m Interim finding, the Regional Director w:ll issue a report on the Region's review and evaluation.

GM 17 established tha procedure, exerelse process, and the standardized FEMA approach for evaluating FEMA graded exeretse. GM 17 assigns the RAC chairman the responsib!!!ty for laterfaelng with exercise participants and estabilshing esercise dates, schedules for meetings, eritiques, etc. GM Ex-1 established guide!!nes for the FEMA Regional Director to allocate FEMA resources for REF exercises.

GM Ex-2 establishes the initial 44CFR350 exercise as the highest priority.

I discussed the schedules for plan review and exerelse processing with NRC R1 and NRC HQ. I discussed and received the FEMA RI Regional Director's approval on these schedules in accordance with 44CFR380, GM 18, and GM 17.

On 2/28, I conducted an exit briefing with NHY. The FEMA R1 Regional Director and the NRC HQ representative contributed to my briefing as appropriate.

I presented the two sehedules referenced above (see l

Attachment A). I discussed the fact that FEMA HQ and NRC HQ were In the process of issuing GM Ex-3 and a supplement to GM Ex-3. I indleated that the supplement to GM Ex-3 should speelfy en additional objoettve to the existing 35 objectives and that the Ex-3 supplement should speelfy that the L

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initial graded exerelse for this type of situation (non-participating organization) would require that 34 of the 36 exercise objectives be demonstrated.

Following the exit interview, NHY senior management (Preeldent of NHY),

requested a separate meeting with Mr. Vicker, NRC HQ, and myself. They requested a postponement of the graded exeteise for the week of 5/23 to the week of 8/23. Mr. Vickers suggested that they meet the schedule milestones for O & L's and wonario submission that I outlined for the exerelse process in the exit Intentew in order to allow additional time for coordination, review, etc.

1 requested Mr. Vickers to Inform Region !! of the exercise date change since it may impact them. I advised him that I would inform FEMA HQ of the exercise date change.,

On 2/24, in your absence, I informed Mr. Sande:1 (acting for you) of Seabrook's request for change in azarelse date, and FEMA RPs concurrence.

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0;:M ATTACHMENT A FEMA Schedule (s) l by R. Donovan 1

A.

FEMA Plan Review and Evaluation Milestones

  • 1st Draft by 2/18.

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  • Bite Visit 2/23-t/28.
  • Ind Draft by 4/10.

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  • RAC Meeting 3/38-4/1.

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  • Final Review to FEMA HQ by 4/18. '

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  • FEMA Finding to NRC HQ W 8/1.

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Note, those milestones meet the committment made by Richard Krima to NRC a NNY on 12/22/87 and my commitments to Mr. Vickers and FEMA HQ on 1/8/88.

B.

FEMA /NRC Eserelse Proesas and M11estone

  • Assumptions NNY exeretse 8/23-38/88.
  • Objectives and Limitations to FEMA RI and NRC RI by 8/7/88.

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  • Scenario to FEMA RI and NRC RI by 4/8/88.* FEMA Rh NRC Rtj
  • FEMA R1 and NRC RI review, comment, and approval of scenarlo by 4/21/88.
  • Ezereise_during the week of 8/28/88.

These milestones are in accordance with the polley of GM If (and GM EX-3). No GM EX-3 says that the GM 17 milestones stay in effect for 1888.

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