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Deposition of PA Giardina.* PA Giardina Deposition in Washington,Dc.Pp 1-115.Supporting Documentation Encl.Related Correspondence
	ML20212K419
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/22/1987
From:	Giardina P; ENVIRONMENTAL PROTECTION AGENCY
To:	;
References
	CON-#187-2726 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8703090302
	Download: ML20212K419 (255)
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'87 tiAR -6 Pl2:31 UNITED STATES OF AMERICA p g grgg qrAay 00cKETU4G 4. RNICf.

NUCLEAR REGULATORY COMMISSION PRANCH BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD

- - - - - - - - - - - - - - - - - - -x In the Matter of: :

Docket No. 50-322-OL-5 LONG ISLAND LIGIITING COMPANY : (EP Exercise)

(Shoreham Nuclear Power Station, (ASLBP No. 86-533-01-OL)

Unit 1) :

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U DEPOSITION OF PAUL A. GIARDINA Washington, D. C.

Thursday, January 22, 1987 ACE-FEDERAL REI'ORTERS, INC.

$ter:'1ttqYIL7 vrters 444 North Capitol Street O

d Washington, D.C. 20001 (202)347 3700 Nationwide Coverage 800-336 6646 8703090302 070122 PDR ADOCK 05000322

_T PDR

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U 1/22/86 1 UNITED STATES OF AMERICA Rptd:JooW NUCLEAR REGULATORY COMt1ISSION Typ:d:SueW 2 ATOMIC SAFETY AND LICENSING BOARD 3

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4 in ~ thE~5a tto r o fi~~ ~~~~~~~ ~~~ ~~ ~ ~ ~ ~

5 LONG ISLAND LIGilTING COMPANY : Docket No. 50-322-OL-5

-(EP Exercise) 6 (Shoreham Nuclear Power Station, Unit 1) : (ASLBP No. 86 -5 3 3 OL) 7 ___________________________________x 8

DEPOSITION OF PAUL A. GIARDINA D Washington, D. C.

10 Thursday, January 22,1987 11 Deposition of PAUL A. GIARDINA, called for examination 12 pursuant to notice, at the law of fices of KIRKPATRICK &

13 LOCKilART, South Lobby, 9th Floor, 1800 - M Street, N.W. ,

14 Washington, D. C. 20036-5891, at 9:25 a.m., before 15 Garrett J. Walsh, Jr., a Notary Public in and for the to commonwealth of Virginia at Largo, when woro present on 17 behalf of the respective' parties:

18 SUSAN M. CASEY, ESQ. ,

LAWRENCE COE LANPIIER, ESQ.

19 P. MATTI!EW SUTKO, ESQ.

Kirkpatrick & Lockhart 20 South Lobby - 9 th Floor 1800 M Stroot, N. W.

Washington, D. C. 20036-5891 21 On Dohalf of the Intervenor, the County of Suffolk, State of Now York 22 O

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N_j 1 APPEARANCES:- (Continuing) 2 STEVE MILLER, ESQ.

Ilunton & Williams 3

707 East Main Street P. O. Box 1535 Richmond, Virginia 23212 4

On Behalf of the Applicant, the Long Island Lighting Company 5

6 WILLIAM CUMt1ING, ESO.

Regional Counsel 7 Federal Emergency Management Agency 26 Federal Plaza, Room 1349 .

8 New York, New York 10278 9 ORESTE RUSS'PIRF0, ESQ.

Office of General Counsel 10 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 11

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c g g I _E E I S 2 'PauliA.-Giardina 3 Examination ~ by Ms c. Ca'sey . . . .'. '. .:. .:. . . Page 4 4

5 EI E,bE 1 E's 6 FOR' IDENTIFICATION Giardina Dep'osition' Exhibit.Numbe'r.!1' '

7 ~ Page 16 8 Giardina Deposition ^ Exhibit Number 2 Page 19

' Page 124 9 Giardina' Deposition' Exhibit Number 3 1

to Giardina Dep'osition' Exhibit Number 4 .Page~41:

11 Giardina Deposition' Exhibit Number 5 .Page 50 O 12 Giardina Dep'osition' Exhibit Number 6 'Page 67 13 Giardina Deposition' Exhibit Number 7 Page 100 14 Giardina Dep'osition Exhibit Number" 8 Page 107 is Giardina Dep'osition' Exhibit Number" 8(2) Page 108 16 17

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Y t P30gEEDINGS 2 Whereupon, ,

3 PAUL A. GIARDINA ,

4 was called as a witness and, having first been duly 2 worn, 3 was examined and testified as follows: [ ;

6 DIRECT EXAMINATION BY MS, CASEY: '

7 s Q Just for the record, my name .f.s Susan Casey. I 9 am an attorney with Kirkpatrick 6 Lockhart, and we are '

to representing Suffolk County in this licensing proceeding.

11 With me are Larry Lunpher and Matt Sutko also 12 with the firm of Kirkpatrick & Lockhart.

13 Could you state your name and busincas address 14 for the record?

13 A My name is Paul A. Giardina, spelled 16 G-i-a-r-d-i-n-a. Business addreos, U. S. Enviro.1 mental 17 Protection Agency, 26 Federal Plaza, Mail Code 2AbRAD, is New York, New York 10278. ,

19 Q Okay. And, what in your prenent job, your 20 position?

2 A My present government job is nucicar engineer 22 and my Environmental Protection Agency title in Regional ,

4

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t 'Ritdiation Kapresentative.

2 Q ' CWuld you give me a description of you'r job duties 3 and responsibilitics?

4 A I am in charge of implementing and planning a 3 regional radiation prog. tam for the United Statos Environmental a P,rotection Agency, Reglon II Offico.

1 Qt And we were told in a responso to'our Interroga-a torios that your tLtle was Chief of the Radiation Branch.

9 In that.S'ill' correct? ,

to A No, it's not <.orrect.

11 Q So, your job has changed since the time of the b" '

12 February 13th,1986 drill?

s 13 A No, that's not correct.

14 Q So, yott are not now, and never have been, the in Chief of Radiation Branch 7 to A Mo, that's not correct either.

17 Q Could you explain it ' for me, plansc7 la A The ticlo, Chief of the Radiation Branch, was a l

'. 9 . tirlo that was used organizationally at a tin:o prior to the to drill. And, I don' t know when it wan stopped being used.

at But it probably -ina noa in uno -- it was not in uso prior l

22 to 1983. l O _

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2 \ .' 4 So, your. job: duties. haven't;' changed?

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2 =A. .That's_co'rrect.- '-

_ .2

. .Q' And,.I believe you'are'also'the' EPA Repres'entative L "

4- to the FEMA' Region II Regional Assistance'. Committee; is:that i

5- correct?'

s- A- .At times'.

7. Q Could you. clarify that for'me?

f i_ , 8 A Dep'ending upon the' matter in_ question ~,'it would ,

- 9 depen'd upon which' member o'f my staff is assigne'd to' the'.

NE^ 10 .RAC. -

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12 RAC?-

13- A . Including =myself, three. ~

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< - 14- Q And,'how,are the assignments divided? '

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A-I~ divide them> based:on' worki load.: '^

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16 Q So, there is no geographic distinction'or --

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There has been.{ geographic distinction at times..

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18 Q 'Are you the only. member who ha~s participated in ~

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19 RAC' reviews of matters rel'atsing~ to the Shoreham plant?

20 A Please' clarify the time frame?

'21 Q. Say, from. November 1985 until the.present time?

22 A No. :

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1 Q Could you tell me who else has and when during 2' 'that same time frame?

-3 'A Mr. Shawn Googins, , Commissioned Officer in the

4 Public Health Service who was on detail to the Regional 5 Radiation Representative position organization reviewed two e revisions recently, and I cannot tell you precise dates.

7 Q Do you know which revisions-of the~ plan they a were?

9 A I can't be specific. I know there were three 10 revisions lately, 6, 7 and 8 but I don't know which ones 11 off the~ top of my head, yn

'^rl 12 Q Have you youracif participated'in any review of

./

13 6, 7 and 8?

14 A I have signatory responsibility for the trans-15 mittal of comments to FEMA. 'To the extent;that comments 16 left my office, they we're read by me.

17 Q Uould you have any-input into these comments?

18 A I saw' things"I'dids't agree with, saw things 19 that needed to be corrected.

20 Q Can you tell me who in your office reviewed 21 prior revisions of the plan?

22 A To the best of'my recollection, there have been l'h q.)

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k , l1 several staff'membersfwho. worked for EPA's~ Regional. Radiation: *

- Office and since - ~I don' t. know .the~ ' dates' you' are. referring to .

' 2' Y:

7 _'s - withTregard to revisions,--I can't.be'.' specific.

But, it- 6 could' be any. number of people.

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4

's - Q~

. I.'m talking about revisions.between_, say, _ .

r i-2 6 ' September 1984 and the . time ~of the exercise r

7 A - I cannot recollect that time frame.- There--have- .c J8 . been quite,a few in place.who have.hadJemergency7responsi-9 bility. ' Certainly, I would be'one'. ' t' 4

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10 Q. .. Can you recall which' revisions you_would have-L - . .

i . . 11 reviewed?

. L' M 12- A' . No,'I'can't'off the top.of my-head.

Whe~n you or members of your staff review plans- *

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- 13 Q .

1 14 'do you justs review particular, portions?

F . 15 MR..MILLERi I would like to make'a comment here

[ . 16' - just so that.we areJclear on the' record, sand that is that 17' We object to anything that goes to what we consider tosbe la part of the deliberative-pr'ocess'. And,I:want to make~sure 19 . tha't we are not_ going to get into that, sand I'm not sure if 20 that's where you are hea'ded now just in terms of how he -is h

21 going about reviewing portions of the~ plan, revisions of i 22 the plan.

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l' IMS.,CASEY: -I'm not : asking ?Md. Gia$dina'. the 'sub- -

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12. stance of h'is reviews or how'he' went.about'it. . I'mljust }

P 3 trying. to get .an idea of witether hisLAgency wouldfrevi.ew J :4 {particular : portions :which relatedl to -his own A' gen ~cy.'s.

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expertise.

6: I'm' just trying to 'get :at t-heL frame' work of how -

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MR.-CUMMING: Maybe I shoul'd clarify the~. record

. that .I am representing, : pursuant to: written ' authorization 1 of.

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l 9 10 EPA,.;Mr.' Giardina;this morning. .And while'I haveTconcerns t

11 .about the delibe'rative-process, too, as long as you are.

i 12 asking.specifically what Mr. Giardina did I certainly have .

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' 13- no objections.

h 14 With respect 1to the.'line of questioning as to how

- 15 he' divides this work or assigns work, I would object to .that 16 :line based on~relevan'cy. ..But, I. assume that that line of questioning is almost exhausted, so we will go on.

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' 17 .

7 18 BY MS. CASEY: .(Continizing) .

19 q- Do you remember the ques ~ tion?

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. 20 A I would like it restated, please.

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t 21 Q- When you or people in your office review the i

22 various revisions of the LILCO plan, do you just look at

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.I' particular portions;of the plan?-

, :2 .A It dep'end's uponEth~e revisioni: and the ': status of the j f3 plan. . Generally, weJdo'lookJatia full; plan'a't some p'oint, 4 'dep'ending upon ths! nature'of3thefrevisions. It'would' depend.

, 5' upon. the . focus and. scope . of 'ths review.

=6 MR.

CUM!!ING: ' Counsel doesn't wish-:to testify,.

7 but I will stipulate for'the record that the-relationship _-

a between FEMA and EPA.is governed by.44~CFR,.Part 351.

9 BY:MS..CASEY- '(Continuing) -.

s

~10 Q' ~ When you'say you look atL full . plans' r at some -

' 11' point, can.you be'more' specific about what:.--;at what point ~

O-12 in the process this o'ccurs? -

13 A. : Generally, whe'n an; emergency-response plan is l14 . first received 'it would have La review for completeness 'so ?'

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the whole' plan would be' looked at. That may not-be a

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16 ~ revision stage,'but:.that'.s theiinitial review generally.

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,, .o Do you know whstherfinitNb most' recent review

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k 17 Q 18 of the consolidated Rev 6, 7~andT8,1wasfths entire' plan f:

k 19 looked at by your Agency? -

p 20 A : Define what'you mean,by'the: entire plan? Like.

21 Page 1 to the .~1ast page?

22 Q Right.

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'; '2 MR CUMMINGi Objection for the~ record with re

.spect.to the lineLof questioning ~ dealing with Revision-6,s 7 --

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. _3 4- land 8.-; Te'chnically, counsel. understands that 'the'y are lfor. 1 -

- s. . considerat' ion by'. the 'so'-called Margulies' Board, OL'-3.. Board. .

6 However, having state'd that obj ection,1to . theiextent that !

7 witnes's-ha's knowledge-lheLis instructed.to answerLthe.

8 ' question.

9 MS. CASEY: 'It is our understanding..thatfthe m

l'10~ fixes contained in.particularly Revision 7 and,8 are part; .

of the' exercise litig'ation. s 12 MR. CUMMING: yYour . understanding and counsel's --

13 differ.-lMy objection stands. I will i only makerit once.for 7

14 'the~ record:so you are not interrupted in the future.

15 .MS.-CASEY: Thank'you.- .,

16 BY MS. CASEY:, (Continuin'g) ' -

17 Q Do you know what ^ parts of' that ' plan wer'e looked 18 at?

19 A Not without~ referring to material in my office, 20 no. , U 21 Maybe we will get back to that, then. Can you Q'

22 tell me, Mr. Giardina, what you did to prepare for this O

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2 A .I had a' meeting with the'two ' gentlemen on my 7-

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C - lef t, .Mr. - Cumming and Mr. ' Shul =ch . -I went through my.fil

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'4 on the'Shoreha~m exercise. I took1the ' sum total .of that 5 filewithmeonabusinesstrip.yesterdayanda$approxi-6 mately 11:30 last night' ~1ooked- through ~ five pages' gof thO 7 post-exercise asses'sment and made'three'che'ck1 marks' and 8

camerhome.

8 Q Wha ~t kind of documents are'in your file on'the 10 exercise?-

jg s 11 A' Post exercise assessment, the-Federal Register

-12 notice. dated September 28th,'1983, and the'draftfof the'-

13 exercise ^ asses'sment, which I do not have-with me today.

14 Q Is that Lyour own personal copy of the draft?

15 A -Well, it's-oneLthat was given to me by FEMA.

16 Q Is it marked up with your own personal-notes?

17 A I do not' recollect. I do6bt it.

18 Q Do you know which draft it is?

18 No, I do not.

A 20 MR. CUMtiING: .Since we are on the record, maybe 21 it would be a good time for me to state that prior to the 22 dep~osition, I was informed that FEMA had been requested to O

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1 igive~ comments by_the Environmental Protection' Agency:on its

2. protective ~ action guidelines' and=a co~py of-this-document was a furnished to -all counsel' present at the~ 'dep~osition: this 4 morning for their_information and use.

5 THE WITNESS: Excuse me. ' The~re'were'three or-fbur s other documents that were' legal documents that were handed-7 out to me at the' meeting the other' day, but I did not get a e

8 chanceto review them.

9 BY MS..CASEY: (Continuing) .

Do you know~what those documents were?'

10 Q They were all -- they were explained . to me but

~~

11 A 12 I really didn't get a chance to look at them.

13 MR. CUMMING: Counsel will stipulateJthat they 14 were all publicly filed documents.

15 BY MS. CASEY: .(Continuing) ,

16 Q Do you have this file with you here in Washington?

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17 A No, I don ' t .

18 Q Has everything'in that! file been' turned over to 19 counsel?

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20 A Shown to counsel'.

21 Q And, have 'they been produced pursuant to discovery 22 requests?

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/i Lf MR. CUMMING: .You may answer if you have knowledge.

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-1 2 THE WITNESS: I have'no knowledge either_way.-

MS. CASEY- ' Mr. Cumming, _could you tell us 'if.

3 .

4 any of those doc ~ ments u have Jbee~n produced?

5 15t. CUMMING: Yes.- .Th'e' ' copy of the ' draft: was a .the' March 12thfdraft which was routed to all RAC members for.

7 comments, which has been.' produced to you'.

4 s -MS. CASEY: Aside from the draft, have'the rest

-9 .of the contents of-that file been" produced?

10 MR. CUMMING: Yes. Mr.'Giardina's -- the 11 EPA remarks-on'the^ draft, I should' note'for.theirecord, were n.

12 covered. by the~ January 9th, 1987 ruling _ of the Board. And, 1

13 we were advised by the Board that they were ~ protected under 14 our assertion of deliberative process.

15 BY MS. CASEY: (Continuing) i i

16 Q Mr.=Giardina, did you take'any personal notes-17 while you were'at the-exercise ~or at any of the~ training l

l 18 sessions immediadely before ;it?

19 A At the' exercise, I did.

20 Q Were those notes turned over to counsel?

21 A No.

22 Q Did you bring them with you today?

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~No.c Would -:you like? to know?what? happened to them?-

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-A 2 .. Q ryes. ,

3 -A 'As.per procedure, all. EPA employees in' Region II, -

2 4- - they make~; note's on.the~ drill, they transcribe ~them onto the

~

s critique ' forms '.and ' they throw. away ' those inotes..'after they -

a have'che'ck~ed for accuracy. Tha't applies to' me'..

Is .this- just a special Agericy guidelin'e? -

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7 Q

. 8 .-An ~No. . It's the' way.we'do it in. Region II. It's ..

.9 not'the policy of EPA, to my knowl' edge,_to do-that.

In -Q Was that- policy explained to allLof the evaluators 11 at the~ exercise?

, 12 _ A- It only applies to the people who work.~for.the-

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13 EPA underneath me or assigned ~ to FEMA. That's the~way I d

tell my people 'to do' it, and tha't 's the' way' I proceeded.

14 4

~15 Q Oh,.,I see, it's.a Reg' ion II EPA --

is A It's the' Radiation. group's way of: doing things

-17 . by' procedure.

18' .Q Okay. RdgionIII?

19 A Yes.

2 20 MS CASEY: ' I would like to.have marked as 1

21 - Exhibit 1 a letter dated August 29th,1985 to Roger Kowieski' 1- --

! 22 from Paul Giardina.

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16 in exx i (The document referred to is 2 marked as Giardina Deposition 3 Exhibit Number 1 for identifi-4 cation.)

5 BY MS. CASEY: (Continuing) 6 Q Did you write this letter, Mr. Giardina?

7 A Would you give me a cha'nce~to read it?

8 Q Sure.

9 (The witness is looking at the document.)

10 A I wrote that. I wrote it and signed it.

11 Q Can you tell me what prompted you to write 12 this letter?

13 A Yes.

14 Q Will you?

15 A Essentially, the function of providing assis-16 tance to FEMA can be such that it limits our ability to 17 dedicate resources to what EPA would consider more valuable 18 radiation projects. Specifically, during 1985, the problems 19 involving indoor radon appeared to have much higher risks.

20 I think that has been confirmed.

21 And, we did not want to be supporting activities 22 that were not of a high priority or would later prove to be

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L) . counterproductive . That's my' recollection at that point.

, 1 2- .But I'm sure' indoor 1 radon was the' driving factor.

3 MR. CUMMING: Is counsel going to mark this as;an 4 e xhibit? .-

5 MS. CASEY: .It has been'. It's Exhibit 1.

s a MR. CUMMING: Okay.

7 BY MS. CASEY: (Continuing) s Q What' response did you receive to this letter?

9 Do_you recall?-

~

to A I'm not certain if it was responded to by Roger, 11 Mr. Kowleski. I know either by -- Mr. .Kowieski's office is

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\ ># 12 a few floors above me, and he. has -a habit of either calling 13 me or walking down. He probably used one of tho'se to tell 14 me he would respond or get a responseJ for ne. .

15 And at a RAC meeting, I believe this ~ matter was 4

16 addressed.

17 Q Did an NRC member come to that RAC meeting and 18 explain their policy?

19 A An NRC member.came, and' quite ' frankly I cannot 20 recollect the explanation'given. But I do remember that we 21 continued the support, .so ~ I must1have bee'n convinced that, 22 in fact, this plan was something we'should review and O

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2 Q Is it fair to say then that at the' time you wrote 3 this letter you did thi'nk there 'was a threshold problem with 4 the. plan?

5 A What do you mean by thr'eshold problem?

6 Q Well, you' mentioned that you thought reviewing.

7 this plan might' have been a misallocation.of your own 8 Agency's resources.

9 A My concern was that if this was not the plan 10 going to be used, the~n I did not want to waste resources 11 on something when a higher priority job' existed.

i ')

12 Q Can you recall, were you told that this plan 13 woul/. De used?

14 A I don't recollect. I have no recollection of 15 what I was told.

16 Q I'm sorry if I already asked you this, but do 17 you recall who from the NRC spoke at that Sep'tember 9th 18 meeting?

19 A Not with any certainty. A gentleman named Borris

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20 traditionally -- Robert Borris, I believe -- came to those 21 meetings, but I can't with any authority remember that 22 conversation or if, in fact, he was the operative person (O

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I speaking. - .So', the. answer to the~ question"is,-.I do not 2 ' re colle ct'.

3 MS. CASEY: .Okay. I would like to haveEmarked 4

~ as Giardina Exhibit 2. a~ memorandum' from Roger 1Kowieski to

s a number of^ people.

indexx -g: (The document referred to is 7

marked as Giardina Deposition 8 Exhibit Number 2 for' identifi-9 cation.)

3o BY MS. CASEY: '(Continuing) 11 Q Do you' recall-receiving this memorandum, Mr.

ym 12 Giardina?

13 (The' witness is looking at the document.)

14 A ' Do I specifically remember getting it,

~

no. Did 15 I-get it, I'm sure because it was transmitted to my office.-

16 Q If you will notice,.at the' bottom the memo says' it has attachments. Can you just look through wha ~t is

17 attached.there and tell me if tho'se look familiar to you or 18 19 not?

20 (The witness is looking at the documetit.)

21 A The attachment -- the first attachment, which is 22 apparently a FEMA letter to Mr. Charles A. Daverio, 2 L

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5: Kowieski: strikes' me.'as being something I've :see'n before. I-l 4 .

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e can recollect seeing it.~.

1 7 LI ha've no recollection of the' Nove'mber '20,,1985

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letter from Jordan to Krimm,L nor from' Krimm to: Jordan.on :

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1 1 9 November ~ 20, '85; noradoJI have rec'ollection of- November 21,

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Jordan; nor, Dircks~~to Speck, November 12.

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There is another one:from.Kowieski to.Krimm,~ and i-

. the date is sort of obliterated.-- And I don' t' recolleet -

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13-14 .that. h 1

D'itto.for not recollecting Speck to Petrone of

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15 November 1, '85; nor. Speck to Dirck's' of October 29, '85.

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[ ~ 17 I don' t want to give you the~ idea that I didn' t -

!' - 18 receive th~em. I just' don't.r'ecolleet them.-

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19 Q Well, we had a problem with the document. It was l

20 hard to.tell what was1 attached to what, and I thought

. 21 possibly you' remembered. t The' one I did recollect, I am not making the

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.1 representation that that'was attache ~d either.2 2- Q Well,fifHyou'will'lookiatthat' utility. letter

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3 that was a'ttached, .'Decemberf 2n'd; thei first attachment, L if-s-

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4 ' you will note 'on the fourth fpage 'of ' that letter the writer' 5 states that FEMA ha's req'ues'ted tha't' the' ~draftEscenario be -

6

. submitted.,to . the' Regional Assk. stance : Committee for- review: "

) 7 and comments by Decembitr'6, 1985. Do you'r'ecall ever receiv .

8 ing a copy' of the1 ' draft ' scenario-[for' the . Sho~reham e'xercise?._

'g' A I'm not sure. . I don' t! r'ec~ollect.

Db'you' recall ever making any;co~mmentston the a -to Q' .

. . 11 scenario?

rM 12 The only thing I can tes'tify to is that -I k'now I 13 . was. aware of-afscenario before,-but I.cannot:under.. oath ,

~14 testify that I received it, the' method to which1I received 15

.it,'or if I made comments. I j us't simply don' t ' recollect .

Can you put:a time frame on this'of whe'n'you fl 16 Q '

17 became aware'of the scenario?

7 A I'm sorry, I can't.

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4 19 Q Was it prior to the exercise?

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b 20 A Oh, yes.

Q As a' member of the RAC, would you receive the l 21 i

!" 22 scenarios of exercises usually?

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2 Q. You or' anyone. in your office?

3 A. The' drills I've attended,'I..have genera 11y'had 4 draft sc'enarios,, generally ha~didraft' scenarios prior:to the'

~

3 : drill.

e Q Which drills have you attended?-

.7 A. .The last Nine Mile' Point'-drill, I was an observer. ,

8 The~ last two Ginna drills, I was an observer. : Th'osefare 9 the three 'probably most recent. And there~areJothers but I t 10 just don't recollect.

11 I .have 'done more 'than those , but ~ those . are the

' ~6 12 three that I recollect.

13 Q Would.you or your staff have made' comments on 14 these scenarios?

15 A Generally, yes. The proce' dure is that we' review-16 that kind of. material and make' comments if they are-neces-sary or requested.

~

i 17 18 Generally, those comments are written. I'm not --

P 19 just describing procedure. And if there are no comments to 20 be made, generally there is a memo saying we have no comments.

21 Q Again, would your comments be of a general nature 22 on the entire scenario or would they specifically relate to lO l

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1 . EPA' concerns? -

.It could be ' "either.

2 A:

a Q Do-you~know'if you or-your-staff made comments?

4 cMR.' MILLER: o

.I'm going.to 'bj'ect'hsrefin termsJof-.

}

5 getting into what the commenting process-was.on.the prepara-tion of the' scenario.

~

6 7 MS. CASEY: I'm not asking for the' substance of 8 any comments.- I'm merely'asking Mr. Giardina.if.he or his 9 staff commented on the Shoreham scenario if hecan recall.

10' MR.-CUMMING: Witness may answer'to-the~ extent he

.11 has-knowledge.

12 THE WITNESS: Okay. I don' t reniember.

13 BY'MS. CASEY: (Continuing) 14 Q If you ha~d made 'such~ comments , would they likely is _be kept in Age'ncy files?

16 A If there~were such' comments, they would.-- FEMA 17 would have a second copy. And they might' be in correspondence .

18 As I say, gen'erally it's in writing.

j. 19 Q Do you recall reviewing the objectives for the 20 Shoreham exercise?

21 A I do not recall, no.

22 MS, CASEY: I would like to have marked as O

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e 24

'l i

Giardina Exhibit :3 another memorandum from Mr. Kowieski tio 2 a number - of peo~ple, indexx 3 (The' document. referred to is 4

marked as Giardina Depositio' n 5

Exhibit Number.3 for identifi-6 cation.)

7 BY MS. CASEY: (Continuing) 8 Q Do you recall receiving this memorandum?

9 (The witness is looking at the document.)

10 A As in the' other case , it's.addrussed to'me so I'm 11 sure I must have received it. I don' t recollect specifically

'- 12 what the disposition was.

13 Q Does the attachment to this memorandum, which is 14 a -- the sec'ond attachment is a copy of the proposed 15 exercise objectives ~ for the 1986 Shoreham exercise, dated is November 6, 1985, do you recall having seen those?

17 A Those look strikingly familiar.

18 Q Can you put a time frame on when you may have 19 first seen them?

20 A No, I can't. I'm sorry.

21 Q And seeing it with Mr. Kowieski's December 6th 22 mamorandum does not refrech your recollection?

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Q. Is it'likely.tha't.somebody;else41n your office 3 might ha've reviewe'd1the'sec obj ectives? :

4 [A' It isiunlikely, s .Q ; So, would it,be fair;to say that at this.p61nt in time 'which would be Dec' ember 1985 that you .wer'e the. 'only

~

6 7 Person. actiively -involved in the Shoreham exercise? -

8 'A To the bes't of my recollection', that's probably a 9 fair statement.

10 Q Again, in other exe'rcises~ in which^you have

~

11 participated would you usually receive a copy of the proposed 12 objectives prior to the exercise?

13 A. It's' my understanding that the procedure FEMA 14 followed is, they" would send it to'me because I was-the 15 Manager / Supervisor or in charge'of the~ group. 'And then, 16- depending upon who I assigned the responsibility, it would 17 be distributed to that person to review.

18 That presumes the fact that they sen'd it.

19 Q Am I correct in assuming from what you said 20 earlier that in this case had you received the Shoreham

.2 objectives', you yourself would have reviewed them rather i-

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22 than delegating --

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1: A- It is likely I'would have,'and Ilmake'tha't repre-2 sentation based on the'Lr'ec'o110ction?of' staffing at the time.

3 There'were two people and'two vacanci'es'.

4 And, as probably indicat'ed by.my~ earlier response 3 - and'the~ letter that-you. pointed out, we didn't.have people, a to do the'~ work. 'The'only other person available'was a young 7 lady on the staff who had other responsibilities ~.

8 So', based on tho~se recollections, and those alone, !

9 I would think tha't it was most likely that I looked at .these?

10 objectives.

11 Q Do you recall making any comments to FEMA?-

12 A .I do not recall anything withJregard to the is objectives.

14 -Q Again, if you had made"such~ comments would they 15 be in writing usually?

Is A In. general, it was our procedure to acknowledge 17 all the requests from FEMA, be they objectives or uhatever, 18 in writing. But, certainly there could be the odd-ball 19 case where they were not done.

20 And that would be explained by the fact that 21 we were at fifty percent of our staff level.

22 Q You mentioned that you do not recall making any

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i - 27

\_ .s I comments on'the.sce'nario which was used dnring the exercise.

2 In-retrospect, would.youihave'any comments to make on that 3 scenario?

4 MR. MILLER: I'm going to object to:that.

5 MR. CUMMING: I believe that is asked and answered, 6 but witness may restate 'his answer for the rec'ord if he wants 7 to.

8 THE WITNESS: I don' t thi'n k I understand what you 9 mean. You mean, in retrospect now would I go back and_make 10 comments on the' scenario?

11 BY MS. CASEY: (Continuing)

(N, ,

- # And from your opinion as an expert, would 12 Q Yes.

you have any comments to make on the' scenario which was

~

.13 14 used?

15 MR. CUMMING: Objection to that question. Witness,

! 16 to the extent he ha~s an opinion, may answer.

17 The' objection is based on' both rel~evancy and the t

18 witness' competency to answer. But to the extent he' has 19 an answer, he~may answer.

20 THE WITNESS: I hate to drag this on. Do'I i

l 21 understand the question to be that today, or at some point i

22 after the drill, would I now consider making a comment on l

I l

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T-

'28

/

,_/

1 the scenario?

2 BY MS. CASEY: (Continuing)

.3 Q And if you'did, what would the comment be?

cndTlA 4 A The answer is no.

5 Q Does that mean you ha've no views as to whether it a was a good scenario or a bad scenario?'

7 A It's not within EPA's res'ponsibility to make 8 those kind of rec ~o'mmendations, whe~ther it was good or bad.

9 You know, a good scenario or a bad scenario.

10 MR. CUMMING: If counsel is going _to continue 11 with 'this line of questioning, I'm going to object. It

(

~

12 calls on witness to speculate on matters beyond its current 13 responsibilities.

14 Also, the Board in its Order of December lith 15 did prohibit FEMA employees and its witnes'ses', which we 16 interpret to include'the RAC, to testify as to whether this 17 met NRC requiremen'ts under their regulations.

18 BY MS. CASEY: (Continuing) 19 Q If you would look for a' moment at the draft 20 objectives which 'are attached to Exhibit 3, on the page 21 which is numbered Page 2 of 12 on this exhibit, do you see 22 the fifth objective listed on that page?

' im is l

29 r: ,

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1 A " Demonstrate the ' ability to activate. . ." is -that .

2 the~one~you are' refer ~ ring to?~

3 Q Righti Do _you' know when this obj ec~tive 'was .

4 4

deleted from the' exercise?

A I have no knowledge of that.

5 6 Q Can you recall when you went to the~ exercise 7 if you knew whether this objective wa~s going to be demonstrat-g ed or not?

9 A This is not in an area wher'e EPA ha's responsibi-10 lity.

11 Q So, you would not look 'at it because it is not an g

k- 12 EPA responsibility?

I may or may not have looked at it. It's not an

~

13 A'

14 area of EPA's responsibilities. So, I don't-feel ~ qualified 15 to talk about it.

I is Q If you w uld turn to Page 4 of 12, I would direct 17 your attention to the sixth and seventh objectives on that 18 Page --

19 A " Demonstrate that the permanent population has 20 received..." that one?

21 Q Right.- And the one after that --

22 A Okay.

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" Demonstrate that information on emergency _

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2 - action's has bee'n providedito transienE populations."

3 :A Yes.- #

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_4 Q- When did '-- did you become ~ aware 'that this . _

5 objective'was not going to bs' demonstrated during the s exercise?

7 MR. CUMMING: Objection' as to. fo~rm, though witness 8- may answer to ths' extent.he' has kn' owl' edge.

'i 9 BY MS. CASEY: (Continding) 10 Q When did you'bec'ome' aware'that thsse.two. objectives

. 11 would not be ' demonstrated during thd exercise? .

f).

'k '- A I was not aware that they would or would not.

12 13 'And let me' explain very simply.

My j ob was to - be -- my 4

- 14 respons'ibility was Accident Assessment'in the'LERO, which is 15 the' Emergency' Operations Center in Bren'twood, I think is the 16 town. Ther~efore,. the demonstration of objectives in the 17 field would not be observed by me, only in the ' accident 18 assessment area.

19 So, therefore, I was unaware they were in or out, 20 to the best of my rec ~ollection.

21 Q As a member' of the RAC, did you have any concern-22 as to whether objectives such as these were in or out?

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31- ] +

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f. / ' '

.L-) , i 1 A My concerns, as'a RAC member, are.different than 2 as an observer. As a RAC member, my job is to judge whether 3 that plan, the LILCO plan,^or any other. plan submitted, 4 meets the criteria in NUREG 0396.. And, specifically those 5 criteria which are assigned to EPA for review.

e Then, when I become an observer in a drill my 7 -job is to assure that certain objectives assigned to the 8 area I am looking at are either met or not met in the time 9 that is appropriate thereto.

10 So, as a RAC observer the demonstration of the

- 11 ability to provide these things here, to the best of my

(' ')

12 recollection, are responsibilities of other agencies such as 13 FEMA, NRC. You would have to check that. So, those are not 14 my -- in my area to comment on.

15 Q So when, as you indicated, happens in other l

16 exercises and as apparently happened in this one, draft 17 scenarios and objectives are sent to you and the other members 18 of the RAC, is it your understanding they are sent to you to 19 review in your capacity as an observer?

20 A It depends upon the situation. It depends upon l

21 whether a drill is a drill and is being scheduled because

22 a previous drill was deficient, certain areas of that drill n

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32 L]

1 were deficient and didn't meet certain criteria that EPA had 2 responsibility for. It would depend upon if it was the first 3 drill based on plan or one that is semi-annually done. It 4 would depend.

5 .Q And how would those factors cut? For example, '

6 if it was a first drill, does that mean that you would review 7 all of the objectives? ,

8 A If it were a first drill -- restate that. I'm 9 sorry. I want to be sure I get that right.

10 Q Well, you told me that the nature of your review -

11 depends on the situation and some factors you mentioned are

()

'- 12 whether a previous drill was deficient or this is the first 13 drill.

14 And I was just trying to understand how those 15 factors cut.

16 A The objectives are drafted by people other than 17 myself. I don't know exactly who does those. It's my 18 understanding those objectives are drafted to demonstrate 19 certain things which are "to exercise certain things."

20 If there has been a deficiency in the drill before 21 in an area that I would observe or be responsible for, I 22 would, and have at times, noted that an objective should be

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w'4,7 1-developed in aa scenario, therefore, played ~ out ~ so that could 2- .be rev$,ewed again. 4 -

4:

i I -can think"of one specific example of that' in'a

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(.y djy. 4 cyicter unrelated to Shorehan where that;has happened. ,

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5 _On the first exercise,- since there have been no ,

6 drill deficiencies, thht Ould not have happened. Have~I-7 answered your question? .

8 Q I believe so. Isit;fairtosaythatwhenyou 9 sgot these objectives you just looked them over'from an 10 evaluator standpoint or an observer stan_dpoint?

11 1 I don't - I guess I don't understand 1what'you O

12 maan. Are you sayin'g that, did I -- let me see if, I lcan t .

g. 13 rephrase the question.

14 Did I look at it from a limited point of view as n -

15 an observer to do the' drill? Or, did I look at it in . a more

' ~

16 wholistic thing as a fair test? Titet's what I want to' know.-

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3 17 ,

What is my choice of this set?.

18 MR. MILLER: I think we are starting to get' back

' 18 into terms of how he reviewed the plans. And I think that c) 20 that is outside the scope of what we are involved in here.

21 MS. CASEY: The development of the objectives of 22 the scenario are extremely relevant.

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u Linto'today.:how he,,went aboutcreviewingjthe. development. oft

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lMR, -ICUMMING:' Witness has. testified that6heydid.

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's : not-have responsib[lithy ifor! developme$t*Sf i:he acenario. or- . ;,

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Q --

, _ 7 . If your: questio'n is 'did he reviewfcertain ob .

8: Jjectives, that has been askedjand answered.1 SSo, counsel >

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9 objects 1'to the line'of[ questioning. i Lt '

If the> witness! understands the questioni;he mayL:

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12 THE UITNESS: Let meitry to -- ,

13 tMR..LANPHER: ' Could you waiti just a momenti?:

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.jff 14 -THE WITNESS: Sure. ,

' (Mr.-Lanpher!and'Ms. Casey are : conferring.)

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,. - 15-i .. - ,

- 16 BY MS. CASEYi .

(Continuing)-

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- 17 Q- Is it fair M 3av that when you received- these:

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is objectives ~that you.dia not. angage in a critical close read-

= m 19 -ing of-them and make suggestions or comments on them?.~Is

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z 20 tht: a fair statement?

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- 21 A No, that's not'a fair statement. It is my personal 22 practice when I get information like this to take a look at

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1 .the reasonability of;whatt is going on. For instance, if --

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2' and this is hyp'othetical. If the' drill was scheduled.and a a ,

-scenario or' demons'tration..'as;pa'rt'ofJthat,was going to 3~

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'4' involve something'in; EPA's area that,shouldn't be demonstrated ,

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J 5 couldn'.t be-demonstrated,.wasn't" appropriate,.I would flag a that.

ii . ., s 7 So, there~is.a general' review under that..

8~

Q .Is it fair to say that the focus'of your-review 9 His on those'. objectives which-might implicate or involve :an

,. -10 EPA area?

J11 A' That's correct.

D 12 Q And, do you recall any of these objectives which 13 might have involved such ~ an area?

i 14 A I can't recollect.

m 15 Q Do you recall ever. receiving, prior to the

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? - ' 16' exercise, a set of 'the final objectives for the Shoreham jy: 17 -

exercise?

18 A I do not recollect. I do not remember.

19 Q Did you participate in any RAC review of Rev 6 I

20 immediately prior to the exercise?

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p 21 A I don't recall.

22 Q Did you attend any LERO drills during a period, h

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J3 -'Al The exercise was held onlFebruary>l3,;;1986; is that

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l '6 (A 'I attended'-- I went to that as an observerJ j '.%

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' fi Are you' talking priori.to that?

7 i I- 8 Q. Right.

.9 A~ No, I'did not.

' 10 Q Did you visit any LILCO facilities prior;to the

1. .

.11 exercise?

. 12 A The day.before the exercise,.I drove byLthe 13 Brentwood. facility so I.could find-it for the next-day.

- 14 : Yeah, I guess I did drive to one LILCO facility to pay a is bill. I'm a ratepayer.. That's about it . ,

16 Q When did you first -learn that you would be an it 17 evaluator at the Shoreham exercise? j 18 A I don't recollect when. But, I was always aware I 19 that a Region II EPA person or two was requested'to'partici-l 20 pate as' evaluator or evaluators for this drill.

L 21: Q Do you know who told you you would be participat-l 22 ing, or was that a decision that you made?

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8 at-the exercise?' s There were aiseries _- of . meetings- beforehand. - (

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'to That's my' recollection. :It was some' severe weather.before -

11 hand, a snowstorm.

D 12-

.To'the-best of-my recollection, . I. had a l govern--i ,

- 13 ment' car which was an unfortunate thing ' to have'. ,It did not.

operate correctly, so 15 realized.-11 was about an hour 11 ate-

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14 15 that I attended' one of those meetings. Whatever' meetings ,

u 16 were scheduled that I.Was' supposed to attend, I essentially.

' 17 went to with the exception of having to pull a car out of. a p 18 snowdrift or something like that.

l.

p . .19 If I -- I don' t recollect what I received ; prior

+ 20 to the drill or prior to the meetings. Suffice it to say, l.

[ 21 we"usually do receive material prior to the pre-drill

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j 22 mee ting ~. And if that is the case, I may have reviewed that O

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l' Prior to-showing;up.. ,

2 LQ' . I am' going to'show-you:what ha's previouslyibeen'

3 marked ~ as Laine C Exhibit . 2, . and1that's1 thezitinerary;forrthe' y; -

Sh'oreham "exercis e,.'

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'3 A ,

Yes.. .

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>. certainly looks~ familiar. -

s 9 .Q' . I'was wonderingif that might refresh'your -

10 recollection as to what went on'.at anyJof these' meetings?'

11 Do you, recall going ' to lth'e 8:30 to noon joint .

12 training session.on-February 11th?

. 13 A Excuse .me, is this what you are referring ' to .

'h'e re, the second one on the first page?

~

, 14

?

15 .Q Yes.

16 A To be really honest with you, I don't really

-17 recollect this specifically. As I said, I 'id.have d a ' car 1

18 problem and 'I know I was .an hour late for one of the meet-l- 19 ings. And this might have been -the one I was late for by L.

20 an' hour.

L -21 Q On the following page, there is a training session

.22 from 1:15 until 3. Do you recall attending that?

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1 : A ~I' don't. recollect, but it's my guess that;I was 2- probably there. . I -see something -- excuse me,. where it says a detailed discussion of exercise ~ objectives : -- excuse me, 4 - observer assignments by T omas!Baldwin and Roger Kowieski, 5 I certainly remember' at 'some ~ point -- and I can't testify 6 whbther it was FebruaryD11th~or whatitime,; that in detail -

7 - going over with Mr. Baldwin what our assignments :were and 8 the fact that he strongly; advised me to drive.to.Brentwood 9 so I could find the facility, and I said I knew where'it 10 was but he said to do-it anyway. -

-11 -So,-I'can reco11ect that specific conversation. '

'()' 12 Q Did he go over each evaluator's objectives 13 individually with them, or was it a group meeting?

14 A I don't recollect.

i 15 Q Do you recall the discussion by Mr. Keller

! 16 relating to dosimetry?

17 A I don't recollect that.

l 18 Q What about later that afternoon when there were l 19 evaluation team meetings? Do you recall'an evaluation team 20 meeting?

21' A No, I don't. I mean, I just don' t recollect it.

22 Q Do you know who else was on your team?

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1 A'. I guess Tom Baldwin might have been.- I mean, 2 I'm speculating. I think -- these all run together.

3 Traditionally, Tom Baldwin and I seemed to have -similar 4 responsibilities, and I. recollect him being'in the LERO/

Brookhaven/Brentwood Center.

+

5 o But I wouldn't really.want to testify with any 7 degree of certainty on that.

8 Q Okay. And what was your ; actual assignment?

9 A Accident assessment.

10 Q Could you tell me in general terms what that 11 involves, what your understanding of your assignment was?

r i

12 A The function of a person who does the observation 13 of accident assessment is to assure that whoever has the 14 function of assessing the accident from a county, state, 15 local, whomever is playing that role level, can assess'what 16 the accident's consequences are. And based on that assess-17 ment, make recommendations to the appropriate people, follow 18 the plan for protective action using accepted protective 19 action guides, which would be those in the NUREG 0396 plan.

20 And I might add corollary to that, any other 21 information having to do with accident assessment, judging 22 the quality and the displays and the efficacy of that kind l l N}/ _'

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1 of material.

2 Q Under the LILCO plan, who had the function of 3 assessing the accident?

4 A It was, to the best of my recollection, a group 5 of people in a room, Radiological Health ' Assessment Staff .

6 strikes me as what their title was. Seven or eight people 7 had the function of doing that function.

8 MR. MILLER: Excuse me. Ms. Casey, are we done 9 now with the Lake Exhibit 2?-

to MS. CASEY: No.

11 MR. MILLER: I was wondering if you could have

'~ that as an exhibit --

12 13 MS. CASEY: It has already been entered as an 14 exhibit.

15 MR. MILLER: Could we have that bound with this 16 transcript?

17 MS. CASEY: I have no objection to that.

ind:xx 18 (The document referred to is 19 marked as Giardina Deposition 20 Exhibit Number 4 for identifi-21 cation.)

22 eN J

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1' 'BY MS. CASEY: '(Continuing).

2 Q Of: these seven or eight . people you just mentioned, 3 .these were'LERO-personnel?

-4 A I can't comment to their actual employment, okay,-

5 who employed them.;.ILdon.'t know.- , ,

!i 6 Q Well, LERO is th'e: Lbcal Emergency . Response Organi-7 zation~under~the LILCO plan - =

A

~

8 Right.

-- 9 Q -- do you'know'if:these seven or eight people to were members of that~ organization?

11 A I'do not know'if they were LERO employees, LILCO

'O_ .

12 employees or contractor employees for LILCO. Excuse me, I-13 . know that they could come 'from those subsets, but I don't 14 know specifically who was what.

15 Q Of these seven or eight people you mentioned, y

[

16 was --

17 A Excuse me. There were also-employees of Brook-18 haven National Laboratory in this same area, i

l 19 Q And, were they also responsible for assessing 20 the accident?

21 A Yes. They had responsibilities in that area.

I 22 Q Well, of these people you've mentioned, was any LO l

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2 70- Yes, there was... '

3 .Q- Do you-recall:who that was?

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4 A' I don'.t' remember his name.

5 Q Do'you remember hisl affiliation? - -

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6 .A No. .; ,

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7 Q Was he a Brookhaven employee?

8 'A I don' t remember his dffiliation.

9 Q Going back,just for a minute tolaine Exhibit ---

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-10 15t. MILLER: Giardina.

11 BY MS.-CASEY: (Continuing) 7.

t .

N' 12 Q I'm sorry, going back just for a. minute to 13 Giardina Exhibit 4, formerly Laine ~ Exhibit 2, you mentioned 14 that you drove to your assignment in the field. 'Would that

. 15 have'been on February 12th? ,

- 16 A I presume that would have been.

17 Q Did you attend any of the other meetings which 18 were scheduled for February 12th?

19 (The witness is looking at the document.)

20 A Le t me j us t say this . I certainly did not attend

- 21 any meetings that I wasn't supposed to attend. For instance,

- 22 I was not a controller; I was not a simulator, so I didn't go C:)

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1 to those meetings.

U 2 Q How about the one.after that?

3 A I really can't say. There would be no reason for 4 me'not to have attended any of the meetings. In other words, 5 if I was scheduled to go to a meeting, I went to it. I mean, 6 I go to meetings unless"the car doesn't work, the dog eats 7 my homework or something like that.

~

8 I mean -- the onesI was supposed to go to, I 9 can probably say I attended unless for those reasons.

10 Q Can you recall raising any problems for resolution

. 11 in any.of these meetings, or asking any questions about your n)

12 assignment or the exercise?

13 A I can't recollect.

cndT1 14 Q I think before you begin describing your assign-15 ment on the day of the exercise to me, could you tell me 16 what time you arrived at the EOC that day?

17 A Wait a minute, just to clarify. I don't think I 18 did describe my assignment today. I told you what accident 19 assessment people do.

20 Q Okay. Would you go ahead and describe your i 21 assignment to me, then?

22 A To review accident assessment at the Brentwood (n;

_)

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f. q) .y 1 facility, which11s a LERO facility.or:their Headquarters, c:

2 What time did I get there was the next' question?

3 Q: Yes.

4 A To the best of' my recollection, it was very early-5 in the morning and:before 6 a.m.

6 Q Did you have resp.onsibility.to look at any other.

p 7 aspects'of the exercise besides' accident assessment?

8 A To' the best of my recollecti,on, I did not. And, 9 I would only' amend thatsby saying that it wouldcnot be un-to common for observers to -- while one observer was going to v .;

11 the bathroom or something like_that to say: Uould you watch

.]. 12 this for me?

P 13 So, I don't recollect any other things being 14 assigned other than the one caveat I put . forward. I don't-15 recollect anything differently.

16 Q Do you recall which objective you were given to 17 analyze and observe?

18 MS CASEY: Off'the record.

19 (Whereupon, a recess was taken at 10:32 a.m.,

20 to reconvene at 10:45 a.m., this same day.)

21 MS. CASEY: All right.

22 Tile WITNESS: I want to amend an answer. Mr. Fish

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1 and-I had a brief discussion in the. men's room,' and Mr. Fish ~

2 reminded me that the members of my team were TomLBaldwin,

- 3 Herb Fish, 'Je'rry Connelly, Paula Camarada and Cheryl Malhia .

- 4 BY MS. CASEY: (Continuing) s' Q Okay. Now, you said you arrived at the EOC ~

s around 6 o' clock?

7 li No, before 6.

a Q Before 67 9 A. Right. < J to Q Can you describe for me what happened that day,-

11- what you did, what you saw?

' 0

12 A I got there, had a legal yellow pad like that.

13 I noted the time I got there, and I proceeded to.make notes 14 on that yellow pad.

15 I observed activities when the drill started, 16 peoPl e arriving, people setting up equipment. I was in-17 formed, I don't remember exactly by whom, where the accident 18 assessment staff would be located, in what portion of the 19 building.

20 And during the course of the exercise, I was 21 aware that certain things would or should be happening, 22 that the accident assessment staff should, or would be, C) c

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- 47' n

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'1- performing =~certain functions. As-they performed;their 2- -functions, I. observed them and commented or ~ discussed or' 3 . questioned them on their actions, their methodologies,

~4 their. procedures.

5 When briefings were given that -it .was -appropriate

., a for me -to attend or to review, I attended such and'would 7 later ask questions either' tio ' thel briefer, tlie briefees,

i. - . ,

a to assure messages.were transferred correctly;^or,_if they-9 weren't, why not. .

6 to I observed things like status boards,. tried to' 11 judge the efficacy and' accuracy' o$ the information contained M 12 thereon. Made comments, usually in writing'to be later 13 transmitted to the forms -- whatever we call those forms --

14 regarding improvements, faults, good things.

15 That's generally what I did. And, I -- while I 16 can't with any degree of certainty tell you exactly when I 17 left, it was before 6 p.m. and probably before 5 p.m. or 18 4 p.m., when the drill ended or shortly thereafter.

> 10 Q You mentioned that you took notes throughout the 20 day; is that right?

21 A On a yellow pad very similar to yours, and I 22 probably would use two or three pages.

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48 v

1 Q Okay._ And these are what was subsequently 2 transcribed onto your evaluator critique ~ forms?

3 A That's correct.

4 Q From where you were in the EOC, could you see 5 everything that was going on, or were 'you just confined to 6 one area in che EOC?

7 What was the layout like?

8 A The accident assessment staff was in a room that 9 was directly adjacent to the main floor room. When I wasn't to in the accident assessment staff soom area, I could see what 11 was going on throughout the'first floor area. I guess it

'- 12 must have been on the east side of the building, which is 13 where most of the activity occurred in'that facility.

14 When I was in the accident assessment area, my 15 line of sight was only within the accident assessment area 16 through the doorway which did not give me a complete picture 17 of the first floor.

18 Q As far as your taking notes and commenting, did 19 you confine that to the accident assessment activities, or 20 did you also comment on the things you might have observed 21 going on in the rest of the EOC7 22 A I may have, and I cannot say with certainty, O

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't . ' commented on something outside my area, the accident' assess--

2 ment ' area if . told to do so.

3 .As I'-- again, thisiis not necessarily specific.to 4 the Shoreham drill, but if somebody went .to the bathroom and:

5 there is going to be a briefing, .would you just listen to what 6 ~PeoP l e say, I know that I would have done'that.: :Now, 7 whether I did in this drill I.do not know, s Theonlyother!thngI(would'addfis,Inevertake 9 my responsibility of accident assessment meaning just what to happens in the room. If thereJisEan ac,cident. assessment it briefing of somebody higher up in the chain of command,.

'() 12 generally after discussion with the' team leader:and other 13 team members, I .would attend that to assure that the informa-I 14 tion generated in that area was accurately transcribed,.

} 15 transmitted, et cetera, et cetera.

Can you recall

l. is Q Yoy. mentioned going to briefings.

i.

17 how many you went to?

1

- 18 A Not in number.

\

19 Q And, for whom would these briefings be?

20 A An example would be somebody called the -- I

[ 21 think the name was Health Services Coordinator or Health 22 Coordinator. That would be the person that the accident g,

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.i assessment team would report to. In the chain of command, 2 they report to somebody. So, when that person was briefed,.

3 I would go to that. And if that person then later took that, 4 it would not be unreasonable for me to attend the briefing, 5 say, he was briefing his higher-ups .

6 I know the name of that gentleman. I believe his 7 name was Weismantle. And I know he spoke at briefings at 8 time s.. I observed those,.et cetera, et cetera.

9 Q Was there'any one. person on the accident assess-10 ment staff who conducted these briefings?

11 A To the best of my recollection, it was one or

J 12 two. And, I don' t remember one person's name. And another la person had a long Italian last name that started with M.

14 Steve, I think his first name was. He did provide some is briefing material.

16 MS. CASEY: I would like to have marked as 17 Giardina Exhibit 5 a set of exercise evaluation critique 18 forms. The document consists of nine pages.

indexx 19 (The document referred to is 20 marked as Giardina Deposition at Exhibit Number 5 for identifi-22 cation.)

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1- THE WITNESS: Excuse me. A Mr. Smith was also a 2 member of my team. And Mr. Fish told me that, too, in the 3 john.

4 BY MS. CASEY: (Continuing) 5 -Q What else did you talk about in the bathroom?

6 (Laughter. )

7 MR. CUMMING: That's privileged.

8 THE WITNESS: How to get backsto New York City and the terrible parking at Motro(ktI' o

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fI io (Laughter.)

11 BY MS CASEY: (Continuing)

[')

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12 Q Do you recognize these forms, Mr. Giardina?

13 A Yes, I do.

14 Q Are these, in fact, forms which you filled out 15 after the Shoreham exercise?

16 A I belicVe these are the forms I filled out.

17 Q Could you take a minute and look through them and 18 confirm that they are, in fact, your forms or copies of your to forms?

20 A I certainly will confirm that everything under 2 " Comments" which is handwritten is my handwriting. I will 22 start there.

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Q Okay. And, do you recall. evaluating these parti-3 cular objectives which in this set are EOC-3, EOC-8 --

4 A Let's do this page by page, please. The first 5 one, I do recollect, the first page which has something, e comething, 3 - Demonstrate through rosters, et cetera, 7 et cetera.

8 The next page has no writing, no handwriting on 9 it.

10 The next page, A29 of 219, that I am now looking 11 at, EOC-8.

()

\'

12 MR. MILLFP.: The next page was what?

13 THE WITNESS: The next page I am now looking at, 14 A23 of 219.

15 MR. MILLER: You misspoke.

to THE WITNESS: Oh, I'm sorry.

17 BY MS. CASEY: (Continuing) is Q Okay.

19 A The next page I filled out and an objective I 1

20 was assigned.

21 We . w go to -- there is a number at the bottom, 22 let's refer to it. It's 850111. EOC-9, that's one I did.

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53~

EOC-9 on page -- there is no page number but it'c the next 1

2 page.

3 That's mine. I did that. The next one that I'm 4 referring to is EOC-ll, Demonstrate the ability to communi-5 cate with all appropriate locations, organizations and field a personnel. Okay. That, I did.

7 I've answered your question.

8 Q Going back to the first page, Objective EOC-3, 9 can you tell me exactly what you did in evaluating that?

to A Specifically to Shoreham, .no, I 'cannot remember 11 exactly what I did. Let me -- well, I recollect that I was I) 12 probably shown rosters of. shifts for the accident assessment la staff. My notes here show that these had person's names and 14 their job titles and positions. And when I found it being it 3-deep, meaning that there were at least three persons to apparently per shift, and then with the exception of the 17 Radiological Health Coordinator who is oft the team Icador 18 or in charge of that accident assessment group, as I've i 10 previously testified, and that apparently was 8-deep. In 20 other words, they had eight people.

i 21 Q Did the rosters also have phone numbers for these 22 people?

O

54

. c i 'i i A I don't recall.

2 Q 'And did you only look at the rosters . for the 3 accident assessment staff; is that correct?

4 A As opposed to other staffs or other . groups :cn:

5 other functions?

o Q Right.

7 A That's correct.

a Q Did you do anything to verify the actual 9 availability of the people whose names were on these to rosters?

11 A To the best of'my recollection, there were the I

12 PeoP l c involved with -- let me' explain. The Radiological 13 llealth Coordinator, as I said, was 8-deep. 'It is my recol-14 lection that several of'the Radiological itealth Coordinators is were there at different times, though only one was in charge, to That's my recollection; I'm not exactly sure.

17 It is my recollection that the accident assessment is staff that was on duty may have gone through a shift change.

to I don't recall. I know I was satisfied that the people did, 20 in fact, exist.

21 Q Based on just seeing the roster and seeing some 22 of these people?

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~O AL Seeing people, too. It is fair to say.that-I 1

2 observed more people there 'than were !necessary to. do' accident 3 assessment. In other words, .the ' group was over-staffed.

4 Q It would be over-staffed, in your opinion, for

-s three' shifts?-

e A No , ru) . 'The' plan calls'for a certain. amount'of 7 people to be there, as I recollect. And those people were a there, and then there were also more people. That's a.

o recollection.

to Q Well, would those extra people being there, for.

11 instance, strip the~ later shift of their personnel?

'- 12 A I don't even recollect that they were performing 13 any function other: than showing up. In other words, there ,

14 were supposed to be a certain amount of pcopie there. ,

They is were there plus more people.

16 Some of those people were also on the roster.

17 Q Do you have any recollection of how many? And, L is when you talk about these ext ra people who were there, were P to those just people in the Radiation llealth Coordinator title?

20 A Negative. That would be the staff below it, too.

2 Q I note that you wrote it was a " Good performance /

5 l 22 Demonstration." Can you recall why you were so struck by it?

7_

56

, ,a t A Yeah. They had a number of qualified people there 2 to do the job. The comment " Good Performance / Demonstration" a was indicative of my thinking, that as compared to past drills 4 that I had attended there were 'at least as many, if not more, 5 than I had ever observed people who were ' qualified to do the o functions.

7 Q Did you observe anybody actually call out a 8 second or third shift number?

9 A I don't recollect. Based on the information in to front of me, I just don't recollect.

11 I also don't recollect -whether. that was an f)

objective of the drill, to call out another shift. I don't 12 13 recollect all that.

14 Q Did you yourself, for instance, make any attempt 15 to call any people on the roste'r you were shown?

to A That is not my responsibility to do.

17 Q So, you didn't?

18 A That's right.

19 Q Okay. If you will turn to the next objective 20 here?

21 A EOC-87 22 Q Right.

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57

(,

J t A Uh-huh.

2 Q Again, can you tell me what you did to evaluate a this objective?

4 (The witness is looking at the document.)

l s A There should be one Radiological Health -Coordina-o tor who is in' charge of the group, and that person should be 7 responsible for getting data that's necessary to make 8 determinations on the status of the accident so he or she can 9 assess that accident and make appropriate protective action 10 recommendations.

11 Through a process by which I observed, I asked

(' ') 12 questions, I asked people to hand-calculate dose calculations 13 or review the dose calculations they are making by a computer, 14 et cetera, et cetera, and then to transmit their recommenda-15 tions to the person in charge. That person in charge under-to stand what they are doing, have some quality control for 17 the data. That might also include data that is displayed on 18 display boards, et cetera, et cetera. And then make those 19 up the chain of command.

20 This is an ongoing and iterative evaluation 21 process during the drill.

22 Q What did you do, for exampic, to check their J

\ ,

58

)

I command of emergency operations by the Director of LERO, that 2 was undertaken by the Director of LILCO response or his 3 designee?

4 A Could you repeat that? I'm sorry.

3 Q I understand you told me what should be going on, 6 and I'm just trying to find'out what you observed that led 7 to your conclusion.

8 A Would you be more specific?_ I think you are 9 asking a specific question and I'm not grasping it, to Q Okay. For example, on this form it says one of 11 the points of review is: " Command of emergency operations O

\# 12 by LERO Director of Local response or designee (see OPIP 13 3.1.1, Attachment 1)."

14 Did you review that. point?

15 A Okay. That is an ongoing point to be reviewed to throughout the drill. Let me give you an example of what 17 would be done.

18 First of all, the accident assessment staff at to points during the day are trying to figure out what the 20 severity of the accident is based on data it received and 21 based on calculations, based on a number of different factors, 22 They then perform that analysis and tell the Radiation Health O

r 59

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1 Coordinator along with thpir ideas for protective actions. r 9///P/.r_RV MOkJ W/ &[y..

2 Thatmayalsobestimulat,edbythef,2gd'ccaHealthCoor-nato c s

3 asking them questions or giving the'm assignments to make the 4 following dose calculations, review population estimates in this area, et cetera, et cetera -

3 fy/lslht&f p l/ s e

Based on that, the' Radi+t-ton-Health Coordi at 7 is to discuss with the Health Services Coordinator what 8 appropriate actions should be taken -- excuse me, what the 9 Status is, what they base that status on, the quality of the to data and what the' appropriate protective action should or 11 should not be.

'/

12 That has been passed up through the chain of 13 command through briefings and meetings that are called, up 14 to whatever the top level is, LERO Director. I observed 15 that happening repeatedly throughout the time of the drill.

to Q So, you observed information going up to the 17 Director at LILCO response?

18 A As well as responses coming down and requests for 19 further information and et cetera, et cetera. Yes.

20 Q So, in your opinion, the request for information 21 and what he was asking for demonstrated command and control?

22 A That is correct.

(3

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60

p m i Q Did you check to see that the plan and the 2 procedures and checklists were available?

a A Let's start with the plan. The accident assessment 4 staff assembled, which' to the best of my recollection would s have been between 6:30 and 8:30 in the 'mornin6 -- I asked a them where the plan was, produced copies. I ask them for 7 specific information that should have been contained in that a plan and how to get at it, specific information that I would 9 judge to be necessary to be in hand-out form ort charted.

to And I asked for that.

it During the course o- the day, I go back and I ask 12 members of the staff and the' '4 a o althCoordinator,,f,,n 7,,

la where'is his plan, where is. this,'where is that?

14 So, with regard to the plan availability,' generally is I -- and whether I did it with Shoreham or not, usually to three times during the day., I usually pick very inconvenient 17 times. I ck times -- it is not uncommon for me to ,

is ask the ka4Lat4en !!calth Coordinator where the plan' is when$

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20 Your other two points that you asked me? You 21 asked about the plan. What oise?

22 Q Procedures and checklists?

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2 Q Again, when you would be asking' for chese, would v'

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3 A That's all I would bo.- .

t Q That's. all yo'a would be looking at? 1

-) A Yes. Or those'that are'directly related to, a 5'se instance, I want to know that the ' gentlemen or.iadies in

., 9 charge of making protective ar ionc have within hand radius to achartthatshowsthepopulationdensitiesofeverysect$r EL J u ,

p 3 F l' 11 Cr.ar could possibly be evacuated and evaluated. I want that 4-0 12 there. .. O And I want them to always'know it's there.

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, is Now, whether. yout.would Ljudge that map or that'

is figure that has those population densitic i as an accident 17 nanosament responsibility or something else, then I would I is check those. Mint I would call directly related to.

, to Q Now, you described what you usually do in an 20 exercise. Do you specifically recollect doing this at the e 21 Shorehum ov.orcise?

22 A As I said, I'm ourc I did it. Miether I did it ,

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L- '3 t' Q If you'would look~'atLtheLnext--obj'ective, EOC-9,-

n [ first of all, if you will note,.- the exhibit .has Ltwol. copies of' ;

s this.one. = And ' the reason is' bec~ausef thel first' copy. hds a1 -

.e : number in the' ' upper left-hand corner. - ' Is that ;your hanN--

tr 7 writing, Mr. Giardina? - ,

5 's , .A. Before the ' word "The" ' accident ' assessment, .' there +

J e is.a' number tha't1looks'like'a~4?'

10 Q- Right.

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.A; Like' -- tha~t does'not71ookilike'my handwriting.

p O.: 12 . Q' -But the comment-is yours?

1:i A' 'Yes', yes.

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ii Q. Wha't'did'you observe'iti conneetion'with this objective? Li , u I l' N r

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1s, A- Could you be'more' specific?

17 Q What formed,thi basisJfor i 'youb comment?

.Very simply stated, there were numerous briefings

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is A-made 'to .those simulators 'who were des ~ignated as state and

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E 20 county simulators.

21 Q Okay. If you will look ~at EOC-11, -if you will note 22 in the' middle 'of the ~ comment some. of it is crossed out. Did t

4

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2- A. L'et.:meitake'a look; 3 (The' witness _'is'looking'at theidocument.)

4 IMR. fCUMMING:- (While- he 'is' reviewing .that, .I: should' lz,.0 f 5' state ,'for . the record. that l pursuant to the'- B6ard's ' Order of W" ' Vi .

6 the 9th. withJrespect to document production, . if therelwere

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'; v -7 . versions tha't showe'd -differences' both versions were produced 4

8 to1 ~you even tho' ugh 'it . reflected, in our judgment, delibera-8' - tive 'pr6ces's , , which' the' Board ruled :adversel'y to us on that 10 issue ^ basad on'its weighing of your need to know'versus our p L11 -need forLeonfidentiality.

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12 THE WITNESS: Well, let's put it this way. I- _

13 could have crossed that out. I can' t say with 'any authority: ,

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i 15' .The-'only' kind of constructive light I can throw 16 on this~is, if 'you will" start halfway .down' whe're it says ,

if 17

" Telephone' lines were used'to communicate..." and then it- j

1 18 appears ' that "with ' field teams and with ' decontamination u p

^

18 centers." Obviously, field teams, it's very hard to use a 20 telephone. That's radios and things like that.

21 -And, clearly I could have written down a compound l

22 t' .oughti, gone back and reviewed and said: That's absurd, Mr.

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1 Giardina. And I.could.have crossed.that out.- lSo, it's 2 possible I'did. '

3 Whether:somebody would cross out my-work after--

~

4- ward, ILean't testify to that or not.. I.can't-tell'you-if

'5 I crossed that out or not.

6 BY MS. CASEY: (Continuing) 7 -Q How wer'e' th~ose : field teams communicated with?

8 A This'.is on rec'ollection. I know there were radios-used.

~

9 One'of the field tedms' involved, as I recollect,.was-10 a RAC~ team which is a federal government. team that I believe.

11 comes from Brookhaven, -and they have various radio equipment.-

~O 12 I believe, 'and I'm not certain because -I don' t' 13 -remember,-the~y may telephone'into -- radio into Brookhaven-14 'and Brookhaven would'tel'ephone. There'was a RAC Coordinator 15 from Brookhaven at the' accident assessment facility.

16 .I'know the'Lteamsidid have' radios, and I don't 17 remember if tho'se radios directly came into the EOC or there

<+

18 was another telephone line. I don't recollect.

l L

19 Q Did the LILCO-teams have radios?

20 A I don't r'ecollect.

21 Q How many types of teams were out there?

j 22 A That was not my responsibility to review, so I O

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.I apparently misspoke.

2- Excu's e' ~me . Telephone .

[n -- (3 ilines-were used to.commun'ica'te.with RAC.teamLcaptain by}thS; F'i~ .4- ' RAC te'am ' liaison. ; ; So,; apparently~; there 'was some .'tel'ephones :

a 5 used.- .

Below'thatnit-says, " Telephone lines;were g 6 Q. 'Okay.

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'7 used to' communicate'withifieldSteams." ,

8- 'A No, td communicate withl - the wayLit reads,_-_if

~

you accept the' striking.which I would suggest you do -

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9 and',u h '10' again you~ are .'asking 'me1to call for .a conclusion 'on what I:

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m . : 11 believe-J to be' my own wo'rkione year later. 'It appears.that. '

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. 12 I have probably indicated tha~t JtelEph6ne lines':were -used 1 M

13 Tab 6ve and the'n realized that I was isssing a' redundant state-: '

. ment . arid, . therdfore , : Erbs'ssd; out "kritih' fiel'd. teams" because e

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is 'it was.in the.'second line tite're.

16 Therefore', jIiwas trying t6J communicateto the

-people'who would' read this, the telephone lines were used

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o- .18 to communicate with decontaminationcente'rs,.oka'y;.and, also 19 I alrea'dy' expressed the~ though in the'second sentence, -

i. 20 telephone lines'were used to communiccate,with.RAC team 21 captain, blah-blah-blah, by the RAC team liaison.

F 22 And that's probably why I crossed that out, presuming LOL

!~ . :. a . . . - . . _.. _ . . _ . - . ~ . . . , . . _ _ _ _ . _ . _ _ . . _ _ - . . -. _ __ _ . _ . _ _ _ _ _ . _ . _ _ - . _ .

~

66.

'_'q).

I was thefone'who' crossed it out which I thinkfis a fair

^

1

-2 presumption.

3 :Q Whe~n did you~ fill out the' crit-ique forms, Itr.

4 .Giardina?

I am not'sure.

5 A- But, within 24-hours of the' drill 6 being complet'ed and very possibly within hours.- ~And, not --

it 'is not imp'o'ssible that I could have made notes just' as the 7

. 8 drill was ended, before 'it ended.

9 Q But possibly-you filled them out on'the same day 10- as the exercise?

11 A- It-is en'tirely possible I-did,'yes.

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.In filling the'm out, did 'you use 'anything besides:

~

12 Q 13 your own notes?

14 A I would refer to . other team. members and discuss -

15 things with other'l tea'm-members.

T

. 16 Q Nobody else'on'your team was assigned to the 17 accident asses'sment ' area', we'r e they?

18 A That's true. _

19 Q Did you use any other~ documents?

If there were documents that were used in the

~

20 A 21 preparation of briefing material, ther~e 'were ' documents that 22 were generated -- for instance, RECS messages. Again, I can't LO s

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1. state' e:2actlyjwhat I. used lin 'Shoreham,[because 'I don' tl re~--

'2 collec~t. . But 'it woul'd not1be uslikely-. thatyI1would ; collect -

every RECS" message 'and ha'nd that" in, that I;would review.

~

3

,.' 4 '. those RECst.messageslin quite'someJdetail and hand:those'.-is.

J5- Time lines' and things like:Jthat' th'at' might be 6 1 generated would be reviewed. Anything that that_ staff wrote:

7 down,- I: got 'a copy of and Itwould review and turn in"and not :

~8 keep-a' Copy. e r

-9 -Q- Did youiyourself; fill"out.-one'of the~ draft time 10 lines'dsring theTexercise, the ECL time line?-

11

~~A LI don't-r'ecollect, but it would be fair toLassume.

~

- 12 I probably:did.; ,

- 13 Or, if I'didn't, I would have helped the' . team 14 - captain prepare 'one. - Whether I' wrote'on one or I assisted -

~

15 a team .c'aptain, _ one :of those ; two procedures more than likely l' 16 would have'been followe'd,

- 17 'MS. CASEY: I woul'd like' to :have' marked as !

is Giardina Exhibit 6 an exercise evaluation critique.~ form, 19 EOC-12. ;

indexxx 20 (The ' document referred to is 21 marked as Giardina Deposition

- 22 Exhibit Number 6 for identifi-l cation.)

4 68.

tj BY MS. CASEY:

~

1- (Continuing) cnd2A:

2' Q- Mr., Giardina, is this'a form you~ filled out?

3 -(The~ witnes's _ is - -looking at the' ' document .)

4 A 'Yes~, ma'am.

s -Q If you will~look at the' points-of review on'this Objective EOC-12, it appears you were ' supposed to observe'

~

6 7- the implementation of ~two OPIPs which are listed there..

8 A' .Uh-huh.

9 Q -Did you-review'the'se prior to the' exercise?

10 A I don't recollect.-

11 Q .Did you have'any'--

O'# 12 A' I would assume I would hsve,-but I can't state on la the' record under oath.that I-did for sure.

14 Q Okay. 'Did you have any OPIPs with'you at the is time'of the. exercise?'

16 A .I cannot' testify with c'ertaintyIhow the procedure 17 was.to get OPIPs. I remember having the'm.; ' I believe - they

~

were provided.

~

18 But,agaknunder'oathI'cannotstatewith'any 19 20 surety how that-was done.

21' Q Do you have any rec'ollection of whether you may 22 have looked at any OPIPs other than the ones listed there?

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( ',}

1 A I could not recollect.

2 <Q The 'sec'ond bullet' theYe, the'. ability toi make.

Protectivefaction dec"is.$ons promptly, how'did'you review this?

~

3 a 4 'A, Again', this is -- excuse'me. Thfs is" a ' deliberative 5 process that goes on through the accident: asses'sment'. .The scenario-that'is availableJwill tell you1certain times, when-

. 16 7 certain events are ha~ppening. Tho~se' events will trigger-8 changes in status of the' plant ~ and projected releases if, 9 in fact, a drill: -- I'm - speaking "a" specifically. now.

- lo And, '.therefore, you Will be ~ ~aler'ted to the fact 11 that s'ome status change ~is occurring and that it woul~d be

,/'1 '

\# 12 prudent for th'e accident asses'sment staff to. assess that, 13 make 'a rec ~o'mmen'dation~ for protec'tive action, transfer that

. 14 up to the' chain of comment so thst it is transmitted, i.e.

15 to Radiological Heslth Coordinator, Heslth Coordinator, 16 et cetera, et cet' era and the - PAG, putf into . place ~, or the PA -

l 17 put into place.

I l 18 This happens throughout the. entire' drill thst 19 the status changes.

L 20 Q Well, with' specific reference to the Shoreham f

21- exercise, what sort of criteria did you use'for promptness?

22 A You mean in the manner of time frames?

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i. Q. Right,;if you gan remember examples: J.t hat'you

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~ 2- obs'erved.-

I can reniember one ' incident specifically .where the ~

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.3 s4 radiological.:he'alth.' staff, the'pe6ple'wh6 wereidoing-the v . .. .. .

.acciden~t assessment, .it was'earlp,in theVscenario and the 3

4 Radiological Health' Coordinator madetheJdet'ermination to

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ll . ,r- his staff, s or. made <the < request of- his . staff to . review a .

s certain-series-of situations that!cohld possibly. occur; ,

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9 In other'wo'rds,'.a what if.

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10 1 Tha"t? staff made? recommendations'-- in-other words, -

. 11 they formed = this -. wha t-iff and -indicate'd to the Coordinatar '

that if ths following status. changes ~ occurred,ythe-following.

i > E. i 12 L 13 protective' ' actions would be.Jnec'es'sarp.

F

, - 14 Later in the' day, the" situation worsened and:they- ,

/33 felliin oneJ of th6se what-if. categories. And immediately~upon p

is . falling 'in the' 'whSt lif(categor , tSe'y' ma'de recommendations r

-1i up the~' chain of command. Excu'se~ me. What'they did was_,

,they communicated the wha't.if analysis;to the Health Coordi-18

[

!~ 19 nator prior to the' change in status and indicated if the

' status changed the~n the' following protective actions would

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20 21 be recommended. .

22 The Health Services' Coordinator transferred that t :

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. t 1 up cthe " chain of: command.; So', they. were in a pro-active -

2 situation suchMthat1they~ knew ee r.his-one.~particular point - -

3 = an'd I don'.t- remembsr the -'sp~eci'fic changeJin status -- that

, :4 if ths .'following; things hdppened the' following protective

'5 ^ action.wss recommended. That went all thsJway to the top.

6 It wa's'. clearly understo'od, because HI attended all Jtho'se; drills and, in-fact,- that whst-if. logic trend-happeri$d and'

~

i .7 8 thsy took 't-he ' pro'tective faction as - immediately as the infor-mation could be 'tran'smitted up the ' chain of command, which

~

9

~

-I would not want to' speculate'how much time'it was'but I;did 10 -

11 : time it;and it wa's quickly.

.12 It-was'my.' general observation thatD the' radiological

- 13 hsalth staff that did accident assessment was pro-active..

14 Q Would you define ~for me what you mean by that~

l15 term?

. 16' A They anticipated adverse changes and planned out--

17 protective actions based on ths protective' action guides'.

18 Q How about ths 'next bullet, ho'wfdid you evaluate I l-ths consistency of decisions with'a plan guidance?

~

19 l

20 A Well, intrinsic to what?I'veidescribed by my i

21 other answer, ths protective actions have'to be' consistent 22- with the numbers and ths PAGs the EPA has. And that's folded O

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1 into the decision ~-making process.

2 I distinctly remember ~ at one time hearing the 3 Radiological -- no , che'ck that . ~The He~alth Services'Coordina-4 tor misspeak during . a briefing in refer'ence' 'to an EPA PAG.

5 I encountered the gentleman in a conversation within five

~

6 minutes after that and asked him to repeat what he'said, 7 which he did not misspeak. Then, I csked him four or five 8 very pointed questions regarding EPA PAGs. I asked him to 9 produce a PAG manual, read it, and he'actually got somewhat to annoyed at me. And I said do it. And'he reread.it.

11 And I said: Do you know what you said there?

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12 And he maintained he 'said what he' had said to me the second 13 time. 'And I said: That's not what I he~ard. 'And I noted it 14 down.

15 And he redid the communication to everybody 16 around.

17 Q Well, that described ho'w they wer'e consistent with

18 EPA PAGs, but how about the second point there, and plan L 19 guidance? Do you know what: the plan guidance'was?

20 A Be specific in what you mean by plan guidance in 21 this case, 22 Q I don't know. That's what I'm asking you.

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=;: ~~, , 1- A: Well,11 interpretiplan guidance to mean what:the 2 plan 'says'you do._ So, under certain' circumstanc'es.-

3 Now,.an EPA PAG says tha't-X'or Y or.Z'or-whatever, 4 you'take a protective' action, or;you consideritaking a-5 protective ' action'. And thsre 'is an overall- ALARA principle a- which is, you try to reduce dose whenever~ it's avoidable..

7- And ths plan guidanceand EPA.PAGs at'this point

.8 better be the's'ame thing. In other' wor'd's , if the plan-re-9 view -- if, in fact, plan' guidance'and EPA PAGs were'dif-to ferent, .that would have been flagged. So, I consider ths 11 fact that either thsy implement ths ' plan or they need~ EPA 12 PAGs as being ths same' thing.

la Q Okay. 'If you look at the last bullet there, it 14 says, " Consideration of relevant factors s'uch as evacuation is -time estimates',- shsiter availability, meteorological fore-16 casts, duration of release, availability of bus res'ource's, 17 road conditions,'etl~ cetera."

l 18 Did LILCO consider shelter availability?

I

.19 (Ths witness is looking at ths document.')

i 20 A- Would you excuse me a second? I'm trying to read 21 through this and recollec't the' actual'scen'ario.

l 22 Q All right.

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1 I

174 '

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1 (The witness 11s -looking at the document.)'

2. A Okay. To 'ths best of my. rec ~ollection, the' way the 3 . scenario. developed, sheltering' availability -- and by.

4 sheltering availability, that means telling peo~ple to shelter 5 themselves.in'a house, et cetera,'et cetera, or in an 6 institutional building which has lots-of air' changes was 7 inappropriate. That's' my. recollection'.

8 But did they~ consider a shelter availability in.

Q 9 making their recommendation?

10 ;I mean,.I understand you are'saying --

11 A It co'ld u have been a situation.where they might b 12 not have wanted to' if ths dose was substantial enough that 13 sheltering availability would have 'done 'nothing. For instance ,

14 to tell somebody to shelter themselves one mile in the~ down-15 wind of a plume that's going to give a fatal dose, you don't 16 consider shelter availability, or you discard it.

17 Suffice it to say that'the protective action such.

3 18 as sheltering availability or sheltering were reviewed by.the j

- 18 accident assessment staff.

~

I mean, they did that when 20 appropriate. But, there were cases when they should not have 21 considered sheltering .and they did ~not.

22 So, you'are saying that they did consider shelter

~

. Q l

. - - _ _ - ~ . _ _ , _ . . _ _ . . , . _ , _ . . , , _ _ . _ . . . _ . . . _ . _ _ _ , _ . - , -

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^75 1 availability?

2 A When appropriate, . yes , .to the best of my!.recollec-3- tion.. Yes~. ,

4 -Q And what did they do to consider it?- How did 5 they --

6 A One'of'the very toughjdecisions protective-action .

implementors must make' is decide'what:the'_ doses ~ people'will

~

7

.8 get are likely to be and 'the adequacy of sheltering. The' 9 prime' shelter is one's'own-personal ho~use. Institutional 10 buildings , because 'of 'a'ir- change restrictioits by zoning 11 ten'd to be' poorer.

12 . So', to determine.the availability and-adequacy

~

13 of shelter would require the' knowledge 'of -what a projected 14 dose could logically be. The ~ people ' involved with' accident 15 assessment did that correctly..

16 Q Now, here 'you say that as a general rule 17 institutional buildings are poorer at providing shelter --

18 A Can be pooreC. Some buildings that have closed,.

19 complete closed, rec'yclable air may be better.

20 Q Did you observe or he'ar any of the' accident 21 assessment people considering the actual availability and 22 feasibility of ho'spitals, for example, as shelter'ing areas?

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That woul_d not be in my ares. Thst- would not bes

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2 Lin;:my; area.

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Q: sand ~you recall no dis'cussions by'theac'cident ry j<' 4- c as s es'sment . s taff ' of' this"?.

'A .: No ,b.ecause . ~it 's no't my area'.--.

2

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. 5 ,

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s -Q s Even:if it-weren't' in your.ared, if:the people: ,

you had" observed began discussing, say, theTavailabilityfof$ ,

~

7 8- sch'ools 7and hospitals 1 for. sheltering, would :you have. notsd 9 it?

1 f, 't o - A. =I'think'we ha've'a-problem he~r~eJon shelter. Let's" 11' get back to what wefare' calling-shelter. If we are= calling '

E'Ol 12' -shelter'an area outsidelof theTimpacted ares,LI'm -

~

I'm i 13 going to speak hypothst'ically for a s'econd. ~ If, . in ' fact, e thsre was an area whi'ch'would not be' effec'ted by.ths'

~

14 ,

T 2

'15 radiation' dose from' 'a power plant, in Quedns,.-clearly outL 16 of- this path, shall we say, and you are ' calling: thdt a shelter 17 tho'se peopleJdid-look~at that.

18 But, I'm tialking about. sheltering' as an interim V

i-18 protective' action measure. 'It 's a techriical' term- for' being 20 in ths plume ' pathway as a 'do'se reduction t'echnique.

21' Let' me try to change that around a little. Today, l' 22 in Washington'if the~re~was a nuclear-disaster -- I don't know lLO i: . . _

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if: th'st's possible '- 11t might be appropriate toi tellipeople -

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~ to ishelter. because':by tellingithsm. to - evacuate 'and byfgetting 2- .

'..hel'd.up in:a'. traffic. Jam.they are' going'to rec'eivela larger-

3

-4 airborne! dose thanzif th'ey. stayed in-.their ho'use,xokay..

5 That's whst I am talking about when we"are; talking

' '~

s about sheltiering : availability.- -Did thsy consider ' wife'ther 7 X,;Y or Z-facilities outside'ths' area we~re'available? -Yes, 8 the~yJ did that,7 too . ~ I' don't call that. sheltering.

We [may be ' arguing a semantic term. ;Thst's.-

~

9 to available'other aress.. Okay'. Did they,do that? Yes, they'.

11 did'that.

.12 -Q No,- I'm not talking ab'out outside EPZ. I' m j us t .

13 -talking ab'out:-- it lists he're'that when someb'ody is' making the; protective ? action ~ r'ecommendation thst- that is both 'a

~

14 15 factor--and an' option thst they' would consider..

i

~16 A Yes'.

L

j. : 17 Q And, I'm asking you, did the peo'ple who' were l ~

18 making ths reco'mmendation' on 4this ' accident assessment staff

, 19 consider (a) the ' sheltering option; and (b) if they considered

[ .

p 20 that option, did they -assess .the..Lactuall ability and capability of ths buildings in that area, specifically the' l

21 l

i 22 - schools and hospitals', to shsiter people?

10 L

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78 Nb 1 A Let me -- the last part of your question, you are 2 asking -- are you asking, did they do specific analysis at 3 the time to determine ~if ho'spitals wduld, in fact, . or public i

4 buildings or whatever, would be adequate'to do shelter --

5 would be adequate ' sheltering techniques?

6 Is thdt what you are asking?

7 That's the'part-(b) of my question.

Q 8 A Okay. I don't think you' understand the proces~s 9

of protective' actions. ~ Excuse me,-with all due respect.-

10 Tho~se decisions are not made~during a drill.

11 Th6se' decisions are' preplanned. OneJean determine what 12 amount of sheltering they can expect from single' family 13 residences, et' cetera, et cetera. Much'of tha~t work was 14 done~many years ago in documents by government agencies.

15 That is already factored in.

16 The controlling factor of whether you would send 17 somebody to an institutional building for sheltering would is be a poor one if you th6ught you were going to later have 19 a high dose. You would evacuate and take them out.

20 And it was to my satisfaction that the staff 21 understood what the' constraints were of h6using and 22 institutional buildings around with regard to the sheltering O

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1 Land the ' dose { reduction. they would provide andimade /the 2 decisions correctly L the~r~e to ._.

"7 3~ If somebody -- les me answer your question very 4 : simply. If the'y hid said,1co'nsidering 'ths ' conditions, : that.

s -they were' going to send pe6pleJ to hospitals.to shelter.for.

t 6 -that specific redson, I would have ' rated' the~m inadequate, 7 b'ecause'thst's:not what thsy were supposed to.have'done. ,

a To ' send people ~to hospitals in - the 'line' ~of a 1 6

-9 plume to. shelter the'm-is. inadequate.unless-they needed severe 10 medical' attention orisomething like'thst. That would hdve 11 bee'nLinappropriate.

o. -12 And, I did not' observe Ethe~m doing that.

13 Q How~ about if they told people in .the hospitals 14 to shelter rathdr thin to evacuate?-

15 A That may be ~ appropriate 'and that may not ba 10 appropriate.. Thst's done in another~ area' called Health 17 Services and is another function.that I do not observe.

18 Q Okay. ' And you~ would not' consider thdt as 19 prot'ective --

20 A That'is a protective action but those'are again 21 preplanned. When the~y reach cer'tain levels , there'are 22 certain things thdt trigger certain responses in other areas.

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~ 't. l And:;s'omebody. probably. was; assigned to observe'-

i c 2 '. them lif thst ;wa's -an: exdrcise - ~obj'eetive.. and. that wasn'.t me.--

3. Q . Now,' youlmentioned that thss'e 'are faireddy...

~

4 . factored in, and I understand Ethat' thsre 'are' 'comput'er programs 5 <or whdtever'thdt factor in' shelter'ing.

.6 A Whstever.. , _ .

7 ~Q :Yo.u'said you~-- it'was your, understandingthat'-

8 ths -'acci' dent asses'sment staff- under~ stood the' shelter'ing

.1 s9 - fact' ors of the .buildin'gs :in the'; EPZ;. ' Thi's Tis rjust. from my '

~

. 10' " scribbling.-

u Is tha't.what you said?

.f Thsistaff that I observed under~ stood;thetvalue of

12 A-13 sheltering or'its lack of'value to" prevent dose.-

14 Q .With' specific reference to buildings in ths~EPZ?;

15 A To thefrespec't'that John Jones ~' house at 337, no.

16 The-gen'eral structural requirements.

Depending

~

17 Let'me use another. radiation analogy.

18 upon ths way.a house'is heated, whether it has a bas ~ement,

' 19 how'it is. winterized,-a house'can under'go one interchange 20 every five to severi hours or fiveyinterchanges in 20

. 21 minutes, depending upon-how.you ventilate'it.

22 Based on that wide ' degree 'of uncertainty and the O

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1 fact tlist .when:you tell) people to shelt'er you cannot itello 2- everyLperson.to assure"that they:only.:getone' air: change in, ~

./ 3 seven h6urs, becaus'e-~it's? impossible, given;thoseLmacro's'opic c -

4. constrai.nts the'se ' people .

V understood the value.1of sheltering.

5 Houses in the' northeast,.be'cause.of insulation, '

a because of . heating, whstever; . tend to b'e 'somewhat -bet'ter? for

'7

.- sheltering thsn,-say,. hous'e. 'on ' ths Virgin Islands .- iBut, . -

, a she'ltering is no't a particularly edfec~tive prot'ec'tive' action-9 when :large Jdoses ,'are ' encountered.-

These' people ~unders'ood'that.

~

10' t j' 11 -Q. I understand that in the' abstract'~ certain - types - -

i 12 of buildings hdve'certain sheltering factors.. Did you get: <

is any sense 'from~ the ' peoplethat you observed Ehat they had 14 done any studies ~or had any knowledge ~as to the' sheltering, t 15 the ' effectiveness as she'lter of buildings inthe EPZ?' .

- 18 And, let's break it down sp'ecifically as to 17 ho'spitals .

. 18 MR. CUMMING: Objection. I believe'that hss been.

19 asked and answered. But if witnes's wishes t6 clarify his 20 answer --

21 THE WITNESS: I did not ask the'm if they had done i

22 any specific ' studies about hospitals, nor have I ever asked

O 5

. - . . ~ - - _ - . - - _ _ _ _ _ - . _ _ . . . _ . . . , _ . _ . . _ . . _ - , ~ . . . _ _ _ , - - - _ . . _ - , . . _ . - -- ~ _ - .-.

- -82

/^s -

' L) that question.

1 How 'about 'sch'ools?'

2 Q.

3 A7 Noneifor specific.institutionschas,the EPA,.ever i since' I've been id61ng this job'.

. 5 Q Again,.in that same section', one of'the other

~

8 things ; listed as a. relevant factor is ths availability' of 7 bus res'ource's. .

a Did you rec'all ths person making protective" action-9 recobmen'dations giving-any consideration to that factor?

10 A Ths procedure followed in this plan, as any other 11 Pl an, is thsy are to find out through' collateral operations 12 going on' in the EOC whether ' this is available. T And if it's la available, th6n obviously they can use thdt to make' protective 14 actions.

15 In this case, thsy did. ~They did dscertain it ,

is was available, and they did factor it into the~ PAG-decisions.

17 Q Ascertained from whom?

18 A Another collateral group that had the~ responsibilit y 19 to tell them whether they did or didn't have bus --

20 availability of buses'.

21 Q So, this would be just another coordinator in l 22 the EOC --

O i

l l

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7-1 l

1 83

(_-

1 A I don't know.

2 Q --

telling the --

3 A I don't know'who it wa's. It may hdve come out of 4 the, briefing thdt yes', we hdve buses availabl'e; no, we don't.

5 I don't say the bus coordinator said they had-6 buses. That 's. no t my j ob . - There~is another-federal person that ch6cks to sed ~if the bus coordinator ch6cks' the bus

~

7 8 resources, I imagine.

9 Q So', I gather you yourself didn't, but do you know to of anybody else ~that did anything to verify the actual 11 availability of buses?

12 A I have no knowledge one way or the~other. It':s 13 not my responsibility.

14 Q Did he consider road co'nditions? ,

15 A Thd' factors. described here, road conditions, 16 meteorology, forecasts, bus resources, and shelter, all of 17 that information comes from a collater'al and it would --

18 excuse me, meteorology may or'may not come from a collateral.

19 That was factored in during'. briefings and used in all cases.

20 I cannot tell you the adequacy of that informa-21 tion, because thdt is not my job.-

22 Q I can tell from your comment on the lower left i

-w ~

y ,

84

( l 1

of Page B --

2 A Lower ~left, EOC-12. It looks-like'some scribbling 3

at the' bottom, s'ome ' cross-outs?

4 Q. Right'. 'Now, when you say he -- strike'that.

5 Maybe the easiest way would be, you said that 6

he did consider road conditions. What' road conditions did 7 you observe --

8 A I don't recollect what the~ road conditions wer~e 9 for this area.

to Q Okay. Looking at your comment on Page B which it is partially crossed out, .if I can dec'ipher it, it appears N/ 12 to say that additionally the road impediments to evacuation la were never reverted back to the' ' accident assessment staff 34 for analysis for. dose implications.-

15 A Tha't's right.

16 Q Would you consider the' impediments to evacuation 17 a road condition?

18 A This is what I'm saying to you. Impediments to 19 evacuation were never reverted back to the accident assessment 20 staff. In other words, the accident asses'sment staff did, 21 in fact, consider. road conditions.

22 What I was noting here was, apparently they were b-)

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. 85

,x"n_ ~

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1- given erronedus <information and probably -- and thi's is 2

speculation, probably the ' reason I' crossed it out, it was 3 p'ick'e'd up some fplace ~else.

4 'If the'y'were told-they had a' clear.. road, their 5 -job is noti-- theVaccident. assessment staff is not to che'ck, are you sure'all the roads are clear. LYou know, you've~given

~

-6 7- me information~ 'saying 'the' ' roads. are !clea'r, I-proceed with 8 that information'. If yoti tell' me ~20 biises' are 'available, 8 they know 20 buses' are~available.

10 They are'given wrong information. And anybody 11 who~ finds wrong information can make'that assertion and they V 12 should note it s'ome' place'. We all know tha't.

13 The' question was, it might' have been' crossed out 14 here because'it had been' picked up some' place'else.

15 Q And it';s:your understanding tha't the~' accident 16 assessment staff was given incorrect' info'rmation?

t 17 A They may have 'at different times during the drill.

18 I might add that ce'rtain scenarios test pe6ple by throwing in

! 18 During a real life drill like inaccurate information.

'20 Chernobyl and Three Mile Island, they did not get a hundred 21 percent correct. data.

22 Q Was it your understanding that the' scenario at O

~ '

' , ' 86'

.r- <

!%)%.

1 ~ this ; drill ~ would . req ~uire the' input of:iriaccurate 'information?

2 ,

'A I : don' t; recollect' ?that..

~

cnd25 f 3 'Q Isn'_t it correc't' that if the'.' accident assessment staff- was giveri' inaccurate informati5n'- as- to -road conditiions ,

~

4L

- 5 this ;could lead.to the'ir giving the'l wrong protective action

!. 6 < recommenda tion?-

.e.

tc, 7 A:. It is entirely.possible that if,anybody on'ths a-

-8 accident' asses'sment_ ' team is given = incorrect information 4

9 regarding any ofL the factors .that"they.'are ' liable 'to make 1

~

10 : incorrect deci'sion's .' '

( .

11 A . good accident assessment staff'will also try

. .O ~

12 to tak'e protective' actions in such'a way.to minimize the impact of bad data.'

~

13

' ~

14 Q Did y~u o see~'any of that occurring?

15 A Y e s ,- -I d i d '. ,

_16 Q Uhst did you observe?

17 A There was an error thst.I observed, one or two

~

. 18 errors thst I observed in either the' transcription or L

18 ' whatever of data, of dose data, and while in general it was rapidly corrected -- at lesst one was rapidly corrected --

~

20 21 I not'ed thst ths staff was able ~to function .and understand 22 the possibilities and potentials of bad data and act lO

, ,, i

. 87'

Lf

-1 accordingly, s

,2 In other words, if youare' experienced-and you.

3 know what you'are doing and you' sed'a piec'eTof data.that looks 4 Out of-line'with othdrs,cyou'can reg'ard it or. disregard it as i 5 you.please.

6 'Q In that instance of their rep'orting a piece 'of .

7 data in' accurately, wa's-tha't an instance'of someb~ody actually-8 receiving inc'orrect. info'rmation?

9 A I don't:know.

[

10 Q- Who' was res~ponsible 'for posting this data? Was that the' accident asses'sment staff?

.11 O 12 A 'Which'one are we~ referring to?

Th6 on'e 'you just -- the~ 'ex' ample ~you j ust gave me,

~

13 Q f 14 A Thd one~I was refer ~ ring to. Page'C, there'are 1

15 two. 'Let'me reread this, okay, please?

16 Q Yes.

t l

. 17 (The witness is looking at the ' doc'ument.-)

i L

18 A Okay. 'I can give you -- this refreshe~s' my l 19 memory. Th6re'was an error received in data. I was not 20 able to ascertain whether the per' son who.got that data heard 21 it wrong or was given it, because'I wasn't party to the phone 22 conversation.

i.

.I5

- 88 7

. ~

1 Essentially what happened was, the' dose rate of s

2 900 MR'per hour was reported as'7,000 meters instead.of 700-a s 3 meters. This.would obviou~ sly ~cause' people to'be' concerned 4 that there was a lot'more' radioactivity,'a lot further out 5 from the' plant, so.it was immediately flagged and reviewed. -

6 It'was also -- the first thing that was done'when

~

7 that was rep'orted,.because that would be inconsistent with ,

8 projections based on the' status, thefirst thing that'the' 9 accident assessment coordinator or whatever we want to call' 10 him did was assure tha~t that would have no inip'lications on 11 protective' actions.

12 In other words, the protective' actions had already 13 been taken and peo'ple were 'already well cleared out, et' cetera ,

And through 'an iterative ' process they' checked

~

14 et cetera.

15 the data and found it to be wrong and they co'rrected the 16 probl'em, as I noted, within five minutes. '

17 Now, let' me read the second one. i 18 (The witness'is-looking at the' document.)

i 19 Q Okay.

20 A Okay. The second one involved the fact that the i

21 blackboard, the' green board, whatever was, the status board, 22 was not big enough'and it was possible'to make er'rors such i

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that a'mhasuremen't might be put dcwn, as -- let's.seeiwhat ry,. Q 1 -

a projection rib vice'-versa..

<2 ' we've got her^e- s l' 'a 'Q Do you know ~whdn theTaccident assessment staff ,

4 idarned that the.re ha'd been impediments, or' were impedim'ents ' -

4'

's, . A I don't. recollect.-

v. ;

,d '

~

-s Q Wha't sort of expertise 'could have. bee'n brought'. to

- fear,, or wha't could a good accident. asses'sment staff do 8 to mitigate 'the' conocq'uences' of not' knowing ther there.~were

-9 two major traffic. impediments?

b '

in MR. MILLER: I'm sorry, are/you asking his opinion o'l somewhat coEl d have. don'e better?- If so, I am going- to

~

11 o

O 12 object to the ~que.r, tion.

13 I think we' are here'to hear hiscobs'ervations and 14 not his opinion ~ of~ what someone 'should have :done or could have done.i ,

is '

IP 16 BY MS. CASEY: (Co~ntinuing) 17 Q Y5u can answer my ques ~ tion.

18 A Let's go thropgh -- repeat the' ' question, please.

19 Whenever somebody objects, r lose my train of thought'.

20 MS. CASEY: -I really<-- could you read the 21 question back?

22 THE WITNESS: . I'm sorry.

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-1' (The -reporter, read back 'the' .last question.).

-2 THE WITNESS: One of thd bes't things that a good

-3.

accident assessment staff can do is 'to be' ' pro-active.- If.

4 you believe'thatcan. accident'is liksly or.could worsen, thsn beforefthe1 worsening of the a'ccident actually oc'cu'rs-you

~

5

~ ive act ions.:

a . beg'in to take' anticipatory protect It requires understanding clearly ths ' status - of

~

7-a the plantcand what could go wrong. ' If . you are: pro-active , .

9 then- the p_eople 'are evacuated well in advance iof the ' dose to : reaching the1 area that you'-are ' evacuating the'ni from.

MR. CUMMING: If counsel Wi'shes to askJa hypothe '-

11 k 12 tica1' question in the : future, maybe 'wd 'can just preface it

- la with'that. .

14 BY MS. CASEY: (Continuing)

< - 15 Q Did you observe the" accident asses'sment staff at- .,.,

16 this exercise 'taking any pro-active ' step's which would have 17 mitigated ths con'seque'nces of thds'e~ impediments which they 18 apparently did not know'about?

i 19 A As I responded in previous questioning, .in general 20 the' ' accident assessment staff that did this was pro-active.

21 Q What did.they do specifically?

22 A By previous ques'tions, I indicated -- in response O,s_

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, } 1 : to previous questions,. I/ indicated.that.they wer~e.using ;.

2. what-if = ' scenarios ,1; proj ecting worsening planti conditions .well. -

'^ i ; 3' ;beforeEthd' plant' conditions.actually wo'rsened. ~\They used- .

- . ~

- -n 4: nomographs'. ' They had 'several t'ech'nical types' of pre-

.. ~

i 's . establfshed. proce~dures which 'thsy referred to. .

6 ,

[Q ~Did' they make'Jany attenipt - t'o revieti the' ' evacuation i

' time Des'timates?-

. 7-

: . 8 -

.A Thd ghaiatd h h fd/ f Health Service's^ Coordinator, -in M.

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p 9 his ' action --: taking hrs protec'tive' actions,-I: observed him:

t

-.r-10- mak'e determinaLions with. regard to evacu'ation t'imes. I l

11 did noth seeDhim look "at ths evacu'ation'. time .~cha'rts.- I- *

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12 ques'tioned h' im. .He recited them to me.

m i

E13 I asked hfm whdre his charts,were.-.~Heshowed me.

14' lHezadmitted he hadn't> looke'd;at them, that hd had memorized 7

. 15 th'em. And, I ~ note d ~ that .

16 And-IL sat - him down for about 15 minutes three

~ 17- times' during the' ' day and indicated that I considered the

'Is procedure of meniorizing poor. I probably used much stronger

[-

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18 language than that, that during accidents -- because I have 4 '

been involved in 'emergen'cy responses, one does not rely on a

r 20 memory, one relies'on procedures, one relies on having the

-21 22 data available, t Os

,.,-; , :a , _, . . : . , .- - . , _ . . . - , . - . - . - , . , , . - - . _ _ . - . . - . . - . . . - - . . . - . - . - _ _ . - _ .

s ,, 3 92-y " ,,-$

,' .To summarize 'what happened, I beat- this. guy Jto

~

1 12 death verbally for: whdt I' con'sidered_ a very . poor' error-in

.3 . judgment. ;His information'was' exactly correct. 'He had-

~

4 memorized it" correctly. 'And I-indicated that if'I ever,!ever

,3 : observed a drill again in which'.he~ used his' memory,.I would s - mak'e the 'same kind of c~o'mments .-

7 Q Okay., Now, I assume-'you are' talking about what 8 you' have 'noted in -your c'omment on Page ~B?

9 A. I think'that's whit.I'm referring to.

t

, 10 Q _0kay. - And,. you say_ there -- is that whit you are 11 referring to?.

- U 12. A- Yes.

13 Q Okay. 'You'say there, "I= asked what th6 time 14 estimates were and h6 knew off the' top of hi's he'ad that it 15 would take eight h6urs under the ' worst wintes conditions =."

4 16 -A Uh-huh.

17 Q Did. h6 ~tell you' anything about the' evacuation l- 18 time' estimates when there wer~e impediments on the' evacuation

-19 routes?

20 A I don't remember exactly what he told me. I've l

j. 21 used an ex' ample here of the eight'h6urs. He'gave me more 22 information than this. He -- the gist of what happened, as LO .

- ~

3

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1. :I rec'ollect,L s iths' gentleman in' charge ~'tried-to impress me 2 with his memory, and-I. beat him to deathffor using..hfs 3 . memory when peo~ple are 'to make' value. ' judgments like 'this .

4 'Q So',-you~ consider this-to bs'aiserious~probl~em;

~

5 is that correct?

'6- A I consider'ed it the-'use'of very poor error-in 4

'7 judgment, what.that one' person ldid. ~And.I wroteLit iup'..

8 Q Okay. ' Did you yoursel'f do theicrossing ~ over . in-9 the boxes on thfs page?

10 Do'you rec'all?

~

11 -A I don' t recall, but it would bs safe to assume

( ',

I did'for the'rea~ sons stated earlier.

12 13 Q Well, do you' recall wh'ethsr' you con's idered thfs . an 14 ARCA orla deficfency?-

15 A Let' me ' state'this.- It wa's not in my area of 16 expertise, okay. 'So, for somebody else~to correct and to l

17 commen't on, I obs'erved tha't the'y did not'get the' correct-i

( 18 information, it wasn' t: reverted back 'as -I say.

19 What1I did here was actually make' a mistake and 20 write it on my form, because it's not' my job to' comment-21 on these' things. And at one of the meetings later on when 22 we discuss issues like this, my job is to assure that whomever O

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2 knew about '.it.?and)tha~t - the'y.would rep ~ ort. it.

,s

(; .3. Q- Well,qperhdpsrI'm misredding1your c~omment,;butLI' 4- under'sto d you' th6ught :itiwas your. fundtion?to ? determine Jif;

~

f .

5 the acc~i~ dent assessment, staff knew thd frime# estimates ~ for -

.a evacuation --

A - Wait = a' minute..- ~We'are'obviously talking about'two'~

8 different things, .then. 1I'm sorry.-

9 Where'are~you?.

g. ~10 Q Lo_wer left-hand corner, PageB-37. . '

11 'A- Right. ~ I tho~ught you' meant -ths Jcross-out at ..the~ -

f.. :.

~

12 bottom of thel page..

-13 Q No. 1If you will' note whe'r'eyou: are supposed. to 14 chdekfone b6x, both'boxec hdve bee ~n -- -

i, 15 A~ Oh', ' .I' m sorry.- I was referring to -- please l

scratch'whatI wa's s_aying. I thought you wer'e' talking.about

~

16

.17 this stuff at-the bottom.

L18 Okay. Let's start this again. You are'asking did I cross out Defici~en~cy', Area for Corrective' Action.

~

19

! 20 I don't recall what happened the're._ I really t

i. 21 don't. Certainly, that could hdve been triggered because of L

the cross-out and I relayed the' information to somebody else

~

L 22

.O-I

c 95 1

or for some' reason.I was, in talking it was a. defici' ncy, e or 2 I hste to admit this but I could have'chdeksd ths wrong box 3 and noticed it later.

h, you1appeare 4 Well, from~what you said before d.

Q .

S to, in your opinion -- in your opinion ~, ay s R adia_ ion Health' [f .

s. _

6 Coordinator memorizing evacuation times was not appropriate; 7 is that correc't'?

~

8 A I would not rate th6t as a defici~en~cy. I would 8 'not rate that as a deficiency. I would rate it merel'y for 10 corrective' action.

11 I hsve no way of knowing that all eight' memorized 12 it . 'In fact, .to me th6 procedure says that you don't --

13 ther~e would be'those ~who would be on ths accident assessment 14 staff who might' say memorizing is fine. ' This may be a 15 judgment call.

16 . And, .certainly everybody who is involved in this 17 proceeding knows that peo'ple have to use judgment. It just 18 so hsppen~s' my standards are'a lot highe~r, or'I think~I have th6 most critical standards around. And I don't.want people 18 20 to rely en memory or whatever.

21 And, I am sure, fairly sure, that the fact that 22 somebody used their m'emory might be 'found acceptable in other O

V i

96 J .-

1 regions or othe~r areas. I just am toughdr than anybody 2 else..

3 Q In general, what' criteria do you use 'for. distinguis h-4 ing betwee'n an ARCA and a deficiency?

5 A Well', .let 's' be~ 'more ' spec ~ific.

6 Q What is your working definition? .

7 A A defici'ency'is generally defined, you know.

8 But what I'm trying to say is -- I wsnt to be' specific hsre.

9 A deficiency is not a board thst's too 'small. (

10 That's.an ared for: corrective' action. A defici'shey' is not =

11 somebody memorizing something instead of .using the ' plan to

/, )

12 impress a, grader. Th6se, by definition, are'not deficiencies.

13 Q How~ about an accident assessment staff having 14 unavailable 'to it information about two' traffic ' impediments

~

15 on evacuation routes?-

16 A The' availability of that is-for somebody else to 17 grade, not 1.

18 Q You said that in your opinion the' fact'that 19 somebody has memorized evacuation times wo'uld not be a

~

20 deficiency; is thdt correct?

21 A The' critical test of a deficiency is whether, 22 after it's all over, I have'some kind of reasonable assurance I)

o

97 4

d-I that this person isi going to provide -- cnr .thfs. person in

-2 part to a total is going to provide'for'thd'protec' tion of 3 ths ~public hsalth Jand safety. ' The' ' fact' :that ths ' gentleman p 4 ch6se to impress'me with his' memory wds,.in fact', .an error 5 in judgment.

6 It did not'giveme any rea'sonab1'e'disassurance, 7 as it were, or'whatever',.tha~t he was not' going to protect 8 the'public hsalth and safety. The~refore, it-wasn't a 9 de fici^ency.

10 In'my standards, memorizing is poor practice.

And I don't want people ~to do that. 'That's my per'sonal

~

11 i

12 judgment; and, .ther~efore , it's an area for co'rrective ' action.

13 It probably would go unnoticed in most p1' ace's.-

s 14 Q Well, isn't your concern with thd memorization is that he'might' memorize'something wron'g or times may have

~

16 changed and it would thereby lea'd to an incorrect --

17 A That's'my co'ncern. But he' 'did not' memorize it 18 wrong. He had m'emorized it correctly. 'He'had the right 19 information, and he' also knew where'the' right' answers were.

20 I' mean, my specific commen't was, he' was tryin g 21 to show me lui ha~d memorized the plan. And that's Tally 22 great. He memorized the plan, and he' knew where ~the plan c

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I was. ' And I wanted him to: look' at ithe' plan; and tell me, _even 2

if hs knew it. :And.I did that at Roche' ster' Gas and Electric.

3 .I did it.at.Nine Mile Point.

~4 -Thd Director of~the~ Radiation Program for.New 5 York' State wh6 does it in the'New' York State Program knows:

6 every time tha~t Im theYe - he has go't to ' pull out -the' ' damn -

i 7

plan and point to it, and that's where hs'get's it from. =And 8

hemay have memorized it, ~ .too.'

8 But, that's,ths way I am.

10 Q I notice ~in your. recommendation on this point 11 you said that the Radiation Health Coordinator should review

(.) 12 ths time'es~timates for. evacuation and demonstrate this in is the next exercise ~and drill.

I4 A That's. right'.

15 luu H alth' Coordinator should be/

16 Q

Th(es' i consulted whsn an impediment to evacuation is encountered.

/

17 ~

A That's right.

18 Q And, again there is a cross-out here. Did you 19 cross that out, or do you know who' did?

20 A No, I don't recollect. But I would assume that 21 I did.

22 Q Why? Why would you have crossed that out?

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-l 99

'me ?

1 A For'the same rea' sons I crossed.out the'othsr one.

2 It was rep'orted in a more ' appropriate areal for s'omebody

~

3 else.

4 Q Okay. But.you did not cross out ths'part that 5 ths -- the' part ab6ut the Coordinator should review the 6 time ' estimates'; is that correct'?

7 A I'm sorry, hold on. 'That stays in. . There is no 8 cross-out thdre.

9 Why, in your opinion, should ths' Radiation Q

10 Health Coordinator bs' consulted when traffic ' impediments are 11 encountered?

(

'~'

)

12 A He 'should be consulted because he ~is responsive --

13 he is not responsive.. He is supposed to receive 'acc~ urate 14 and adequate' timely information to road conditions. So, 15 therefore, he'should bc' consulted.

16 Q And why specifically does hs need this informa-17 tion?

18 A So that hs can have 'the bes't available information 18 to make protective' action decisions and use protective 20 action guidance, i

21 Q Well, does he'need the information about the 22 impediments so that he can factor in the possibility of a I'l a

100 L.;'

I longer ~ evacuation ~timd?

2 A -That would.be'certainly one. reason if evacuation 3 had not been take'n', yes.- I 4 If you~lookat Page D,.you stated there as an area Q

5 for corrective' action tha't the~'deci'sion to send about 100,000 6 people to Nassau Veterans Coliseum for monitoring --

7 A I'm sorry. 'I'm -- you will-have to start again.

8 I have my Page D here. Could you sho'w me'yours?

9 MS. CASEY: Off the record.

10 (O f f- the'-r~e co rd . )

11 MS. CASEY: I would like to have marked as ls) 12 Giardina' Exhibit 7 thi's exercise ' evaluation critique form, ind:xx 13 (The document referred to is 14 marked as Giardina Deposition 15 Exhibit Number 7'for identifi-16 cation.)

17 BY MS. CASEY: (Continuing) is If you will compare Exhibit 6 with Exhibit 7, Q

19 you will see that Exhibit 7 has an additional page.

20 Just tell me, is it at the' end?

A 21 Q Yes.

22 A Okay.

O Ri

101 x~,

1 Q On' Exhibit' 7 'now', .do you' sed 'a Page 'D? .

2 A Let'me tell you'what I have.

3 Q Okay.

4 A- Exhibit' 6 h6s D and E at th6 ' top, and .it looks like D and E we're 'xer'ox'e d togethdr', photocopied togethe'r.

~

5 l 6 And, .th6n 7 'hss j us t' E.as ths 'last 'page , and D 7 is thdfpage before it.

8 Q Did you' fill out Page'D of' Exhibit 7? Is that your 9 writing?

10 A Whfch~ever', yes. I would like'to state'for ths

.11 record that I did not xerox these.

i

)

12 Q Your first comment on tha't page' notes that at one point the Health' Services Coordinator misstated a PAG.

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13 14 Can you tell me 'why' thfs matter's?

15 A Yes', bec~ause'everybody is supposed to pass along 16 ths' correct and accurate information'. 'They are' supposed 17 to understand what they are'doing.

18 And a misstatement, even if unintentional, in 19 my opinion, .in my j udgment, should be noted.

20 Q Is it possible'that in a real accident this 21 error might have led to an incorrect' protective' action 22 rec'ommendation?

(')

x>

. 102 i

u.-

1 A No. ~ It- was my . judgment that : this could not have 2

occurred.

3 Q Could you explain the comment you made'about 4

the' Nassau Veterans Coliseum?

5 A Referring to what's on Page D at the bottom?

6 Q Right'.

7 A Please let' me read that.

8 Q Sure.

8 (The witness is looking at the document.)

10 A I don'tirec~ollect this terribly well.

11 Well, would -- is it fair to say that it was your

,c 3 Q

't.) 12 opinion at the' time that the decision to send 100,000 18 people to Nassau Veterans Coliseum might'have been in-I4 appropriate -- was appropriate?

15 A Yeah. What I'm saying he're is the' decision to 16 send about 100,000 people to the Nassau Veterans Coliseum I7 for monitoring and decontamination appeared appropriate due 18 to the " release / deposition."

19 Now, I don't recall what I was referring to there.

20 But I am saying it was This does not jog my memory.

21 appropriate.

22

,, Q Was it also your opinion at the time that the

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7

,c

es L5 1 capability of ths Coliseum hsndling7that number. of people 2 was dubious?

i:

2 A' .Okay. :You are.' referring.toimy s'econd sentence?

1

=

,4

.Q - Right'.-

5 A. And, again'while'-- I'm going to read' aloud e whst I'said. '"While ths NVC is~ capable'of hsndling 30,000 7 or so in two h6urs..."' I can'.t:redd tha~t. Is it two'or 12?

8 Q It looks like 12 to'me.

9 A Okay. '" ..ths' expanded use of the~ facility.is to dubious."

11 I cannot recall what I meant. . ' But,. looking at

) 12 the rec'ommendati ths side it says, "A review of the 13 to handle the 100,000 people is..

f y adequacyofthe( / )

14 necessary." '

15 So, I was raising a rec ^ommen'dation that they should 16 review thdt to ' ees h6w the'y' could handle 100,0.00 people.

17 And, looking at ths last page'of'the' exhibit, Q

18 Page E --

19 A Yes.

20 Q -- what's ths' significance of your comment there?

21 A Please let me read it.

22 Q Sure.

lO L

104 t

. 's 1 (Ths witness is 'looking at ths document.)

2 A To' the best of my recoll'ec' tion) thsre was .a pie chart and thd pie ' chart was one of these ' pro-active 'whst-if

~

a 4 types of things.-

5 The way ths' scenario was apparently developed --

6 and I'm using deductive ~ reasoning her~e -- it is very rare 7 that you would ever con'ider s or be con ~ce'rned about a situation 8 whsre 'the ' containment ' failed but ths core 'didn't, because 9 the~'co~re hss ths~ radioactivity to be' released and ths con-10 tainment does not. Those' people who' designed thd technical workings of the' scenario, the' actual redetor decident which

~

11 i /

~'~' 12 is not' EPA, devised some'way to have~a release to containment 13 without ths core failure. Okay.

14 Whsther.that's realistic, possible, I have no --

15 I can' t judge. ' What 'thsy' did was, .they' uncovered an area 16 in the plan -- an attachment to ths plan where the logic 17 wasn't covered. Okay. That's what I was noting.

18 And I fur ~ther noted that the Health Coordinator 19 and the nuclear engineer were -- used their judgment to work 20 around the fact that that wasn't covered. In fact, I do 21 recall that the'y just assumed core and containment failure 22 and used that nomograph which would have besn obviously much

\(~j)

105

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1 more severe.'

2 My rec ~o'mmendation was to . take 'a look 'at their 3 attachment and revise it to take' care'of the' function.

4 Q To your knowledge, has that . attach'ient n been 5 revised?

6 A I don't know.

7 Q. Is it correct to state'that your assignment did 8 not include review'of recommendations or' implementation of 9 ingestion pathway protective' actions?

10 A Restate'that. My assignment that day?

11 Q Right'.-

o 12 A To the best of my recollection,.it wasn't one of 13 the obj ectives. I'm not clear on that. I don't remember.

14 Q So, to the'best of your recollection that was not 15 one of your assignments?

16 A To the best of my recollection, it wasn't a 17 question that day. Therefore, it wouldn't ha've been one of 18 my assignments.

19 In othe'r words, therefore, it was not tested.

20 Q You mentioned that you received a draft of the 21 FEMA report; is that correct?

22 A I think the answer to the question was, I found b

a

r 106 1 one in my files which; indicates I. received.it. 'Yes.'

2 Q Do you~ recall receiving it?

3 A Not'really. .It is procedure to'get the draft and 4 to review it sho'rtly thereafter. I.cannot r'ecoll'ect getting 5 it, but it was in'my file, o Q Do you. recall' making any' c'omments on the draft?

7 A Yes,-I do.

8 Q Can you tell' me what areas your comments went 9 to?

10 A I can't be' specific. My rec'ollection'is that 11 the~y were fairly trivial, such~ as spelling errors and word-(

^' ') 12 ing ch'anges. That's a r'ecollection.

13 Q In your opinion, were any of the' ch'a'nges that 14 you suggested substantive?

15 A I don't recollect any, no.

And, to who~m did you transmit your comments?

^

16 Q 17 A I can't say with surety. It should have been' to 18 Roger Kowieski or whoever was in charge. It would -- to 19 somebody at FEMA in tho' Regional Office ~. I don't know.

20 Q Did anybody else'in your Agency review the 21 report?

22 A To the best of my knowledge, nobody in EPA Region I I O

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F.

I i

107 a >

did. I'did not distribute it to anybody'in EPA Region II, (1 i t

l- 2 . nor would the're be 'any reason thdt FEMA ~ would give 's'omebody 3 outsidemy office'one. ,

4

!. 4 Whsther it wds reviewed at ths Headquarter's 5

levelofthsOfficeTofRadiatio'n'Programshor'another" EPA e area,-I could not'tell you one'way or anothsr.. I've'never 1 hsd that happeri or .I've 'never known it to happen.

dnd~3A 8 Q. You said earlier that'maybe'if you saw the review 9 of Rev' 6, 7 'and 8 you~ might' be 'able 'to identify those portions you had worke'd on.

10 11 MS. CASEY: So, I would likefto have marked as j h i 12 an exhibit the review of ReV 8.

L indsxx 13 (The' ' document referred to is i

14 marked as Giardina Deposition is Exhibit Number 8 for identifi-to cation.)

l 17 BY MS. CASEY: (Continuing) ,

Would you look~at this Exhibit 87

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18 Q Okay.

19 (The witnes's is looking at the ' document.)

20 A In seeing thi's, I can now state that I did not

i. . 21 review Revisian'8. 'A member of my staff did, i

22 Q Now'--

O

t 108

b. 1 A Oo's.-

p 'There is something -- I got Revision ~8 2

which is this, whicli' 'is what I just said. .And then we have

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3 this which 'is also Exhibit 87 4

Q Yes.

5 A Excuse me. ~What I just held.up the second time 6 was a letter to Mr. Victor Stello from Mr. Dave McLoughlin.

7 And I take it, you consider both'of these Exhibit 8?

8 Q Well, that is the transmittal letter' for the 8

review, as I understand it.

10 Petrhaps for' clarity, we can call that Exhibit 11 8 (2) .

(q indexx 12 (The document referred to is I3 marked as Giardina Deposition I4 Exhibit Number 8(2) for iden-15 tification.)

16 THE WITNESS: The' first time I saw this was when I7 I met with Mr. Cumming who gave'me a copy of this without 18 the LILCO Transition Plan for Shoreham, Revision 8. He 19 did not give me this.

2 In now seeing this, which is the LILCO Transition 21 Plan for Shoreham, Revision 8, Key to Consolidated RAC Review, I can tell you that I did not do that review; that a U

'i 109

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member of my staff did.

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1 2 Q Who was thd' staff m: ember?

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- 3 A Shawn Googins , . spelled G-o-o-g-i-n-s .* I will

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4' indicate, though,ghapIdid_. sign-offonwhatever' review s material was sent.

8 Q Do you'have 'any personal'kn' owl' edge'of'the review 7 that Mr. Googins performed?

8 A ' Goo'g ins?- Could you bemore~ specific?

9 Q Well,.for instance', the way.you said you signed to off on', what did you have 'to do in order to do that?

11 A I rec ~ollec't' that before 'any documen'ts were i! 12 prep'ared for my signature 'that I discussed this for some 13 time with Mr. Googins, some time being less tha~n an ho'ur.

And I asked him to orally summarize what he was

~

14 is putting down. And I also was very careful in instructing 16 him on the format we use. And thfs came'into my office a 17 couple of times', and I just wanted to make sure that the is format was correct'.

19 There~was one specific co' mment that he' had whi~ch 20 I really can't recollect. I know'it was not a significant 21 co'mment insofar as befng terribly substantive, but it was It involved training, a subset 22 a good suggestion'or co'mment.

O

110 of wh6 should be ' trained and wh6:sho'uld not be trained. 'And t-2 I instructed him to call another gentleman wh6 was involved a in the review 'of th6 plan, a Mr. Keller, and to get' his 4 opinion'and discu'ss it..

5 And based on'what the~y would' decide,.that would be an appropriate commen't.

~

t 6 'And.Mr. Goo'g ins did that, told 7 me what they'had discussed.

8 Q And you can' t remember what --

9 A It involved a training issue, and it involved an to area -- to the best of my recoll'ection, it was not directly 11 EPA's responsibility. 'For background, I wanted Mr. Googins O'

~~

12 to look' at thfs bec~ause he has five 'or six years of health is physics' experience, very specifically applied at some 14 points of his career at-the' National Institute'of Health 15 wher'e he was a radiation'safet'y officer, and I thought it 16 might be wise to get' another perspective 'in reviewing that.

17 Tha't-is one'of the reasons I assigned it to him 18 as opposed to somebody el~se. And it was an area that might 19 have been in his area of expertise by ~cxperience but not by 20 EPA authority.

21 Q Okay. So, he was the only EPA person who reviewed 22 these --

/~%

O

111 1 A He was the'only EPA per~ son in the Region II office 2 who worked for me. 'I don't believ'e the~r'e'was anybody else 3 in the' EPA. 'I can't tes'tify-to the surety of that.

4 Q Okay. 'And, to your knowledge, he confined his 1 5 concern .to this one ' point; is that correc't?

6 A No. 'He - 'it is my impres'sion'in discussing this 7 with him that he went'through'it'very thoroughly, looked through 'the' ' plan but that his co'm ments wer'e limited to that

~

8 9 and several other smaller things, tho~ ugh he'did look'at to each' -- he info'rmed me 'that he ' looked at. cach' EPA area of 11 responsibility.

'# 12 Q To your knowledge, did he' attend any RAC meetings la at whfch'this plan wa's considered?

14 A To the best of my recollec' tion, at the RAC 15 meeting that that was considered he was.on vacation or leave.

16 And this is all my recollection. I believe I attended the 17 portion of that which was where he'gave' discussions or had, 18 which was a limited portion.

That's a rccollection.

~

19 20 Q And that was the only meeting over this particular 21 set of --

22 A To the best of my recollection.

112 c

1 1

Q What'are the' EPA spec ~ific portions of this? Could 2 you identify theni for' me?

3 A Yes. I can' t withoist re:? erring to this and I 4 need another document.

5 Q Wha't is theother document? Do'you recall?

6 A We ha've a guide and checklist that we dse'at EPA 7 to review plans which'have' identified out the' element numbers.

8 It's a.proco' dural document.

9 Q Did Mr. Googins prepare'a written comment?

10 A That is correct.

11 Q Could you tell me what the ' comment was?

!D

' >' 12 MR. MILLER: I'm going to object to that.

13 BY MS. CASEY:- (Continuing) 14 Q Could you tell me.what the' comment was?

15 A I think I've done as best as I could in my 16 previous answer. It involved training of various subsets, 17 and that's about as much' 'as I can recollect.

18 MS CASEY: Mr. Cumming, we would like the copy 18 of that document.

20 MR. CUMMING: Okay. Let me'again restate what 21 I stated earlier. FEMA objects to the line of questioning 22 with respect to Revision 7 and 8 of the LILCO plan as not (O

v

113 1 being a part of this procee' ding. However, bec~ause we'are 2 representing EPA we have -- and based on the instructions 3 to me by EPA's counsel ~'s. operation, we have no objection to 4 produci'ng the' document.- ' But I' 'should state that _we have 5 received no formal discovery req'uest from the Intervenors 6 concerning Revision'7 and.8.

f 7 We did provide,'as a courtesy,' the' transmittal a

letter and the' revision itself to all parties. But we have 8

not yet received any discovery req'uest.

to And I have no objection to having this produced 11 in formally. I will note that Mr. Skuinuck is here from s

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12 the Regional Counsels Operations. He'can make'a note of 13 your document request, and on behalf of the' EPA we will 14 provide that to you.

18 MS. CASEY: Thank you.

16 MR. CUMMING: Assuming that they in their 37 review process have no objection. And I understand that is, I8 in fact , their position.

19 MS. CASEY: Thank you. I have no further 20 questions.

MR. CUMMING: Before we go off the record, I just want to state that we don't waive signature and that we

-114 n.

V- 1 would request- that Mr. Giardina's. deposition 1be Jsent to him 2 so that-hs~can review it for' appropriate' correction at his '

3 address at 26 Federal Plaza.

4 MR. PIRFO:" The' NRC staff ha's no, questions.

.i >;

5 'MS.:CASEY: Thank .'you' very niuch; '

6 (Whe'reupon; ,the; 'taki'ng, of the ' deposition was 7 concluded at 12i57 p.m.,'this same day.)

8 i;

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10 Y Off

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/ PAlf A. GIARDINA 11

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b 12 13 Sub cribed and vom to before me19O

.d;yof this

4

- Notay Pub 33 31.

16 f.1y Commicsion Expires WARREN H, LLEWELLYN I7 N9d pry Public,8 State of New York

.,) , 160.31 432182 Qud416 edin New York County Jg CommisWort Egites NamenespeeN 10 20 21 22 O

t Y 115 (d

j

t. CERTIFICATE OF NOTARY PUBLICAND REPORTER 2

3 I, GARRETT J. WALSH, JR. , thd ' officer before whom the 4 foregoing deposition'was.takin,.do hereby ce'rtify.that thi 5

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s .

s witnes's whose ' testimony appear.s in the foregoing deposition,

, 6 Page 'l thr'ough 114, was -duly sworn by me; tha~t,thd' testimony 7 of said witness wasotaken by me'and thereafter reduced to a typewriting by' me or under'my direction; that said deposition t

is a true record of the testimony.given by said witness; that

> 9 to I 'am neither counsel for, related to, nor employed by any of-11 the parties' to the' action in which'this deposition was taken; 12 and, further, .that' I 'am not a relative or' ' employee of any attorney or counsel' employed by thd parties heret'o, nor

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13 14 financially or othe'rwise interested in the ~ outcome 'of this 15 action.

16 17 18 GARRETT g( WALSH Notary Public in and for the

[

Commonwealth of Virginia 10 20 My Commission Expires: January 9, 1989 21 1

' 22

._ J%d44c.y J 1.1

. . W.. .

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6h Rl/kf h/Y #l 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY g/ REGION 11 O-

24 FEDERAL PLAZA NEW YORK. NEW YORK 10278 AUG 2 91985 Mr. Roger B. Kowieski ,

C h'ai rm an Regional Assistance Committee U.S. Federal Emergency Management Agenc;r .

Region ",1 26 Federal Plaza New York, New York 10278 ,

Dear Mr. Kowieski:

We are in receipt of your memorandum of August 20, 1985 and r the Long Island Lighting Company's (LILCO) Revision 5 for l Shoreham'. Additionally, in April 3, 1985 you tr ansmitted a i memo summarizing the 8 elements which the Regional Assistance !

Committee (RAC) graded inadequate along with LIL.C0 responsas. . >

In all cases, the LILC0 responses contained in the April 3 1985 memo were made in Revision 5 for those alements for O- which EPA has responsibility.. Therefore, the plan itself appears adequate. However, tfur overriding concern is the l

status of support by New ' York State and Suf folk County to this plan and the legal ramifications thereto. It is still ,

unclear to us what the RAC's role and EPA's role should be vis a vis further plan review and any future exercises.

i memo that the Nuclear l We note in your August Regulatory Commisston (NRC20,)1985 requested RAC comments on Revision

5. I believe it is essential for the RAC to understand the NRC's policy vis a vis this plan and its status reg 6rding whether it meets NRC requirements in place of the traditional ,

Before ! can continue State and/or County planning effort.

to justify the expenditure of valuable Federal resources on !

reviewing this plan and critiquing future exercised, I would t

l- like to have a representative of the NRC state whether or not l

this can be considered the plan that will legally be able to -

satisf y the NRC's regulatory requirements for Shoreham if the l l

State continues not to participate in the effort.

5 i

I 2 i O .v. adv &>Kako,aa.g,,ga, a,y ,/n

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I would appreciate it i f the RAC meeting for September 11 or 12 could be the forum for such a policy statement by an authorized NRC representative. ,

Sincer(7y, z,,. [k 4 ? ,' ' ; ... l . - , ,

' PauF & Giardina Regl6'nal Raditation Representative -

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g. ,, g o 3 'IP ; Federal Emergency Management Agency L./ a* : New York, New York 10278

. ? Region 11 26 Federal Plaza

' .' .v -

. ., 0: Tv. -

F Mmorandum For: Charles Amato, NRC 6 kCI Herbert Fish, DOE

. Paul A. Giardina, EPA Rcnald E. Bernacki, FDA Paul Lutz, DCyr '

George E. Bickerton, CSDA Joseph H. Keller, INEL Thorns E. Baldwin, ANI Wh. har kp From: P cr K wleski, Chairman Regional Assistance Conrtittee

Subject:

Proposed Shoreham Exercise In a letter to FEMA dated November 12, 1985, Mr. William J. Dirks

o. t?. : T' re.g. .n.x t.:n TY. . , c.nd.:ct. ar. L.ercist cc.u.s: n with the approach outlined in Option 2 (see October 29, 1985 letter from Samuel W. Speck to William J. Dirks) .

f]

An exercise has teen tentatively scheduled for February 13, 1986. I will keep you apprised of the situation, and have attached for your infornation the tire-line which all parties must adhere to in order for the exercise to be conducted as scheduled.

In the near future you will ha receiving the proposed exercise objectives along with the utility concents for your review.

It is extrenely important that all exercise material is kept confidential to assure the creditability of this exercise. Please do not release any information pertaining to this exercisi. unless it is discussed with me and concurred by our agencies legal counsels.

Thank you again for your continued cooperation in this important matter.

Attachnent's 3

(V 790677

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1:

Federal Emergency Management Agency g

Region II 26 Federal Plaza New York, New York 10278

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. 2 DEC 1985 Mr. Charles A. Daverio Long Island Lighting Company 175 East Old Ccuntry Road Hicksville, New York 11801

i.

Subject:

Status and M,ilestones Relating to the Proposed Radiological Plan Exercise for Shoreham

Dear Mr. Daverio:

The purpose of this letter is to summarize our discussions and confirm the agreements reached at the November 25, 1985 meeting in New York City attended by:

t

'") Charles Daverio -

LILCO ln_C Brant Aidikoff -

LILCO/Aidikoff Assoc.

Raymond Seiter .

LILCO/Impell Charles Amato - NRC, Region I William Stokes -

TBA/ FEMA Edward Tanzman. -

Argonne National Laboratory Bernard Weiss - NRC, National Office Robert L. Acerno -

FEMA, Region II Stewart M. Glass -

, FEMA, Region II/OGC -

Spence W. Perry - FEMA, National /OGC Roger B. Kowieski - FEMA, Region II/RAC Chairman i

I. GENERAL DISCUSSION I =

i o The scenario is to be kept strictly confidential as it evolves, so that no exercise participants have access to it. The letter from John

! A. Weismantle, LILCO, to Roger Kowieski dated November 25, 1985 on this l

subject (dsitributed at the meeting) is to be folleved by another ons re-( flecting additional requirements suggested by Stewart Glass, Esq.

o The exercise is to be no earlier than February 13, 1985w LILCO will try to arrange for that date; the main problem is the Nassau Coliseum l

i

[

\ ') may not be available because setup for the upcoming boat show rdght inter-fere with the exercise. LILCO will get back to FEMA about this issue.

L . 790578

/%,

's 8 Page (2) d*) o The exercise will test Revision 5 of the LIICO Transition Plan; further revisions to reflect the RAC review of Revision 5 will not be made prior to the' exercise. -

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o The exercise will_take no more than one day, approxima%efy D*between 6:00*a.m'.~and 5:00 p.m.

,, II. EXERCISE OBJECTIVES-

' ~

On November 6, 1985, I submitted the proposed objectives to be demonstrated in the upcoming offsite exercise to Mr. Richard Krima of FEMA headquarters office. On November 21, 1985, the exercise objectives-were' forwarded to Mr. Edward Jordan of NRC. Consequently,-on November 22, 1985 a copy of Mr. Krimm's memorandum to Mr. Jordan and the proposed exercise objectives were transmitted to your office.

At our November 25, 1985 meeting, there was a brief discussion of the exercise objectives.

Some of the key agreements reached at this meeting were the following:

o No shift change will be demonstrated at the exercise. The ability-to maintain staffing in the LERO organization will be demonstrated by rosters, g o No actual traffic direction will take place at the exercise; traffic

_Q guides will be questioned by evaluators at TCP locations to determine the level of performance.

o It is acceptable to FEMA for the relocation center at the Nassau County Coliseum to be activated somewhat out of. sequence with the exercise scenario, provided that it is c.ctivated on the same day as the exercise, and in such a way that communicarions between the Coloseum and EOC can be demonstrated realistically.

o It is acceptable to FEMA for the medical drill to be performed out of sequence with the exercise scenario, provided that it takes place on the same day as the exercise. FEMA will accept a demonstration of either an onsite or an offsite injury, o It is acceptable _to FEMA that the Red Cross actually demonstrate its capability at no more than two locations.

o The objective which states that access control points must be demon -

strated, will be rewritten to reflect the fact that only traffic guidance is planned (as distinguished from control), provided that LIICO explains this in a letter to FEMA.

o LILCO will advise FEMA about the level of participation by various school districts.

It was agreed at this meeting that LIICO will advise FEMA in writing (around December 4, 1985) of suggested modifications to the exercise objectives, if any.

780579

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v III.

EXERCISE SCENARIO REQUIREMENTS At the November 25, 1985 meeting, FEMA provided LIICO witIl the specific instructions regarding the exercise scenario:

y-7 .

, A.

Proposed releaser wind directions for periods of radioactive' material lst direction - out ofR700, toward wsw (4%)

Radious Zones Affected - assuming 3 sectors Population 0-2 miles A,B small part of C 7,969 without C 11,415 with C 2-5 miles A,B,F, G 37,326 5-10 miles F,G,K,L,R,Q 87,561 2nd direction - out of 300, toward ESE (12%)

0-2 miles A,C,D,E 11,519 2-5 miles C,D,E,I,J 10,913 rw 5-10 I,J,0,P,S 12,975 B.

. Source Term and Meteorological Conditions.

FEMA requested that the exercise scenario produce the followin g:

o total intergraded dose between 4.0 to 5.5 miles in 1st wind direction will exceed 140% of PAG (/1.4 Rem whole body or 7 0 Rem thyroid). .

o No constraints on dose in 2nd wind direction except it will be "

measurable in the 2-3 mile area.

A note of clarification is required concerning the exercise dura tion j and the scenario requirements discussed during our November 25th g, meetin It is FEMA's stated objective ".... schedule as full an exercise i

Local Emergency Response Organization (LERO) plan as is feasible of the LILCO therefore, the discussion of scenario duration and scenario re quirements should not be construed as limiting the level of play on the LEROnsfunctio exercised.

intended as a guide, bassd on our previous experienceThe twelve .

longerscenario. exercise duration, FEMA could consider a greater i

exercise 1

780580

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Assistance Committee for review and comments , 19B5. LIIro by nal Decemb indicated that they will try to meet this date,

,, IV. j g _..

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PROPOSED MILESTONE DATES FOR THE COMPLETION O SCENARIO DAYS PRIOR PROPOSED TO DATE ACTIVITY EXERCISE 80 11/25/85 FEMA provides the utility with the proposed exercise objectives.

80 11/25/85 Meeting with the utility to establish the exercise scenario requirements.

_/ 71 12/4/85 Utility will advise FEMA in writing about suggested modification to the exercise objectives, if any.

69 12/6/85 Utility submits the draft exercise scenario to FEMA and NRC Region for review.

This submission will include the on-site (radiological data) and off-site portions of the exercise , .

scenario. ,

69 12/6/85 Proposed exercise objecti es and utility comments / modifications are submitted to the Regional Assistance.

Committee for review and cocnents.

62 12/13/85 f'~

Taking into account the utility input and RAC comments, FEMA will provide the V utility with the revised exercise objectives.

In addition, FEMA provides LERO with a list of items to be demonstrated (e.g. , number of 'ICPs, 790581 evacuation routes, etc.) .

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'f j' x.s DAYS PRIOR PROPOSED. ACTIVITY -. -

TO DATE -

EXERCISE

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', ,' 57 12/18/85 Utility submits the final exercise

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objectives to FEMA and NRC Regional office.

55 12/20/85 RAC comments on the exercise scenario are provided to the utility. If necessary, FEMA and NRC Region will meet with the utility representatives to discuss modifications necessary to complete the scenario.

41 1/3/65 Utility submits the final exercise scenario which will include, at a minimum:

{( )- o a comprehensive description of all activities to'be demonstrated, consistent with exercise objec-

.tives; o a full schedule of all events at each classification level (matrix);

o dosimetry values to be supplied to the field monitoring and sampling teams by exercise controllers;

. . .- + . ~- - :- ~ *** '

o calculation of all offsite doses, including those that trigger pro-tective responses, and applicable meteorological data.

38 1/6/86 Utility submits the starting locations and times of field activities to be demonstrated in chronological order.

. The locations of all facilities and '

field, activities will be also indicated on the county maps.

O)

\ ',

35 1/9/86 Final date for the approval of the exercise scenario and field activities.

W o rs e n

. 4 O %! %i Q

I

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Page (6)-

') %

DAYS PRIOR PROPOSED TO ACTIVITY DATE

.n- -EXERCISE. 4 k"

- 15 1/29/86 Table-top exercise. ~

0 2/13/86 EXERCISE DAY.

in the timetable, late submission of the acceptable exercise scenario material may lead to postponing the exercise.

Since FEMA is already committed to evaluate a number of exercises in the first quarter of 1986, even a one week delay in submission of the exercise material, may require the postponement of the exercise for 30 days or more .

If you have any questions with regard to information contained in this letter, please contact me at your earliest convenience.

Sincerely, CDs,y g. ,

<aha Roger B. Kowieski, P.E.

Chairman Regional Assistance Committee l

l i

O l

790583

,4 50 / A.

' A. -

g A.RG0NNE NATIONAL l

(' LAB'ORAT0RY

~: - . .

INTRA-LABORATORY MEMO 4

~

November 26,1985

^~ .

R. Kowieski, PEMA Region !!

TO:

FROM: E. Tanzman, ANL 'f'l Meeting with LILCO Concerning

SUBJECT:

Agreements Reached at November 25,1985 Shoreham Exercise Per your request yesterday afternoon, this memorandum collects and sum my understanding of the commitments made by Charles Daverlo on beha Lighting Company (LILCO), and by yourself on behalf of FEMA, at the mee ,

yesterday at FEMA Region II to plan for the proposed exerc i

n Power Station.

) U the proposed scenario at the time of this meeting, I suggest that you review carefully to assure that I did not misunderstand the context in which various state were made (and, hence, the substance of the commitments).

I. COMMITMENTS BY LILCO A. The scenario is to be kept strictly confidential as it evolves so that no exe i participants November 25, 1985 have access to it. The letter from John A. Weism another reflecting additional requirements suggested by Stuart Glass, Esq.

l 13, 1985. LlLCO is to try to B. The exercise is to be no earlier than February l

I r

arrange foe that date; the only problem is that the Nas LILCO will get back to you about this.

C. The exercise will be of Revision 5 of the LILCO Transition Plan; further i revisions to reflect the RAC review of Revision 5 will not be made.

D. The exercise will take no more than one day, with the starting time no earlie i 00 P.M.

I . than 6:00 A.M. and the termination no later than 5:

E. Exercise participants will be told no more than the date of the' exercise.

O (C 780584

v . . . _

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l' 50/-3 R. Kowleski 2

~

. F. The " Proposed Wind Directions for Periods of Radioactive Material Release" which you submitted to LILCO is acceptable and will be used as the basis for a scenario.

As much of this as possible (perhaps the entire scenario) will be submitted by December

~ # 1985. Stokes; Weiss, Amato, Keller, and you each are to receiva Ocopy of that submission; those sent to NRC are to comply with legal requirements enabling them to be

compt from filing in the Public Document Room (probably including malling in a double envelope with " PROPRIETARY" stamped on the outside).

G. No shift change will be demonstrated at the exercise.

H. No actual traffic direction will take place at the exercise; traffic guides will be questioned by evaluators at their locations to determine the level of performance.

I. LILCO will provide assistance based on its knowledge and experience concerning how to assure that the exercise and its observation are in complete compliance with all applicable laws. In particular, this is to include a list of traffic control points at which it could be illegal for an observer to park, exit his or her vehicle, and question a traffic guide positioned there.

i J. LILCO will respond to your suggestion that it write each school district and request that it participate in the exercise.

l K. LILCO will permit Stokes and Weiss to attend the drill scheduled for December i

j O s-4,185, and wiil permit veu to attend future eriils c .g., the eress rehearsal" i-January 1986).

% !!. -COMMITMENTS BY FEMA A. You will send LILCO a letter with a revised " time line," i.e., milestone sebedule leading up to the exercise.

B. You will send a formalletter with the proposed scenario parameters (i.e., wind and radiation) as presented informally at the ineeting.

C. It is acceptable to FEMA for the relocation center at the Nassau Colosseum to be activated somewhat out of sync with the exercise scenario, provided that it is activated on the same day as the exercise and in such a way that communications with the Colosseum can be demonstrated realistically.

D. It is acceptable to FEMA for the medical drill to be performed out of sync with the exercise scenario, provided that it takes place on the same day as the exercise.

FEMA will accept a demonstration of either an onsite or an offsite injury.

E. It is acceptable to FEM'A that the Red Cross actually demonst' rate its

, capability at no more than one or two locations.

F. It is acceptable to FEMA that the EBS station (s) not air exercise messages, provided that the exercise messages all are draf ted as planned and a test message is O alred. The objective on p.11 of the " Proposed Exercise Objectives for the 1986 Shoreham Exercise" (dated November 6,1985), whien states that the Emergency News Center must demonstrate its ability to draft EBS messages, will be rewritten to reflect g(- the fact that EBS messages are drafted in the EOC, provided that LILCO explains this in a letter to FEMA.

790585

j .

n.,

R. Kowleski . 3 50 /- Y G. The objective on p. 4 of the " Proposed Exercise Objectives for the 1986 Shoreham Exercise (dated November 6,1985), which states that access control points must be demonstrated, will be rewritten to reflect the fact that only traffic guidance is

, pranned (as distinguished from control), provided that LILCO explains this4n a letter to FEMA. -

H. The objective on p. 4 of the " Proposed Exercise Objectives for the 1986 Shoreham Exercise (dated November 8,1985), which states that a demonstration must be made that the permanent population has received information about the plan, will not be demonstrated, provided that LILCO gives a good reason why in a letter to FEMA, and provided that the remainder of the public alerting system (strens, EBS, and route alerting) is' demonstrated as planned.

1. Although the exercise will demonstrate revision 5 of the plan, it is acceptable to FEMA for LILCO to clarify it at the observer training session whfeh will precede the exercise. ,

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f; i . . .a NOV 2 01985 n Mr. Richard W. Krism

) Assistant Associate Director Federal Emergency Management Agency (C500C . Street, S.W.

, Washington, D. C. 20472

.. 'n-Dear fickr '

N' .

The upcoming exercise involving the Shoreham Nuclear Power Station has differences which will alter some of the normal communication paths necessary to plan for and'c~onduct such an exercise. We would expect that the manner of communicating with LILC0 regarding the onsite portion of the exercise would continue as described in the NRC/ FEMA Memorandum of Understanding and GM-17.

The principal difference in the upcoming exercise is that the planning and conduct will be performed by utility personnel instead of state and local personnel. Therefore, we agree that FEMA may communicate directly with LILCO on matters related to planning and conduct of the LERO plan exercise. ,

For coordination purposes we request that the NRC Regional I office be kept informed of these communications on a weekly basis.

Sincerely, e n

V Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement cc: T. Martin, RI Distribution: .

l DCS.

DEPER R/F JM'aylor RHVol1mer JGPartiow BKGrimes SASchwartz .

DBMatthews KEPerkins RLBaer

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NUCLEAR REGULATORY COMMISSION

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WASHWGTON, D. C. 20666 c

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NOV 2 01985 2 . _ .

~

Mr. Richard W. Krime Assistant Associate Director Federal Emergency Management Agency 500 C. Street, S.W. -

Washington, D. C. 20472

Dear Dick:

I

- The upcoming exercise involving the Shoreham Nuclear Power Station has differences Which will alter some of the normal communication paths necessary to plan for and conduct such an exercise. We would expect that the nanner of communicating with LILCO regarding the onsite portion of the exercise sould continue as described in the HRC/ FEMA Memorandum of Understanding and GM-17.

l l As discussed with Robert Wilkerson of your staff, the pr< ncipal difference in I (]~ the upcorning exercise is that the planning and conduct of the offsite portion of the exercise will be performed by utility personnel instead of state and local personnel. Therefore, we agree that FEMA may commnnicate directly with LILCO on matters related to planning and conduct of the I.ERO plan exercise.

For coordination purposes we request that the NRC Regional I office be kept informed of these communications on a weekly basis.

Sincerely, I

s:( /

p.g/ / -

ar C Dordan, Director Preparedness l

Divisio)QineeringRes)of and Ed ponseEmergency-Office of Inspection and Enforcement cc. T. Martin, R1 -

1

.i b 790588

. =

i Federal Emergency Management Agency

( [ Washington, D.C. 20472 -

. , #*~

~ ~ '

hW 21 1985 -

MEMORANDLM EOR: Roger B. Kowieski 01 airman, Regional Assistance Ccrumittee FEMA Region II (New York)

FIUi:

Assistant Associate Director Office of Natural and Technological Hazards Prograns

SUBJECT:

Authorization For Meetings With LIICO

'Ihe attached mmorandum fran the Nuclear Regulatory Ccrumission (NRC)'

provides written authorization for you ard the senior controller for the Shorehan exercise ('Iheodore Barry Associates) to inld neetirgs, as appropriate, with representatims of the Iong Island Lighting Cmpany (LIICO), in preparation for an exercise of the LIICO offsite prepared-ness plan for Storehan. 'Ihis is written confirmation of the auttoriza-tion which ms provided to you orally by Edward L. Jordan of NRC's

. Office of Inspection and Enforcement, on Novenber 19, 1985.

If you have any questions, please feel free to contact me at 646-2872 or R2ert S. Wilkerson at 646-2859.

Attachment ,

9 e

4 U

l L 790583

. . .. . .. . . . .. .= .-. .. -.

~

Federal Emergency Management Agency ,

Washington, D.C. 20472 Nov 21 585 - NOV ?

, , , 4a-MIMCRANDQi POR' Edward L. Jordan -

, Director, Division of Emergency Preparedness and

.e Engineering Pospense 4 '

, , Office of Inspection and Enforcement Nuclear hegulatoy ission wh/

FKM it T W .' K U m m Assistant Associate Director Office Natural and Technolcgical Hazards Programs SGk7EI'r Transmittal of Objectives For Shoreham Exercise his is to transmit proposed objectives for an exercise of the tong Island Lighting Cogany (LIICO) Transition Plan for offsite preparedness at the Shorehan Nuclear Power Station in Suffolk County, New York. The

objectives were generated by the Regional Assistance Counittee Chairnan in Federal Dnergency Managernent Agency (FEMA) Region II.

Marked by an asterisk, for your infornation, are the objectives which are l relata$, in our view, to the legal authority issue ard State and local i

participation. Please transmit this information to,the appropriate

- LItCo representatives, ~in preparation for the first'meetirg with the

~

utility on the exercise process., This is now scheduled to take place on Monday, November 25, 1985 At the meetirg, we plan to discuss the troposed objectives, as a basis for the requir'ements for the exercise scenario. .

In order to provide nere realism to the Shorehan exercise, we wmld like t

to see .a considerable arnount of free play activities incitding the i following:

' Activation of traffic control points (TCP). Federal evaluators will provide the Exercise controller information on t w location of traffic control points to be demonstrated during the exercise.

The Exercise Controller will then request the denonstration of the TCP activation.

'Igediments to Evacuation. Federal evaluators will intrt@ce free play events to test proceduree for the removal of imedinents

. fran evacuation routes. The devonstration will include the actual dispatch of an emergency vehicle to the scene, report .

fran the scene to the ECC requestirg appegriate resourose, ECC

. requesting apporpriate resources.(e.g., tow trucks, gasoline trucks, etc.), estimating the time of arrival at the scene and for clearirg the impediment. EOC staff will be expected to quickly analyse the situation ard select an alternate evacuation route, if requirsd.

O In addition, an appropriate IBS nessage should be issued to inform the public abo 2t the impedient (s).

l 780500 l

~ . - -- . . . - - ._

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' Bus Evacuation Foutes.1%deral evaluators will indicate which bus route's are to be dertonstrated during the exercise. Upon notifica-

~

~

tion by LI!ro's tocal Dnergency Response organization (LERO), bus -

,a drivers will assenble at their dispatch location, be assigned

, ~ appropriate toutes, be briefed and deployed in accordance with

. the appropriate procedures. Upon ccenpletion of the routes at the transfer points, the buses and drivers will then stoceed to reception centers. The bus mutes selected for denenstration on the day of the exercise will inclu:le school evacuation routes.

StWents will not be moved for purposes of this denenstration.

' Evacuation of Non-Institutionalized mbility-Inpaired Pecple. '

Federal evaluators will select several addresses of mobility-impaired persons within the 10-mile EP2 A vehicle for the <

transpartation of the handicapped will be dispatched to these

-addresses for simulated evacuation. No handicapped evacuees will be picked up for purposes of this denenstration.

Evacuation of Institutionalized Mbility-Inpaired Pe@le.

Federal evaluators will select at least one special facility

, with mobility-impaired persons within the 10-mile EP2 A vehicle I

for the transportation of handicapped will be dispatched to this

' special facility. N3 handicapped evacuees will be noved for purposes of this demonstration.

! {k

Back-up Notification Systen. Federal evaluators will introduce free play, simulating a limited failure of the siren systan'. It -

is expected that IZRO will demonstrate an effective use of the l

back-up notification system (e.g., route alerting).

l' We would like to enphasize the need to proiide us with starting locations i

and tims of all field activities to be denonstrated, in chronological order. A sanple foon to record this infonnation will be provided. This is important since FEMA will be evaluating the exercise against this timetable. 'Ihe locations of all field activities inc1 Ming an address directory (except free play) should also be indicated on county maps, with an appecpriate legend.

I hope that the enciceed objectives will expedite LIIco's planning . efforts for the anticipated exercise.

It should be stressed to the utility that all exercise scenario material '

i

, nust be kept confidential. .

If you have' any questions concernirg this material, please do not hesitate to contact ne at 646-2872 or kbert S. Wilkerson at 646-2859 i

i O Attachnent i

l As Stated i( 790591 1

f. .

f . ,. ....,/g UNITED STATES

[

?,

)t . NUCLEAR REGULATORY COMMISSION i

,. % .. ,, :f WASHINoToN, D. C. 2o65s j

%,7,.' NOV 121985

~

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, 4W

~

I !. -

~ Mr. Samuel W. Speck

.' Associate Director .

' State and Local Programs and Support -

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

I* :

Dear Mr. Speck:

i This responds to your letter of October 29, 1985, propojsing two opNions for an exercise to test onsite and offsite emergency preparedness capabilities at Shoreham. c We conclude that an exercise should be condu'ted consistent with:the' approach outlined in your Option 2.

You asked in the letter for further clarification from ,the NRC as to the scope of the exercise to be conducted. As stated in our me'morandum to you of June 20, 1985, we requested that you schedule as full an exercis'e of the LILCO Local Emergency Response Organization plan as is feasible. Op' tion 2 would include all functions and normal exercise objectives, recognizing that some offsite response roles may be simulated. We believe that such an exerciise would be 'useful in the licensing process for Shoreham. Please let me know if 'we can be of further assistance. !

Sincerely, Y

)M lliam J. Dirc;ks ' n (gyecutive Direc' tor for Operations I

l l

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l pd 1

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790532 1

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. _ _ _ . _ _-_. - _.. _ _ _ _ i

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ed 44

(-) 1

/Y.T M67 + Emergenc'y Management Agency Federal yg -

,. Region II 26 Federal Plaza New York, New York 10278 g% ' " . v 0 se ,r.:

~

Memorandum For: Richard W. Krimn ,

. Assistant Associate Director State & Ircal ams & Supprt

~ W~ ofV*v. 7 ok 7 GIM > b~

Fran: er B. Kowieski, Chairman

Regional Assistance Ccmnittee i

Subject:

Scheduling of REP Exercise for Shoreham i

This is in response to a nutorandum dated Novenber 1,1985, fran Samuel W. Speck to Frank P. Petrone in which FDR, Region II was requested to develop the exercise cbjectives for the following two i

, (2) options:

Cption 1 - This option would require that we set aside all functions and exercise objectives related to issues of authority and State end local participation. Thus, q only the functions outlined for LIICO would be exercised.

j V Option 2 - This option muld include all functions and

! nomal exercise objectives. This option would exercise i Pavision 5 of the IERO Plan. ERercise controllers would sinulate the roles of key State or local officials unable i or unwilling to participate.

These tm'(2) options 9.ere presented to NRC on October 29, 1985.

In respnse to Mr. Speck's request, we have developed the exercise objectives for both options. Exercise objectives related to issues of authority and State and local participation are marked with an asterisk and must be deleted when Option 1 is chosen (copy attached) .

The proposed objectives have been developed to generally correspond to the observable elements of NUREG-0654, EEG-REP-1, Pev.1.

In order to add nore realism to the Shoreham exercise, we would like to sec, considerable free play of activities including (provided Option 2 is selected):

Traffic Control Points ('ICPs) .

Federal evaluators will provide the Exercise Controller information on the location of traffic control points to b3 damnstrated during the course of the exercise. The Exercise Controller will then request the demnstration' ~ ,

cf the 'ICP activation.

790503 l

cj g ,.t ', .

p. .

2 --

Impadients to Evacuatimi

-u. . i._

~ Federal evalt$atois will intrrrhvw free play events to test phv=dures for removal of ittradimants frm evacuation routes. The demonstratica

will include the actual dispatch of an emergency vehicle to the scene,-

c report frm the scene to the EOC regesting a;prcpriate recources, IDC -

requesting awwriate resources, (e.g. tow truck, gasoline trucks, . 1 L

i etc.) estimating the time of arrival at the scene and for clearing the inpadiment. EDC staff will be expected to quickly analyze the situaticm' l l and select an alternate evacuation route, if required. -In addition, an '

appropriate EBS message should be issued to inform the p'pnlation about the impediment (s) .

!i -

1

Bus Evacuation Routes ;

Federal evaluators will indicate which bus routes are to be demmstrated during the exercise.' Upon notification by IERO, the bus drivers will ;

i-

' assemble at their dispatch location, be assigned appropriate routes, !

p briefed and deployed in accordance with the appropriate procedures.

Upon ampletion of the routes at the transfer points, the h- and

-drivers will then proceed to reception centers. 'Ihe bus routes s

selected for denenstration on the day of the exercise will include ,

j school evacuation routes. Students will not be noved for purposes

[ of this demonstration. '

l Evacuation of Non-Instituticnalized M,hi1ity-Inpaired Federal evaluators will select several, addresses of nobility-inpaired persons within 10-mile EPZ. A vehicle for the tra w.rtation of the handicapped will be dispatched to these addresses for sinulated evacuation. No handicapped evacuees will be picked up for purposes of this dmonstration. i Evacuation of Institutionalized Ptabi,lity-Inpaired Federal evaluators will select at least one si,acial facility with mobility-impaired persons within 10-mile EPZ. A vehicle for the

--transportaticn of the handicapped will be dispatched to this special

' facility. No handicapped evacuees will be picked up for purposes of this dmonstration. .

O .

s 790594 t

i

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.es Is:ss rtm - rco cm 2

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.J t , Federal Emergency Management!Mg~ency

"k' 5

Washington, D.C. 2002 ~

M985 NOV -

t MDOPANDtM POR: Frark Petrone Pcgional Director FD3.A Pegion II FPCMt Sa w .

ci t or .

S e ,

1 Prcgra:m a

SUBJECT Sch irg of Diervancy Plan Exercise For Shoreham You havo, of ccurso, received a ecpy of my October 29, 1985, letter to Mr. William Dircks of the tGC.

l cotions is still uncertain. In addition NRC's decision to the to oncthe Shoreham exercise letter, NRC could choose to have no exercise at all. ptions stated in the we are cardtted As you can also see, November 15, 1985 to contiruirg cur edministrative grocess until of exercise c6jectives These foractions toth of would reasonably the cptions in theirclude October the development 29, 1985 revio.i of the exercise scenario. letter to Mr. Dircks, ard the nornal turirg the staff discussions on-october 24 in your office, the resource neais identified were: implications of the preliminary work wre cutlined a .

assistant to the Pagional Assistance ccmmittee (PAC) Ota exclusively with Shorehrn requironents; and 2) contirued clerical s Headquarters staff have already discussed the assistant for the PAC Q .

with Argonner Office in Garden City. that resource is available on request fran 1airran the Argon e

the RAC review p ocess. Argonhe is already providirn additional suppet to Directorate to fill the existirgisclerical also vacancyaggressively in REP. pursuirc the exenption ou to all reet to providethe clerical requironent the necessary support. for this exercise, Argonne has been alerted to I would hcoe that esecy effort would be rmde to supply LILCO and the

! s exerciuo Hovember for both cptions9,1985 control on Novenber contractor ard have

15. on handwiththe therecpccod ob$ectivos scenario for atxibothsupp co l

J raterials

! As a final note, the office of the ActingeDirector requirem nt has l

This was dona to facilitate the precess of working on nportant this i esite.

work. 79 0 5

l OCT.29 '85 21:25 FD% t$rSH FED CTR 3 P.03

$ t Federal Emergency Management Agency Washington, D.C. 2002 October 29, l98$ t

%. William J. Dircks Executive Director for Operations

'U.S. Nuclear Regulatory Camission Washirston, D.C. 20555

Dear Mr. Dircks:

his is in response to a menorandum dated June 20, 1985, fr a Edward L. Jordan to Richard W. Krima in Wich FDE We requested to pro-coed with the contet cf "as full an exercise......as is feasible to test offsite preparedness capabilities at the Shoreham Ntclear Power Plant."

In my October 8,1985 letter,which transmitted the review of revision 5 of the LIICD Iocal Energency Response Organization (IZRO) plan, I indicated we were analyzing Septenber 17, 1985 the results cf the plan review in the context of the letter from Chairnan Palladino to Congressman Markey, and the varicus legal proceedirgs related to shoreham in order to respond to the June 20 menorandum within several weeks. . Our analysis includes consideration October 18, 1985. d the Atanic safety and Licensing Appeal Board decision d

\ De deficiencies identified in my letter cf October 8 do not preclude the conduct cf an exercise of the IERO plan. However, the reluctance of county and State cf ficials to participate in stch an exercise and the related legal authority issues would place special paranaters on the con @ct of a LEM exercise.

We have no indication at this tine that cffaite jurisdictions are willing to directly participate in an exercisie in the short term. Thus, any exercise will be dramatically different than is typical at other sites in the State of New York. Any exercise without participation by State and local g:rverments would not allcw us sufficient denenstration to reacit a finding of reasonable assurance.

This conclusion is w on the current legal decision with respect to utility autterity to perfom civil energenqr functions. However, that does not preclude the con &ct of an exercies that would provide an indication to the Ezclear Angulatory Cennission (NBC) as to utility onsite and offsita energency capabilities. We believe such a report would have value in decisions to contirue the licensing process or.possibly provide a basis on which the NRC could make predictive findings . Obvicualy, the value of su:h an exercise in the licensing peccess is a determination which can only be made by the NRC. ,

Given the nature cf your June 20 request and consideration of a practical structure for an exercise, we feel that, Wiile there are a nutter of variations possible, the basic cptions for exercising in the near term O '" """ "" -

s Option 1 - his cpticm would require that we aside all 79053G functicris and exercise objectives related to issues of authority and State and local participation. mus, only the functions outlined for LI!ro would be exercised. Such

j.,ocT.29'8521:26 fem t#5H FED CTR 3 P.04 2

an exercise is pessible but its usefulness would sean very limited.

An exercise cf this type would not address 4 a --

. questions such as those raised on pages 35 through 39 of

- the October 18 decision cf the Atcmic Safety and Licenairg

- " Appeal by NRC. Board and would be redundant to actions already taken Optien 2 - Tnis cption would include all functions and nonnal exercise objectives. 'Ihis cption would exercise Revision 5 of the LEBO Plan.

Exercise controllers w:uld simulate the roles of key State or local officials tnable or unwilling to participate.

governnent parsonnelIt would be desirable actually that State and local play. However, such a sinu-lation nachanism would at least test the utility's ability to respond local to ad hoc participation on the part of State and goverments.

'The ultimate purpose cf an exercise is tas support a finding by FDiA for use by the NRC in their licensing process. As we nentioned above, neither of these cptions w:uld allcw a fiMirg by FP.A on cffaite preparedness.

However, we racconize that Storeham is in no way typical ard that in the past in exercisirg its adjudicatory towers the Commission and the varia2s Atcmic Safety and Licensing Boar & have teached predictive findings.

Pursuant to your June 20 request, we are initiatire the process necessary to conduct an exercise of either eption. He are prepared to conduct such an exercise in approximately 75 days. However, FD4A requires further clarification frcm NRC as to the scope of the exercise to be conducted.

PD4A will proceed with the initiatirg steps until Mavember 15, at which time we will costs.

pechibitive need a definitive exercise accpe frcm NRC in order to avoid If at that time we have received no direction frcm the Nuclear Regulatory Ccmission we will suspeM activities until a decision is made.

the current windcw would require an exercise postponetent of at days beyond the mid-canJary time fraus.

Sinoneely, uJ.jA y-.W 1 W. Speck eaciate Director State and Iocal Programs ard Sappart

' ' GMRdl/vi4 B5c *3 Federal Emergency Management Agency

(

!m Region II . 26 Federal Plaza New York, New York 10278 Menorandum For: Charles Amato, NRC 6 ote b5 Herbert Fish, DOE Paul A. Giardina, EPA Ronald E. Bernacki, FDA Paul Lutz, DOT George E. Bickerton, USDA Joseph H. Keller, INEL E. Baldwin . ; Z' E. 4 (GJ/W Frcm: Roge B. Fw ieski Chairman Regional Assistance Ccmnittee

Subject:

Proposed Exercise Objectives for Shoreham As referenced in my December 4th nenorandum to you, enclosed find the proposed Exercise Objectives for Shoreham with the utility cuments.

Please review the docurents and subnit your findings to ne by December 11, 1985. If I do not receive your conments fb that date, I will assunn that you concur with the proposed objectives.

Thank you for your continued cooperation in reviewing Shoreham material.

Encl.

cc: Edward Tanzman William Stokes l

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[./44"O/MfGM//AGF/M LONG ISLAND LIGHTING COM PANY 17 5 EAST OLO COUNTRY ROAD

H IC K SVI LLE, NEW YORK 18801 Direct Dial Number December 5,1985 Federal Emergency Management Agency Region II 26 Federal Plaza New York, New York 10278 ATTENTION: Mr. Roger Kowieski

SUBJECT:

Shorenam Nuclear Power Station Local Emergency Management Agency Proposed Exercise Objectives for tne 1986 Shoreham Exercise

REFERENCE:

LILC0/ FEMA Meeting on November 25, 1985 Gentlemen:

O Pursuant to the referenced meeting, we have enclosed your Proposed Exercise Objectives for the 1986 Shoreham Exercise, witn our comments footnoted at the bottom of each page. Where additional space was needed, separate pages were inserted between pages of tne document. These separate pages are not numbered.

Witnin tne proposed objectives and our subsequent comments, there are a number of items which I would like to bring to your attention.

First, is the subject of Access Control [Ref: pg. 3 of 12, fn. (1); pg.

4 of 12, fn. (2); pg. 5 of 12, fn. (1)]. Here, I would like to point out tnat LERO treats access control to evacuated areas as a subset of traffic control. Access control is provided at traffic control points located on

, zone boundaries by Traffic Guides performing their traffic control i duties. It should be noted that the same constraints on traffic control, related to the issue of legal authority, apply to access. control.

Second, security functions at LER0 emergency facilities .are provided by LERO personnel and are therefore, not related to legal authority.

Third, on page 6 of 12, we have deleted the last two objectives which are related to tne demonstration of emergency medical facilities for the j handling of injured and contaminated individuals. These objectives are being deleted because tne volunteer ambulance company and hospital have expressed a preference for a weekend drill.

73196Ti 1

Federal Emergency Management Agency Region II December 5,1985 Page Two As an alternative, we would like to suggest that FEMA attend the next scheduled Emergency Medical Drill, and that these objectives be evaluated out of sequence with the Graded Exercise.

I think that you will find the remainder of our conar.ents to be self explanatory. If I can be of further assistance or should you have any questions concerning the exercise, please do not hesitate to contact me at (516) 420-6211.

Very truly yours,

[ & '. / A-Charles A. Daverio Manager, Emergency Preparedness Division CAD /DMB/cjc O

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PROPOSED EXERCISE OBJECTIVES for the 1986 SHOREHAM EXERCISE November 6, 1985 l

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November 6, 1985 J

PROPOSED EXERCISE OBJECTIVES FOR THE 1986 SHOREHAM EXERCISE Emergency Operations Center (EOC) i Demonstrate the ability to receive initial and follow-up emergency notifications.

Demons the trate the ability to mobilize staff and activate Local Emergency Response Organization (LERO) .EOC in a timely manner. ,

Demonstrate'through ros ters, the ability to maintain staffing in the LERO EOC on a 24-hour basis.

Demonstrate that the LERO EOC has adequate space,-

equipment, .and supplies to support emergency operations.

Demonstrate that the LERO can establish appropriate communication links., both primary and backup systems

( communication with the State and county via RECS to be simulated).

O X oemon te te ta t the t=ao soc was deeoate access

~

L control and that security can be maintained.

Demonstrate that messages are transmitted in an accurate and timely manner, messages are properly I logged, that status boards are accurately maintained and updated, that appropriate briefings are held, and that incoming personnel are briefed.

Demonstrate that the appropriate official. is in charge and in c'ontrol of an.overall coordinated response including decisions on protective action recommendations.

I (1) Insert objective.

'

Note: Exercise objective related to issue of legal authority and State and local participation. This objective to be set aside when Option 1 is selected for exercising of the LERO plan (see Mr. Speck's l letter to Mr. Dirks of NRC dated October 29, 1985).

(1) Insert the following objective:

Demonstrate the ability to coordinate the emergency response with simu-Q lated county or State officials should they decide to participate on an ad-hoc basis. (Role of State and/or county official to be simulated by FEMA designated personnel.)

! 7313G8

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i Novsmbar 6, 1985-PROPOSED EXERCISE OBJECTIVES FOR j THE 1986 SHOREHAM EXERCISE _.

Emergency Operations Center - Continued 1

(1)[ Demonstrate the ability of the designated official to determine the need for and ability to obtain ; State assistance.

D emo n s t rate the ability to communicate with all appropriate locations, organizations, and field' personnel.

Demonstrate the ability to receive and interpret r adia tion dosage projection information, and to determine appropriate protective measures, based on PAGs (BAO).

Office and inf ormation received from the Brookhaven A ea Demons trate the ability to provide advance coordination of public alerting and instructional messages with thu S tate and county (State and county participation' simulated). ~

O (2)

Demonstrate the ability to activate the premlat. -

notification siren sys tem in coordination with St. ate:<

and county (State and county participation simulated).

(E) Demonstrate the capability for providing both an al+ art signali and an informational or instructional message to the population on an area wide basis throughout the 10 mile EPZ, within 15 minutes.

Demonstrate the organizational ability to manage an orderly evacuation of all or part of the 10-mile EPZ.

Note: Exercise objective related to issue of legal authority and Sta te and local participation. This objective to be set aside when Option 1 is selected for exercising of the LERO plan (see Mr. Speck's letter to Mr. Dirks of NRC dated October 29, 1985).

(1) This objective will be satisfied via discussions between the Direc-tor of Local Response and FEMA Evaluator concerning the need and procedures for requesting assistance from the State of New York or, other appropriate organization.

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f(2) The siren s.ystem will..be activated in coordini}tfon with the

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'i 3 simulated issuance of 4n EBS, message. Local radio stations i will,jroadcast an explanation of:the siren test with no

. b[pr ha reference to protective action r6co,amendations,.

The actual oemonstration of this objective is still being considered.

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,; ; PROPOSED EXERCISE OBJECTIVES FOR THE 1986 SHOREBAM EXERCISE ,y 1

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Emergency Operations _ Center - Continu d ' 1 Demonstrate the organizational ability to deal with' !

' ' I' impediments to evacuation, such as inclement weather or traffic obstructions.

Demonstrate the organi za tional ability ~necessary to-ef f ect an early dismissal of schools within the 10-mile EPZ.

f (1)

Demonstrate the control access to an evacuated area.organi za tional ability necessary to

, _]* (2)

Demonstrate the

- effect an orderly organi zational ability -necessary to evacuation of schools within the 10-mile EP3. If this. protective action is not -

recommended by the decision-makers, e.g. schools were dismissed early, a free play controllers message may be inserted to demonstrate this activity.

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Note:

Exercise objective related to issue of legal autnority and objective to S ta te and local participation. This for exercising be of set theaside LERO when Option 1 is selected letter to Mr. Dirks of NRC dated Octoberplan (see Mr.1985).

29, Speck's (1) LER0 Traffic Guides will control access to evacuated areas.in accordance with OPIP 3.6.3.

people not to enter the area. Traffic Guides can only advise I

(2) Schools will be notified during the exercise via tone alert radios and simulated phone calls from the Public and Private Schools Coordinators as set forth in the OPIPs. As we discussed at our meeting, it is not expected that any school district will parti-cipate in an exercise except the Shoreham/ Wading School District.

The activation of the tone alert radios is still being reviewed.

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Paga 4-of 12 November 6, 1985 PROPOSED. EXERCISE OBJECTIVES FOR

, THE 1986 SHOREHAM EXERCISE Field Activities

,J '

."'- Demonstrate the ability to continuously monitor and control emergency worker exposure including proper use l

of personnel dosimetry.

A

," Demonstrate the ability to mobilize and deploy field L.

monitoring teams in a timely. manner.

'8 Demonstrate appropriate equipment and procedures for determining ambient radiation levels.

1 Demonstrate ~ appropriate equipment and procedures for

'8 measurement of airborne radiciodine concentrations as 3

low as 0.1 picocurries/cc in the presence of noble gases.

o 88 *

~' Demonstrate the ability to provide backup public alerting, if necessary, in the event of partial siren

, system failure.

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I Demonstrate that the permanent population has received inf ormation on how they will be notified and what their

" actions should be in the event of a radiological

' emergency and that this information is updated on an L

annual basis.

Demonstrate that information on emergency actions has been provided to transiest populations.

c- ( 1)

Demonstrate that access control points can be

>' established in a timely manner.

C 3

Demonstrate the ability to supply and administer KI, jC once the decision has been made to do so, i :

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Note: Exercise objective related to issue of legal

. authority and S ta te and local participation. This objective to be set aside when Option 1 is selected for exercising of the LERO plan (see Mr. Speck's i letter to Mr. Dirks of NRC dated October 29, 1985).

(1) Access control points are Traffic Control Points manned oy Traffic Guides, along sector boundaries.

731972 L

Paga 5 of 12 November 6, 1985 h PROPOSED EXERCISE OBJECTIVES FOR THE 1986 SHOREHAM EXERCISE Field Activities - Continued Demonstrate that emergency workers understand who can authorize excess exposure under the Protective Action Guidelines.

Demonstrate a s a'mp l e of resources necessary to~-

implement an orderly evacuation of all or part of the 10-mile EPZ.

Demonstrate a sample of resources necessary to deal with impediments to evacuation, such as inclement ~

weather or traffic obstructions.

(1)

Demons tra te .a sample of resour.ges necessary to control access to an evacuated area.

Demonstrate the adequacy of evacuation bus transfer points including access and parking / transfer areas.

Ox Demonstrate a sample of resources necessary to effect an orderly evacuation of the institutionalized mobility-impaired individuals within the 10-mile EPZ.

Demonstrate a sample of resources necessary to effect an orderly evacuation of the n o n-in s titutionali zed mobility-impaired individuals within the 10-mile EPZ.

Note: Exercise objective related to issue of legal authority and State and local participation. This objective to be set aside when Option 1 is selected for exercising of the LERO plan (see Mr. Speck's letter to Mr. Dirks of NRC dated October 29, 1985).

(1) These resources are the same as. those required for traffic control [Ref, page 3 of 12, footnote (1)]. -

O 731973

, , Paga 6 of 12 November 6, 1985 m PROPOSED EXERCISE OBJECTIVES FOR

) THE 1986 SHOREBAM EXERCISE Field Activities - Continued (1) Ocacastrate a sample of resensueo necueser2 Lv effmet r carly di =ia :1 cf schocis within the 10-silm ZE I.

(1) Demonstrate a sample of resources necessary to effect an orderly evacuation of schools within the 10-mile EPZ.

(2) Demonstrate the ability to mobilize staff and activate Reception Center in a timely manner.

(2)(3) Demonstrate the ability to mobilize staff and activate Congregate Care Center in a timely manner.

Demonstrate by shift change or through rosters, the ability to maintain staffing at the Reception Center on a 24-hour basis.

Demonstrate by shift change or through roster, the ability to maintain staffing at the Congregate Care Center on a 24-hour basis.

Demonstrate the adequacy of procedures for registration, radiological monitoring, and decontamination of evacuees and vehicles including adequate provisions for handling contaminated waste.

Demons trate the adequacy of facilities for mass care of evacuees.

I Ocacr tr:cc adcquac3 foc ;;hal;acc f ac;1; tic; :nd

-p r e c e d u r c e for handling injurcd and contaminetma individualc. '"cdical drill invcirc; an on site /

cff site injury'.

-D c r. c a c t r a t e adequacy cf h: pit:1-facilitic and p recedurec fer handling injured and ccataa;aated *

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- individualc '"cdical drill involve :n :n ;itc/

cff eit; injury'.

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l (1) In accordance with procedures, only one of these options can be implemented. Should decision makers decide to recommend early dismissal, it will be up to controllers to exercise a contingency message to prevent early dismissal I

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of schools which would lead to a demonstration of evacua-tion resources.

. 731974 L .

(2) May need to be demonstrated out of time sequence, depending on availability of facilities.

(3) The congregate care function is provided by the Nassau County Red Cross.

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Paga 7 of'12 November 6, 1985 fl-d PROPOSED EXERCISE OBJECTIVES FOR THE 1986 SHOREHAM EXERCISE (1) Brookhaven Area Office (BAO)

' Demonstrate the ability to receive ~ initial and follow up emergency notifications.

Demonstrate the ability to mobilize staff and activate the BAO in a timely manner.

Demonstrate through rosters, the ability to maintain staffing in the BAO on a 24-hour basis.

Demons trate that 'the BAO has adequate space, equipment, and supplies to support emergency operations.

Demonstrate that the BAO can es tablish appropriate communication systems.

links, using both primary and backup Demonstrate that the BAO has adequate access control and that security can be maintained.

D emo n s t ra te that messages are transmitted in an accurate and timely manner, messages are properly logged, that status boards are accurately maintained and updated, that appropriate briefings are held, and that incoming personnel are briefed.

Demonstrate that the appropriate official is in charge and function.

in control of an overall accident assessment D emon s t rate the ability to communicate with all I appropriate locations, organizations, and field personnel.

Demonstrate the ability to pro the public via plume exposure, based ject radiation on plantdosage to data and

field measurements, and to d termine appropriate protective measures', based on PAGs and effectively t

communicate them to the LERO EOC.

i (1) These objectives have not been reviewed by the Brookhaven Area Office.

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Page 8 of 12 November 6, 1985-PROPOSED EXERCISE' OBJECTIVES FOR 3 -O.. THE 1986 SHOREHAM EXERCISE

, Staging Areas Demonstrate notifications.. the ability to receive' emergency Demonstrate the ability to mobilize staff and activate the staging areas in a timely manner.

Demonstrate through ros ters, the ability to maintain staffing at the staging areas on a 24-hour basis. ,

. . Demons trate that the staging areas have adequate space, parking emergency operations.

area, equipment, and supplies to suppprt Demonstrate that the staging areas can establish appropriate communication links with the LERO EOC ~ and field personnel using both primary and backup systems.

Demonstrate that the staging areas have adequate access control and that security can be maintained. ,

D e mo n s t rate that messages are transmitted in an accurate-anc timely manner, messages are properly logged, that status boards are accurately maintained and updated, that appropriate briefings are held, and that incoming personnel are briefed.

Demonstrate that the appropriate official is in charge and in control of an overall response assigned to the staging area.

Demonstrate emergency workers in the field.

the ability to dispatch to and direct

Note:

' Exercise objective related to issue of legal authority and S ta te. and local participation. This objective to be set aside when Option.1 is selected for exercising of the LERO plan (see Mr. Speck's letter to Mr. Dirks of NRC dated October 29, 1985).

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Page 9 of 12 November 6, 1985 PROPOSED EXERCISE OBJECTIVES FOR THE 1986 SHOREHAM EXERCISE Staging Areas - Continued Demonstrate the ability to communicate with all appropriate locations, organizations, and field personnel.

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Pcga 10 of 12 November 6, 1985 PROPOSED EXERCISE OBJECTIVES FOR

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THE 1986 SHOREHAM EXERCISE Emergency Workers Decontamination Facility Demonstrate the ability to mobilize staff and activate Emergency Worker Decontamination Facility.

Demonstrate by shift change or through rosters, the ability to maintain staffing of Emergency Worker Decontamination Facility on a 24-hour basis, f Demonstrate adequate equipment and procedures for decontamination of emergency workers, equipment and vehicles including adequate provisions for handling contaminated waste. '

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1 Pr.ga 11 of 12 Novsmber 6, 1985 ,

n PROPOSED EXERCISE OBJECTIVES FOR V THE 1986 SHOREHAM EXERCISE Emergency News Center (ENC)

Demonstrate the ability to mobilize staff and activate LERO functions at the ENC in a timely manner.

Demonstrate through shif t chaage or through rosters, the ability to maintain staffing of LERO functions at the ENC on a 24-hour basis.

Demonstrate the ability to brief the media in a c' lear accurate, and timely manner.

Demonstrate the ability to share information with other

. agencies at the ENC prior to its release.

Demonstrate the ability to es control in a coordinated manner,tablish and operate rumor .

(1)

0 e e n c trate the- ch111ty- te p cpore -cad impicacat=000 ---in-a tir.cly manner (i.e., within 15 minuter after ec- and and centrcl de:icicr fer i=pic catatica- cf proteet>iWe-cticn recom..cadaticas). '

Demons trate that the ENC has adequate space, equipment, and supplies to support emergency operations.

Demonstrate that the Et:C has adequate access control and that security can be maintained.

Note: Exercise o b jec t ive related to issue of legal authority and S ta te and local participation. This objective to be set aside when Option 1 is selected for exercising of the LERO plan (see Mr. Speck's letter to Mr. Dirks of NRC dated October 29, 1985).

(1) EBS messages are prepared and communicated from the E0C only;

by LERO procedures.

O 731ern

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. -Paga 12 of 12 November 6, 1985 N

' %) - PROPOSED EXERCISE OBJECTIVES FOR THE 1986 SHOREHAM EXERCISE Emergency Operations Facility (EOF)

(1) Demonstrate the ability to mobilize staff and activate h

Ligo functions at the EOF in a timely manner.

(1).

Demonstrate by shift change or through rost.ers, the ability to maintain staffing of LERO functions in the EOF on a 24-hour basis.

Demonstrate that the Emergency Operations Facility has adequate space, equipment, and emergency operations. supplies to support Demonstrate have adequatethat the Emergency Operations Facilities

. maintained. access control and that security can be '

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Note:

Exercise objective related to issue of legal i authority and S ta te and local participation. This i objective to be set aside when Option 1 is selected for exercising of the LERO plan (see Mr. Speck's letter to Mr. Dirks of NRC dated October 29, 1985).

(1) The LERO plan does not include dispatching a person to the E0F.

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Itinerary for the Shoreham Esereise

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February 10-14, 1986

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h ,*5'.' ? d'.g . p twi Time Event Place Remarks :

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4 .- ( x 5

- N- f ( "' T . Feb. 10 Traveler's Out of town evaluators. Evaluators at the Importants Evaluators, can' trollers I

'_ ...~j, Arrangements controllers and simula- Inn at Medford 1

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. ,1-tors are espected to and simulators should f amiliarise themselves with the exercise I

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check in at hotel Controllers and simu- package including plan, exercise

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. E ;. } , ' - '4.. ,4 l: lators at Colonie objectives, scenario and assignment ,

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' ' . $! 3 r,b. I 8:30 - 12:00 Noon Joint Training Session The Inn at Medford All Federal evhluators and FEMA's 4,

with FEMA evaluators. - Ballroom - controllers and simulators are

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, , yp, ]lkt b' - .~ " ,f, controllers, and required to attend. 1.ERO con-

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simulators

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trollers are also invited to attend this session as well.

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Itinerary for the Shorehann Esercise 4 .

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sate a Time Event I Place Remarks Fe b. 11 ICant'd) -

b. How the LERO Plan is 1 j structured

c. Esercise control plan -

overview e Interaction of FEMA '

evaluators with FEMA e

controllers and simulators Roles of FEMA cont rollers vs. FEMA simulators g

o 2. PIO Activities to be covered by O Marianne Jackson / Roger Kowieski.

hO 12:00 Noon-1:00 PM Lunch Own arrangements P 1:15 PM - 3:00 PH Training session with

@ The ten at Medford FEMA evaluators and - Ballroom -

I. Topics to be covered by Joseph Keller controllers (no simulators will attend e Exercise this session e Dosimetry

2. Detailed discussion of:

o Exercise objectives e Observers assignments by Thomas Baldwin and Roger Kowieski v b/

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[I[ 7$' }8 ltinerary for the Shoreham Esercise February 10-14, 1986

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.'I'h ...t. Place Remarks t R,g gi 4 *;' ';l reh. 11 1:15 PM - 5:00 PM Training session with To be determined 1. How New York State and c$unt y ICont'd) simulators of State and Qg f .d 6 ]3' . k County functions plans are structured by Roger z n i: o Kowieski Q,h (t )m ..e

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fG,. 2. Role, responsibility and ,

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'c authorsty of each simulator by {

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[ C Bernard Weiss '

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!s 'i M.Ig .M ,-3:00 PM - 5:00 PM Evaluation team meetings

.o Individual rooms Team leaders meet with their teams

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O and discuss individual evaluator assignments, answer questions, etc.

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h 3:00 PM - 5:00 PM Training session for The Inn at Hedford

/' b(i,b*H(D J b' 2 all FEMA controllers - Ballroom -

Topics to be covered by Richard Donovan.

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Controller assignment Controtter responsibility and authorsty

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. Yl i if I' l. i " k ych. 12 8:30 AM - 11:30 AM Evaluator / controller with their assignment Per evaluator / All evaluators are to drive to their ll *P . '.M ' ' I controller assignment field assignments so they will be kO-.g 'Wt ;F ,J sf' y aj

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locations in field able to navigate their routes during exercise.

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                                             ;        jd.                                                                          February 10-14, 1984 h.f!                                      f! ~

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reb. 12 8:30AM - 11:30 AM l h.' (Cont'd) Simulators will find Per simulator assign-N their assignment ment ' Simulators will visit the following locations facilities: p I j{; I: . e EOC e EOF e Control Cell at Brookhaven ih ,, National I,aboratory J tp g ta O Simulators who are to be stationed at I not the EOC and EOF should find but h enter these facilities. II:30AM - 1 00 PH Lunch O Own Arrangements j

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I:00 PM - 4:00 PM Evaluators will study Individual rooms their assignments Evaluators will study the following: i e Plan e Procedures 9 e Exercise objectives

e Assignment sheet 1:00 PH - 4:00 PM Controllers and simu-f' i lators will attend To be determined e Controllers

activity to be training session coordinated by Richard Dunovan e

Simulators' activities to be

                                                                   '                                                                                                          coordinated by Bernard Weiss 4:00 PM - 5:00 PH        Ceneral meeting for

( evaluators / controllers The tan at Medford Resolution of any problems y' and simulators

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i j - Altschment fl '

                                                                                                                                      ,             Page 5 of 8             i I

ltinerary for the Shoreham Euerelse February 18-14. 1986 '

   '                                                                                                                                                               t tute           Time Event Place Remarks F.:b. 13   Per Esercise j                                                          Evaluators on Esercise                                                                                            \

l Day Per esercise e ' Assignment (s) All FEMA evaluators wil report to observation points. . e Team Leader may change the assignment during the esercise to meet the changing situation.

                   ;. g                                                                                              Each evaluator will complete the O

l! O O Esercise Objective Evaluation Form. e h All activities pertaining to p News Media /PIO will be coordi-nated by Roger Kovieski through Marianne Jackson. Controllers and simu- Per esercise e lators on esercise day assignment All controllers and simulators ~

will report to assigned location.

6:00 PM - 7:00 PH Dinner Own arrangements All FEMA evaluators, controllers, and simulators return to Medford Inn, taking time for dinner enroute 7:30 PM - 8:30 PM Neeting of a'll (one hour only) Place to be deter-evaluators, cont rollers, mined The purpose of this meeting is to and simulators with RAC develop Emergency Classification Chairman and Lead' and Event Time Line and brief Cont roller discussion of major esercise events. s i 1 L li _ -

                                                       *          .r
  . h .T -                                  L". f                          nk j

N N,3,* a '

                                                                           'I j, f}, :; *

t e .(4,r, -

Attachment #1 it - Pqesors [ 1,

   ' { .i' %

Itinerary for the fBiorehess Euereise i February 10-14, 1996 l

                     ' d5 [Lp *I sfM?vth                       I }h '?.f.-

A.I I Date Time

             . . . .e. .

Event

. v. ,.1: Place Remarks

   * * - . *rtt.                                     pg,3,h
                                                       ~i. **

h-b. 13 8:30 PM - Team Leaders meet with Place to be deter- ) ye4 A ' D.'s' 'T *

          < . ; .51 (Cont'd)    completion                their team members and             mined e    Each Team Leader will develop an
                                                     ;. ' ,, I simulators                                                  exercise highlights summary

( 1. , ., *t i narrative (approminately one (1) (( , . 6 paragraph f rom each evaluator) ,'

                                                          .                  9 I                                                                   ,

for the team. Team Leader must

 , NA ',' '                  5 U,'              h"*                                                                                                                      delsver handwritten draft of Team
          ' 9 j g.  .-
                                    )
                                                                     ,y
                                                                     '..      y ' ,.       -

highlights to typist (s) no later p, than 6:30 AM Friday, February 14 [ [ o

                                                    - =,

Q e Simulators should complete their

                                        ~ I J 3. ,}

log of key discussion / interactions with LERO players. b.

                                              *?'th ,; O!c 4
         ".--                                        4                             .i
       .. ' ' 3 :tk k . I's          '

Feb. 14 6:30 AM - 10:00 AM Typist (s) type team Place to be deter-

                       .h', %*'# +"4 )1                                                                                                                                                   Team leaders must deliver highlights

i. highlights y, mined to typist (s) so that draf t highlights "f

9. ' >

                                                                  ~.$g,
                                                                      ,                                                                                                                   will be prepared for 10:00 AH meeting J             .y                                                                                                                     with RAC chairman
                   ~ j'                        ~~ I A               I- A                                 11:00 AM-12:00 PM         Meeting of RAC Chairman            The Inn at Medford
       } ,' y. ., _                                  P,)                  e, Review of Highlights J.1 -                                                                                               with Team 1.eaders
                             "    '[.1a                .$l'-                                             8:00 AM - 12:00 PM Exit meeting for FEMA                     Place to be deter-
         .[*"     '

3 ;- controllers and mined

1. Simulators should check with Evaluation Team Leaders to insure

                        ' N; ,b.

fp ?>d j '*. . . A - simulators that all questions pertaining to simulator discussion / interaction 5 '. . __

                                                                   ' .                                                                                                                       logs are resolved.

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p. 447 m ..

q. e.=mi.-

). (....,,.,.+ s ,c c. ; .I ' i { .,

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Attachment iI e t .-, . $,- Page 7 of 8 I, . . -

                                                     *[$ p?;; A i                                                                          llinerary for the !Biorehamn Ezerelse e             , . ;                                                                                                                         February 18-14, 1986

_y> ,. l 4 : k# l pate !

               ?;                                       .L 3         -                                          Time                                                                                                            '
                                            ^
                                                               '-                                                                      Event Place
                    ..'.-                                                                                                                                                                              Remarks L'

j .

Fe b. 14 Iy * ; , $'r, 5{ ~g s.-- (Cunt'd)

                                          .d .

M .l g * ,} f-.

                                 .d dA                  .:-                                                                                                                            2. Simulators and controllers will be
                                                    ,%.,3            d/g
    ,4                           c'.                                                                                                                                             .         released to leave the hotel when     t all issues, questions, etc. have 9** *&                                                                                                                                                                               been resolved.
                                                     '43                              '

8:30 AM - 2:00 PM Completion of Esercise j t'l .1 i ,

Evaluation forms by all Individual rooms e All FEMA evaluators are to com-g FEMA evaluators

                                     '.       . .s.                                        O plete their exercise Objectives Evaluation Forms and hand them
                                                                  . W] h
                                                *1 ~ (.                I4 t;

c) in by the trae designated by their o

    -y "' - l? jfj hf. o                                     y}k 72y g. P <.                                                                                                                         respective Team Leaders. ALL t         .

g COMMENTS AND RECOMMENDATIONS MUST at CLEARLY WRITTEst, COMPREltENSIVE AND READY FOR USE IN THE POST J .Z g EXERCISE ASSESSMENT REPORT. b.;,. lif O'

                                                          +j 3:00 PM . 4:00 PM Briefing of Lllr0 Mh  , , ,
                        ' : ,j W ' 1 , ,

Dhi > . Place to be deter-mined RAC Chairman, Team Leaders, and all

                             ' ' Mt
                                                                      .i.
                                                                                    '                                                                                               observers the LILCO. will be available to brief 4:00 PM - 5:00 PM A. .I'" W'                   'r' k (1 4     -!
                                                                       '                                                    Finalise Esercise f5'y ,' 1: .:- t JG Evaluation Forme                                       All evaluation forms must be com-
           *                                                    ,'3                                                                                                                pleted and submitted to team leaders 8

d'd J t by 5:00 PM. i ' r/ , mT, - Mr'. .u - '

                         '                      M4+<                                                                                                                               Evaluators will be released to leave r-                 h'I*h,{  E                                                                                                                         when Esercise Evaluation Forms have been reviewed by Team Leader.

gl < . : .. ' ' e

                                                                                                        $:00 pH . 9:00 PM 7 .. ...,                                       n..         -,

RAC Chairman will finalize Critique.

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{;'l Attachment fl -

    . . t                                                                                                                                                                                                        Page 8 of8
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Itteerary for the Shoreham Eserelse February 10-14, 1985 e t- pt,' + '., I

    &',y                                                 y         -

i,.* Y l, . ; M Idl ' Date Time Event Place

                                                                       ')'j                                                                                                                         Remarks
                                '.N , $ q ','.'.

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g ['4*~-.f. - Fein. 15 Time to be deter-t.~.- r

                               . . *            .,..'-                       j                                 mined Esercise Critique To be determined 1
  ? ~ . '.;'                                      -
                                                              , , 4' i Esercise Critique by FEMA and WRC.

7 ., ,. 'b m' b / *j. Id i -ts.1 j( Selected FEMA personnel.

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                          .              wa.hin,,en, o.c. 2o472                              .

DEC 3 0 i986 l l l r Mr. Victor Stello, Jr. l Executive Director for Operations U.S. Nuclear Regulatory Cbnsnission Washington, D.C. 20555 Dear Mr. Stello On July 16, 1986, the Nuclear Regulatory Camission (NRC) requested the ( Federal Dnergency Management Agency (FEMA) to review Revision 7 of the Iong Island Lighting Co@any's (LIICO) Transition Plan for the Shorehan l Nuclear Power Station (StPS) and LIICO's responses to the FEMA Region II l Shorehan Post Exercise Assessnent (PEA) for the February 13, 1986 exercise of Revision 6 of the LIICO Transition Plan. On Septenber 30, 1986,tec requested FEMA to include Revision 8 in its review of the LIICO Plan. 'Ihe [ requests were made mder the NRC/ FEMA Menorandum of Understanding (POU). A full Regional Assistance Conmittee (PAC) review of Revisions 6, 7 and 8

O has been completed and the results_are. cont &ined_in the enclosed report entitled "LIICO Transition Plan for Shoreham - Revision 8, Consolidated RAC Review" dated December 15, 1986. The LIICO responses to the FEMA PEA are evaluated separately on the enclosed spread sheets. (Note: On February

' 12, 1986, FEMA provided NRC with the results of the FEMA review of Revision 6; however, due to the limited nature of the changes, the review was conducted by FEMA Region II. In revi(wing Revisions 7 and 8, FEMA also requested the RAC to include Revision 6 in their review). -

         '!he RAC reviewed the plan revisions against the standards and evaluative criteria of NUREG-0654/ FEMA-REP-1, Rev.1. Based on FEMA's evaluation,

! Revision 8 contains fifteen inadecuacies. The planning inadequacies and l reconnendations for improvement are explained in.the enclosed RAC review. l Due to the legal authority issues which arise when some NUREG elements are l applied to a utility-based plan, we have marked with an asterisk any aspect of the plan where, in our view, this legal issue occurs. The specific legal concern related to that part of the plan is identified separately in Attachment 2 of the consolidated RAC review of Revision 5. With the i exception of plan aspects relating to NUREG element A.2.b. (a requirement ,. to state, by reference to specific acts, statutes, or codes, the legal basis for t!)e authority to carry out the responsibilities listed in A.2.a., f i.e., all major response functions), the legal concern did not affect the FEMA rating given to the technical or operational itens related to NLREG elements. ,s \O ~ l l l C J

          ..                      -   -   -           _. .-           .    .               _ _ = - . -

i O . , h e issue of the participation of WALK FM radio was treated in the following manner. Via the September 18, 1986 LIIID letter transmitting Revision 8 to NRC, it came to FEMA's attention that on September 16, 1986, WALK FM had withdrawn from its agreement to serve as the Shoreham emergency broadcast

primary station. In that letter, LIIiD also stated that a replacement station would be incorporated in the next plan revision. Based on the fact that the administrative processes for printing and delivering Revision 8 (which includes

, WhLK PN radio) had undoubtedly been completed by the time that LILCD was j informed of WALK's withdrawal, FEMA evaluated element E.5, which depends on

               . the participation of that particular radio station, as adequate. However, in any future reviews of the plan, element E.5 (and perhaps others) would be rated inadequate unless a suitable substitute station has been established and is supported with the necessary letter (s) of agreemer:t.

In the spread aheets detailing the FEMA evaluation of LILCD's responses l to the FEMA Post-Exercise Assessment, there are several instances where l training was to have occurred by September 1, 1986. PEMA did not request rosters or take other steps to verify that such training took place. As i stated in'the evaluation portion of the spread sheets, the training's offectiveness would have to be evaluated in the future. As you are aware, FENA and the RAC have consistently supported the NRC in the Shoreham licensing process by reviewing numerous LILCD Transition Plan iterations rO-submitted to us for review under the provisions of the'KXJ. FEMA has expended a considerable amount of staff time and financial resources to provide for these reviews and subsequent expert witness testimony before various NRC licensing boards related to plan litigation. Further, at NRC's request, FEMA devoted additional resources to the preparation for and evaluation of the exercise of the LILCD plan. At present, there are a number of unresolved issues being considered or litigated

in no less than three different NRC forums. Here are planning and exercise issues l hefore two licensing boards; numerous issues under consideration by the full

! Comission. In addition, the OL-3 Board has recently reopened the record on l issues related to the Nassau Coliseum. (A separate letter on these issues is being sent from FEMA's General Counsel to the NRC General Counsel.) In FEMA's view, the fluidity of this great number of issues renders it imractical, and an unwiso use of limited resources, to continue to perform further reviews of LILCD plans or exercises under the current unsynchronized

              . manner in which these issues are being adjudicated. This works to the detriment of effective treatment of the issues fran a programatic view-point.

Within the limits of sound management of resources, FEMA remains comitted to providing testimony to assist in the resolution of the various issues before the NRC's licensing boards and to provide information which may o be needed by the Comission tio resolve issues being considered by them.

s O - I hope the enclosed. information is helpful in your analysis of emergency preparedness issues concerning Shoreham. I also hope it will assist you in understanding FDWs position relative to am/ request for plan reviews and exercise activity. l Sincerely, bw Dave Mcteughlin # Deputy Assciate Director State and Local Programs and Support i Enclosures As Stated O - s ( O .

     ~ ~ - - - - - -    s - ,     ,-.-a ,n_ -. ._     ,, __ ,___ _ , __ _ ,_ _ __            _

0 {& h[ LILCO Transition Plkn for Shoreham - Revision 8 O . seP to consoliaetea arc as ie-Dated December 15,1986 The Regional Assistance Committee (RAC) review of the LILCO Transition Plan for Shoreham (Attachment I) is based upon planning criteria specified in NUREG-0654, FEMA-REP-1, Rev. 13 Criteria for Preparation and Evaluation of Radiolorical Em a.av Rense Plans and Preparedness in Support of Nuclear Power Plants. November,1980. The plan has been evaluated against each plaaal=r element specified in NUREG-0654 applicable to State and/or Localjurisdictions. These evaluations are keyed to the following rating systems ADEQUATE RATING A (Adequata) A* (Adequate - concerns pertaining to LERO's legal authority identified

                                                                                                       .during this review)

The element is adequately addressed in The element is adequately addressed in

                                             ,the plan.         Recommendations for                the plan provided concerns pertaining O                                         improvement shown in italie are not                 to LERO's legal authority are resolved.

The issues of legal authority affect-mandatory, but their consideration would further improve the LERO plan. Ing these elements are described in These recommendations include Attachment 2 to the RAC review of revisions to the NUREG-0654 cross- Revision'5. reference, and other minor improvements.- -

     .O e

4 , . , . _ _ __.- _ ._J

         '~     ' >

LILCO Transitio'n Plan for Shoreham - Revision 8 h , Key to Consolidated RAC Review Dated December 15,1986 INADEQUATR RATDIG I(Inadequate) I* Onadequate - concerns pertaining .to LERO% legal authority identified during this review) . The element is inadequately addressed The element is inadequately addressed in the plan for the reason (s) stated in in the plan for the reason (s) (not related bold type. The pien and/or gwet. ee to legal concerns) stated in bold type. l must be revised before the element can The plan and/or procedures must be revised before the element can be be considered adequate. considered adequate. In addition, concerns pe_-taining to LERO% legal authority were identified by the RAC, and are described in Attachment 2 to the review of O Revision 5. - l 1 I O I e

     ,       ,, e - - . , , , - . . . , _ - ~ . - - . . , , , - _ _ - - , _ _ . - ,         _. _.-_2.-_.--.__. - _ _ . -    _ - - . _ _ . - - . _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

   $ . o ATTAC m mT1 ue LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review a t a o     =6 15.1'==
 -O                    .

Page 1 of.15 NUREG-0654 Element Review Comment (s) Ratins A. Assignment of Responsibility (Orranization Control) A.1.a See review of Revision 5. A* A.I.b See review of Revision 5. A A.1.e See review of Revision 5. A A* A.1.d See review of Revision 5. A.1.e See review of Revision 5. A A.2.a See review of Revision 5. In addition, two (2) key A* positions have been added to the LERO organiza-O .- The plan has been revised to add a traffic engineer to the staff at the EOC to evaluate any possible impediments to evacuation and to make recom-mendations on necessary changes to evacuation routes in response to potential impediments. Another position, a LERO Spokesparson, and additional staff have been assigned to assure better coordination of information in the ENC. A.2.b See review of Revision 5. , 1* A.3 See review of Revision 5. In addition, the following I* comments pertaining to revised letters of agree-ment presented by LILCO with Revisions 7 and 8 are now applicable. Federal Aviation Administration (FAA) - A letter of agreement with the FAA has been withdrawn by LILCO since responsibility for notifloation of the FAA has been shifted to the U.S. Department of Transportation (DOT) via FEMA as recommended in the review of Revision 5 of the plan. However, based on results of the February 13, 1984 exercise and the RAC review of subsequent plan revisloes it G h _R -

ATTACNMENT 1 a.w l LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review O . Dated December 15,1986 s Page 2 of 15 NUREG-0654 Element Review Comment (s) Ratins A.3 la recommended that LERO notify FAA direetly !* (Cont'd) (see comments for element F.1.e in.this review). In

                                      , order to assure the most timely notif%ation of FAA, LERO should again obtain a letter of agreement with FAA.

Amerlean Red Cross - The letter dated August 21, 1988 submitted with Revision 8 of the plan states that " there is no agreement between Imag Island Lighting Company and this (Nasman County) Chapter ! relating to the chapter's responsibility to provide

                                          ' emergency                                    assistance  during            a             radiolagleal emergeney." This letter is not an aseestable letter                                                                                -

of agreement to assure that American Red Cross respoestbuities for Congregate Care faenities described in the plan wiu be carried out. Q Teledyne lootopes - The new purchase agreement > with Teledyne Isotopes, Appendix B, B-74A to 74D is an agreement for the routine Radiological Environmental Monitoring program. No indleation of detection limits or any assurance that there wul be capabuity for analysis la the event of an - l emergency could be loested in the plan. There is some mention af 24 hour emergency analysist however, this reference is in regard to routine samples being over prescribed limits. In response to an lasse identified at the February 13, 1988 azarelse, the plan has been modified to laalada notifloation of the Long Island Rauroad (unnh These planning provisions are adequate but point of contaet and telephone number for notifloation of the appropriate LIRR offlefal(s) should be documented with a letter of understanding between LERO and the LIRL Congregate Care Centers - Neither of the two (2) O eon re ate eare facilities activated for the February 13, 1986 exereise are identified in the l

                                                                                                ~                                                           -

LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Q _ Dated December 15,1986 Pa'ge 3 of 15 NUREC-0654 Element . Review Comment (s) Ratins A.3 latest submission of the LERO Plan. 'the Plan (Coct'd) thoukt be revised 'o include au faculties latended for une as shelter faeHities daring a radiologleal emergency at SNPS. '! bene facuttles must be laeladed in the !!st attached to LERO's letter of agreement with the Amerleen Red Cross. It is noted that OPIP 3.8.3, p. 3, mentions contacting the U.S. Coast Guard for helleopters (paragraph 5.1.1.e). There is no mention of holloopters in the Coast Guard letter of agreement contained in the plan. Brookhaven Multiplex Cinemas - The new letter of agreement for the use of the Brookhaven Multiplex Cinemas parking lot. as a bus transfer point, 0 . Appendix'B, B-68A-B-68E, is acceptable. A.4 See review of Revision 5. A C. Emergency Response Support and Resources I C.I.a See review of Revision 5. A* l C.I.b See review of Revision 5. . A l

C.1.e See review of Revision 5. A C.2.a See review of Revision 5. A C.3 See review of Revision 5. A C.4 Speeffle reasons for the landaquete rating of this ~ I*

element are detaDed in analysis comments for~ element A.3 in this review and the review of Revision 5. O D. Emergency Classification System D.3 See review of Revision 5. A

 ,e   ,--,---~,,-y,g,---. y   s,,wn-m,,l,   . , , . y ,,_e_--J,,.,m-,,_,--..,,.,----.., , , , _ , . _ , _ . , _ , , , , - - *, - . -                -

s . . ATTACwungT1 LILCO Transition Plan for Shoreham - Revision 8 ' Consolidated RAC Review O

                              .                  Dated December 15,1986
                          ~

Page 4 of 15 NUREG-0654

 .               Element              Review Comment (s)                                             Rating D.4               See review of Revision 5.                                           A L                 Notifloation of Methods and Procedures L1                See review of Revision 5.                                           A L2                See review of Revision 5.                                           A L5                See review of revision 5. In addition, it has come to              A*

FEMA's attention via the letter of transmittal for Revision 8 of the Plan that WALE has withdrawn from its agreement to serve "as the Shoreham Emergency Broadcast primary station. Based on Revision 8 which includer WALK FM Radio, this Q - element has been rated as adequate. However, in future reviews of the plan this element will be rated inadequate unless a suitable primary EBS station has been established and is supported with the necessary letter (s) of agreement. E.8 See review of Revision 5. It is recommended that A* the EBS message recommending evacuation be revised to include a sentence urging people to be

                                      " good neighbors" in et evacuation. Some suggested wording would be " Persons in the area to be evacuated are urged to be good neighbors and to assist one another by # ;ng rides and otherwise helping others with problems."            It is also recommended that this same sentence be included in the public information brochure.

L7 See review of Revision 5. A F. Emergency Communications F.1.a See review of Revision 5. A F.1.b See review of Revision 5. A n

ATTACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8

                                            -                          .                 Comlidated RAC Review Dated December 15,1986 Page 5 of 15 NUREG-0654 Element                    Review Cosmeent(s)                                                                                                Ratins F.1.e                    See review of Revision 5. In addition, the following                                                                     I comments are now applicable.

A letter of agreement with the FAA has been witadrawn by IJLCO since r W W for notifloation of the FAA has been stdtted to the U.S. Department of Transportation (DOT) via FEMA as recommended in the review of Revision 5 of the plan. IEowever, based on results of the February 13, 1988 exercise and.the RAC review of M - plan revisions it is recommended that LERO notify FAA direetly. In order to ammes the most timely notifloation of FAA, LERO should again obtain a letter of agreement with FAA. i n

     \/                                       .

The plan, has been modified to include notifleation of the Long Island Railroad (LIRR), Procedure OPIP . 3.3.3 Page 4 of Attachment 4, instructs the Support Services Coordinator to contact the LIRR at the Alert, or higher emergency classification, and to request closure of parts of the mainline if evacuations are called for in certain sectors.

                                                   .         Figure 3.3.4, page 4 specifies that the Long Island l                                                             Railroad will be notified at the Site Area Emergency and/or General Emergency ECLs. The LIRR should also be added to Figure 3.3.3 and to the notification diagram shown in Figure 3.3.5.

F.1.d See review of Revision 5. A F.1.e See review of Revision 5.- A F.2 See review of Revision 5. , A F.3 See review of Revision 5. A* O . . 9 9

            --.----,,,cm.,,,,_w.y              --,   .,- p y.-.m.m_!-_,--,--     ..- __ __ _ _

ATTACRMENT 1 LILCO Transition Plan for Shoreham - Revision 8 O . c iia t a a^c a $ - Dated December 15,1988 Page 6 of 15 NUREC-0654 Element Review Comment (s) Ratina G. Publie Education and Information G.I.a-d See review of Revision 5. It is recommended that A the public information brochure include information to encourage boaters in the EPZ to listen to Chatet 16 so that they con receive radio notification in the event of et emergency at Shoreham.

G.2 See review of Revision 5. A G.3.a See review of Revision 5. A*

G.4.a See review of Revision 5. A G.4.b See review of Revision 5. In addition, the following I O. comments are now applicable., Insufficient copying capabilities at the ENC resulted in delays in the distribution of information during the February 13,1986 exercise. These delays affected the following two (2) areas:

Hard copies of EBS messages were not provided to the media in a timely manner.
Rumor control personnel were not able to answer questions received from the public because they were not given accurate up-to-date status reports.

LERO should make provisions for reliable and rapid equipment to reproduce, in hard copy, all appro-priate messages for distribution to the ENC staff. The plan has been modified to create an additional l position, LERO Spokesperson, and additional staff ! have been assigned to assure better coordination of information in the ENC. The LERO spokesperson is responsible for coordinating the release of infor-mation working in conjunction with the County Executive, . or his designee, if he chooses to

     ,                                                                                                    ---__21

ATTACaumuT1 e , a LILCO Transition Plan for Shoreham - Renion 8 Consolidated RAC Review Dated December 15,1986 l . Page 7.of'15' NUREG-0654 Element Review comunent(s) Ratins G.4.b partielpate. The LERO spokesperson will represent (Cont'd) LERO at press conferences. Press releases are to be distributed to utility, government and media personnel at the ENC. Ar provided in OPIP 3.8.1, Section 5.2.4, changes in j important emergency information will be elee-tronleally transmitted to Rumor Control District offlees and call boards via TSO printout (also see ! . OPIP 3.8.1, Section 5.3.4). LILCO la stfIl evaluating the lack of hard copy espebility for distribution of EBS messages to the ( press la the ENC. Untti LILCO completes the evolastion of this agalpment for providing hard ooples of EBS messages to the media, the response . - O ===am-is-= % oomment for element G.4.e la this review. *

                                                                                  ~-           '

G.4.e See review of Revision 5. This element in rated I Inadequate for the same m given for element G.4.b of this review. , G.5 See review of Revision 5. A H. Emergency Faellities and Equipment H.3 See review of Revision 5. A H.4 See review of Revision 5. A* H.7 See review of Revision 5. A H.10 See reirlew of Revision 5. A. H.11 See review of Revision 5. A H.12 See review of Revision 5. A L -

                                     ,        , - - _                     ._ .                    -   -  _    _. __    _ _ _ _ - ~

l

      - -        -                                                                                      ATTACnunuT 1 l                                             LILCO Transition Plan for Shoreham - Revision 8 c

lO ( iia t a a^c a i - Dated December 15,1986 Page 8 of 15 NUREC-0654 - l Element Review Comment (s) Ratins L Accident Assessment L7 .See review of Revision 5. A L8 See review of Revision 5. A \ L9 See review of Revision 5. A I L10 See review of Revision 5. In addition, two (2) plan A changes have been made to address issues identified at the February 13,1988 exercise. The plan has been modified in OPIP 3.5.2 Section ' 3.6, to require that when field data are received, the data is identified as an actual measurement or - - O as extrapolated data. 'All extrapolated data are now- - - - to be posted under " projected data" on the status board. i Procedure OPIP 3.5.2, Section 3.5 has been revised I to speelfy that all distances reported by DOE-RAP teams are to be recorded in miles. I.11 See review of Revision 5. - A J. - Protective Response i J.2 See tsview of Revision 5. A , J.9 See review of Revision 5. In addition, the following I comments are,now applicable.

Revisions to Attachment 1 of procedure OPIP 3.6.8 refleet the current FDA response level tables including all footnotes whleh are necessary for proper use of. the numeric data contained in the Q . tables. I

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ATTACRMENT 1 LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1988 : ! Page 9 of 15 i l NUREC-0654 l Element Review Comment (s) Rating i J.9 As disenamed in the Post Exarelse Assessment of the (Cont'd) February 13,1988 ensreise, delays were observed la the dispateh of bus Myers due to delays in issuing i dosimetry and la the briensg of bus Myers and transfer point ecordinators. This element is rated inadequate until the plan is revised to aeoomplish timely distribution of dosimetry to the large an=hae of Das Drivers required to be dispatehod from the Patebogue Staging Area. This Wte rating also affects element J.18.g of this review. J.10.a See review of Revision 5. In addition, Procedure A* l

                                               -       OPIP 4.2.5 provides details on the set up and use of l                                                       LILCO's Bellmore, Hicksville and Roslyn Operations              .

Centers as reception centers for evaeuses in the O - -- event of Shoreham radiologic &l emergency. J.10.b See review of Revision S. A J.10.c See review of Revision 5. A* J.10.d See review of Revision 5. A J.10.e See review of Revision 5. Several issues involving I l' emergency worker knowledge and use of KI were i identified at the February 13, 1988 exercise. This element has been rated inadequate because bus drivers used for school evacuation have not been trained in KI polley and the use of KL Suffielent , supplies of KI are not available for school evacuation Bus Drivers. (1) Bus Drivers used for school evacuation should be trained in KI policy and the use of KL (2) Adequate supplies of K1 should be provided for l Bus Drivers used for school evacuation. ,.O LILCO's commitment to provide training and equip-l ment for exposure control to school bus Myers is l l l '..--_.-_,..._,._-,. n..,_._

ATTACnum4T 1 LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1988 Page 10 of 15 NUREC-0654 Element Review Comment (s) Ratins J.10.e understood. However, it is not evident la the plan (Cont'd) how thsee non-LERO workers are to be informed that tlhry need to laitiate the request. J.10.f See review of Revision 5. A* J.10.g See review of Revision 5. This element is rated I land =q==te for the same reason given for the i i==darrate rating of element J.S la this review. ! J.10.h - The letter from the American Red Cross to LILCO I dated August 21,1988 (see Appendix B pages B-11 to B11-4, states that the American Red Cross has not agreed to respond to a redlological emerge'eey at Shoreham (see lines 1-4 page B-11a). Page B-11b O- imou - that the i-*an Red - adr -

                                .with and through the government. . It also states                            ,

that letters of agreement between the American Red Cross and owners of a facility to be used as a shelter wiu be entered lato at the time of an. ; laeldent. This polley is unworhble. The new l material submitted for Appendix B raises many I questions concerning the partielpation of the Amerleen Red Cross in a Shoreham ineident, not only in the operation of shelters but also in connection with EOC partielpation. It is FEMA's position that letters of agreement are required for au faentties wideh are planned to be used in an emergency response. J.10.1 See review of Revision 5. A J.10.) See review of Revision 5. A* J.10.k This element has been rsted inadequate for the I* reason (i.e., snow removal r- and procedures) ! specified in the review of Revision 5.* -

                                 *It should be noted that one (1) RAC member felt that this element should be rated adequate (A).                                 ;

I

                                                                                                                  .                ATFACEMENT 1
                                                                ~

LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review O , Dated December 15,1988 , Page 11 of 15 NURSC-0654 ,. Element Review Comment (s) Ratins i J.10.k in response to an exercise issue, the plan has been (Cont'd) revised to add a traffle engineer to the staff at the EOC to evaluate any possible impediments to evne-ation and to make recommendations on necessary ehanges to evacuation routes in response to poten-tial - Impediments. Procedures for field workers, i.e., bus drivers, traffic guides, etc., have been modified to include instructions to make prompt notifications through their communication network of any potential impediment. Provisions have been made to issue an EBS message in the event that changes to evacuation routu are necessary. Internal communications within the LERO EOC

                                                                       ,, regarding assessment of an response to evacuation impediments has been adequately addressed through                          ,

modification to the NJa (esp. , OPIP 3.8.3, , Traffle Control). The Evaewton Route coordinator is responsible for obtaining periodle updates from the Evacuation Route Spotterr, and for immediately reporting road impediments or other problems to the Traffic Control'Coordinatcr and Road Logistles , Coordinator (See OPIP 3.6.3, Section 5.8.7) Lead ! Traffle Guides (at the staging weas) are to aport any incident. J.10.1 See review of Revision 5. A J.10.m See review of Revision 5. A ! J.11 See review of Revision 5. A l J.13 See review.of Revision 5. In addition, the following I comments are now applicable. l The LERO Reception Center previously designated at the Nassau County V2terans Memorial Coliseum has been changed to three (3) LlLCO fac811tles O loested in seitmore. ai *svii.e and Rosiin. The adequacy of these facilities as reception centers l must be evaluated at a future exarcise. + \ s I--- r-.--- - - - - - -r --,,m-- ,--,--n -._.w.--,-g-

                            ,                                                                                                                                           ATIACHMENT 1 LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1986 Page 12 of 15 NUREC-0654 Element                         Review Comment (s)                                                                                           Ratina 1

J.12 la addition to the etaanse of Reception Center (s) (Cont'd) loestion, the plan specifies (see page 3.9-5 of Revision 8) that a sermening process will be used to ahoek evaanaan for con *=minotica. ' Insoming v=hiales will be directed to monitoring stations where the webloie and elver wiH be ahaalrad for contamination. Aeoording to tids sereening procedure, passengers of the veldels wiu also be assumed to be vemoscamineted and a clean tag win be issued to them if the &iver is be:ow anotamina-tion limits. This screening praaad=e is inadarpate since the applicable guidance requires the onpabutty of monitoring wittdn about a 12 how period au residents and tracelents,la the plume EPli. .;,Q at tie Reception Centers. .. O- t==O is re.ponsibie for me.dtoring an evneeses _.;,W at receptica centers. It is not adequate to plan for tids monitoring with perman==1 and equ pment when avallahla- It is not possilde to 8 evaluate the number of personnel required for socitoring et the special population reception eenters since the plan shewe la procedure OPIP 3.8.5 pages 21-37, "to be arranged" for most of the special population reception centers. K. Radiological Exposure Control K.3.a See review of Revision 5. Several issues involving I emergency werker knowledge and use of dosimetry were identified at the February 13, 1936 exercise. This element has been rated inadequate because dcainistry and training were not provided to the Bus Drivers used for school evacuation. f (1) Bus Drivers used for school evacuation should tx. trained in the use of dosimeters. O (2) Adequate supplies of dosimetry should be provided for Bus Drivers used for school evacuation.

  . - . .  ,...-.__..v.---,.-.-.,,.,y                      .__-._,,_,.,____,.-m__               . , _ _ . _ _ _ . . , , , _ _ , _ _ _ . , _ . , - _ . . - . _

l *e . ATTACIDEERIT 1 l LILCO Transition Plan for Shoreham - Revision 5 Consolidated RAC Review O .. osted oeoe aer15.1555 Page 13 of 15 l l NUREC-0654 . Element Review comment (s) Rating E.3.a LILCO's commitment to provide trahdng ami (Cont'd) equipment for exposee control to sehool bus skivers is inderstood. However, it is not evident la the plan how these non-LERO workers are to be leformed that they need to initiate the regnest. l E.3.b See review of Revision 5. This element is rated I I landarrate for the same reason given for element E.3.a la this review. E.4 See review of Revision 5. Tais element is rated I land =nrate for the same reason given for element E.3.a la this review. - E.5.a . See review of Revision 5. A l l E.5.b See review of Revision 5. . 'A i i l L. Medical and Public Health Support l A

l L.1 See review of Revision 5. l L.3 See review of Revision 5. A L.4 See review of Revision 5. A M. Recovery and Reentry Planning and Postseeldent_ Operations M.1 See review of Revision 5. A M.3 See review of Revision 5. A M.4 See review of Revision 5. A O *- z erei e a o o iii-N.1.a See review of Revision 5. -A* N.1.b See review of Revision 5. A*

   , - . . . _ ~ . . _ _ . - - . _ , . _ _                   . . . ~ . . , . . . - . _ _ _ _ . _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _          . . . . _ _ _ . . ~ _ . _ _ _ _ _ _ . _ - . . - - - . _

[ AT"!1CHMEWT 1 ULCO Transition Plan for Shorehsm - Revision 5 O . consoiid ted RAc Review Dated December 15,1986 o - Page 14 of 15 - MREG-0454 Element Review Comment (s) Rating N.2.a See review of Rerision 5. A N.2.e See review of Revision f. A N.2.d See review of Revision 5. , A N.2.a.(1) See review of Revision 5. A l N.3.a-f See review of Revision 5. A > N.4 See review of Revision 5. A N.5 See review of Revision 5. A

                                                                                                                                                              .  ?
                                                                                                                                                                              ?

O. Radiolorleal Emerraney Response Training ' O.1 See review of Revision 5. A , i O.1.b See review of Ra'ilslon 5. A O.4 See review of Revision 5. In addition, it is A s suggested that ULCO consider requiring that L D D4 be provided per module 11 to personnel assigned to the Emergency Worker Decontamination Facility and the Reception Centers. It would also be advisconte to consider requiring L.L.Lg per module Il for personnel assigned to the following positions: Emergency Medical Coordinator, Nospital Coordinator, and Ambulence Coordinator. O.5 See re<!n of Revision 5. A P. Responsibility for the Plannint Effort P.1 See review of Revision 5. A* O P.2 See review of Revision 5. A* P.3 See review of Revision 5. A* P.4 See review of Revision 5. A*

ATTAR'msmsT 1 LILCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review . O - o t a a - 25.1'a . Page 15 of 15 NUREC-0654 Elemene Raview Comment (s) Estins P.5 See review of Revi2 ion 5. A* P.6 See review of Revision 5. . A P.7 See review of Revi'ston 5. A j P.8 See review of Revision 5. A I P.10 See review of Revision 5. A j h

O - t G O

O O O . . S

TARLE 3.1 SHOREHAM NUCLEAR POWER STATION - SCHEDULE FOR CORRECTING DEFICIENCIEg OR AREAS REQUIRING CORRECTIVE ACTtoll February 13, 1986 Eseretse e

1.ERO EOC Fage 1 of 85 l Q 30 SstI ^d =E =~. OS" 4.3

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l Ile. RAC Retemmendation for Corrective Action jgy LERO Response (ACTiell) ' FEMA Evaluation of LERO Response lI j Delays in respondtag to the two (2) D Procedures have been 5/26/86 The plan has been revised to A 1 1 J.10.k add a traf fic engineer to the evacuarton impediment free-play. s.-tawed and revised messages inserted at the LERG EOC were t. *sure ,taformation staff at the EOC to evaluate Impedimente to any poselble impediments to caused by the fatture to inform the os. promptly passed to all evacuattoe and to make recoe-Evacuation Coordinator to a timely mendatione on necessary changes manner. la addition there vae a lack relevant pereoanet and of internal communication in response a coordinated response to evacuation routes in to these tapediment problems. Per- taptemented. In addt- response to potential imeed!- tion, a Traffic mente. Procedures for field tinent taformation was not included on Engineer has been workers, i.e., bue drivers, the 8045 and .1106 8.ERO Message Forme traffic guides, etc., have been from the Evacuation Route Coordinator added to the 1.ERO EoC to the Evacuation support Communicator staff to assigt in modified to include teatruc-evaluating and tiene to make prompt motttt-I for Route Spotters / Road Crews regarding cations through their comment-the almulated impediment involving the developing alternate routing. cattoe network of any potentist gravel truck and fuel truck problems. tapediment. Provisions have As a result of this 1sek of informa- The Traffic Guidance 5/26/86 been made to tenue an Ess Lion, the tipeJiment probt:ss were not message in the event that analysed in a timely fashion and Table Top TT-6 has been modified to changes to evacuattom routes incomplete equipment was dispatched to are necessary, handle the gravel truck taps,diment in incorporate the i l the field. Internal communicatione changes to the pro- 'I cedarse. _ Attachment laternal communications withis procedures should be reviewed and the LERO EOC regarding assese-revloed as necessary to ensure that 1. ment of and response to evacua-leformation on tapedimente is promptly tion tapediments have been passed both up the chain of command to adequately addressed through . the Evacuation Coordinator and downward modification to the procedures and laterally to all lead courdinatore (esp. OFIP 3.6.3. Traf fic Con-under the Evacuation Coordinator and trol). The Evacuation Route their staffe. Additionet training to Coordinator to responsible for needed to ensure that the procedores, obtstalag periodic updates free whether

new or current, are property

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8 TAtt2 3.1 SHORENAM NUCIEAR F0WER' STAT 10ll - SCHEDULE FOR CORRECTING OEFICIENCIES OR AREAS REQUIRING CORRECTIVE ACTlost j

February 13, 1986 Esercise IARO 50C (Cont'd) Page 3 of 16

3 - 3.n

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iii laI ma ji LERO Respunse (AdTION) 131 If FDIA Evaluation of JARO Response I$ 1}t juE No. RAC Riceemendation for Corrective Action ]gy There was some confusion regarding the ARCA The FAA vill be con- 5/26/86 A. letter of agreement with the 1 1 2 F.I.c FAA has been withdrawn by methcJ for notifying the Federal tacted as part of the FEMA FRERP respones. LItio, since respoestbility for Aviation Adataistration (FAA). notification of the FAA has

The plan sad tratates (1) The 12RO procedures should be re- will be modified been shifted to the U.S.

viewed and revised as necessary to accordingly as part of Departeemt of Treasportation ensure that a point of contact Rev. 7. (DOT) via FEMA as recommended with the FAA has been destgested. in the review of Rev. 5 of the , plan. However, based ea ! results of the Feb. 13, 1986 (2) The BARO EOC staff should be eueretoe and the RAC review of trained la the appropriate pro-cedures so that the FAA can be subsequent plan rev&olome it to a

       !                     notified in a timely amaner.

recommended that IARO notify FAA directly (see comments for element F.R.c in the plan review of Revision 8). la order to assure the most timely nottftcottom of FAA, 12R0 should egets obtain a letter of agreement with FAA. Treintag of 12R0 personnel responsible for notificetton of FAA should be verified at a future exercise. e 4 O V

1 1 TARLE 3.8 *

8800REHAtt 133 CLEAR F0tfER STAT 1001 - 808E0012 FOR CORRECT!IIG RdFICtKNCIES OR AREAS REQUIRIIIG CORRECT {WE ACTiosi
February 13. 8986 Esercise LERG EOC (Cont'd) race 4 of 16 q~ *0 Sr

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, w u g LERO Respusse (ACTIOII) FE804 Evaluation of J.RRO Beepense If see. RAC Receemmendelles for Corrective Actica s - Stace there are, no procedures for ARCA The procedure vitt be 9/1/06 The plan has been endtfied to g g 3 E.8 notification of the long Island modified in Bew. S to include mottitcattom of the F.I.a Imag Island Battroad (LIRS). Ballroad (LIRR) in the rise, the LIRR include a phone ca11 was not mottfled during the esercise. to the LIRR. LERO Frecedure Ofir 3.3.2, Fage 4 of training will be modt- Attachment 4, teatructs the (1) The LRRO procedures abould be fled accordingly. Sepport Services Coordtaator to contact the LIRR at the Alert, revised to establish a point of contact and a means of motifying or higher emergency closelfica-the LIRA. tion, and to regeset closure of parts of the mainline if evac-(2) The LERG EOC staff should be matione are called for is tratned in the revised procedures certain sectors. l ro that the LIRR can be notifled ,

                                                                                                                                        ,,     g, 3,3            ggg,, gg,                   ,

I" " "I""II "*""*'* Imag totand Battroad will be notified at the $1te Area Ener-gency and/or General Roergency ECLa. The LIRR obould also be added to rig. 3.3.3 and to the notification disgree shown in Fig. 3.3.5. These planetag provisione are adequate but point of contact and telephone

                                                                                                                                   ,    aumber for motificattom of the
                                                                                                                   .                     appropriate LIRR official (s) should be documented with a letter of understandtag between LERO and the lang Island Batt-road.      Training of LaRO per-sonnet responeable for notif1-
     *                                                                                                   -                               cation of LIBR should be I
                                                                                                                                         -- 811ad ar = f-tess-easse&a               -

TABIA 3.1 suoaEllAN NUCl. EAR POWER STAft001 - SCHEDutA FOR ComaECTIII0 DEFICIEleCIES OR AREAS REquistsIG CotaECTIVE ACTient February 83, t986 Esercise lea 0 EOC .(Cont'd) Pag. s f 16 1 ! l . . 2_3 .L.n_-

                                                                                                                                                                               .o B_r-l
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!           no.            .AC .ec      d.o    fo, C.,,.u i.e Aco -       3:y       uu. .e.r..e ( ACno.3         =

rs ... ao .f u .e. - .e :3 j}o3 6 i.io n e use .e.. .t .tstu. .a to o,e A.CA ue u.e a.... .t ,iiin u.0.. .aitic.ti u A i

a. cide.t ...e...e.t ar.. i.a to acco.- .o.rd .iii 6e .odified a..e. .t . tate. fo.r,ed do.e to 4 .odate both DOE BAP and Litto f told to acco odate data acca==aJata data fro. both 4

                           .onttorlag data. There mere not enough                   fro.       both     DOE-RAF           DOE /BAP tea.e and LILCO t.a colu.no on the teard to.k.ep the tuo                     teiss and LitIO tea.a.                1. adeqisate.       Tratalag of the I                           (2) sources of data separated.       lea 0                                                    LERO does a..e. ent .taff to shoute enlarge the do.e a. sees.ent                                                           . eke eff.ctive        is.e    of the statu. board to acca--~Iste a clear                                                           .odified state. board .hould be separattoe between the data reporte                                                            evaluat.d at a future eseret.e.

i fro. the DOE RAF and LILCO field . .onitoring tea.a.

I .

O i l l _e_ _ e_

1

                                                                                                                                                       !           'l TABLE 3.1                                                               1

SHORENAM NUCt. EAR F0WER STATION - SCHEDUIA FOR CostaECTIIIG DEFICIENCIES i on AaEAS REquittNG CURRECTtvet ACTIGet February 13. 1986 Esercise 12R0 EOC (Cont'd) Fege 6 of 16 2.- I _a :-

                                                                -                                      e                                                 .1-          =a=
                                                                 --                                  u. . .

e..- uo i 3:- z.- t-3 E,i gle. c BAC Secommendation for Corrective Actles 333 fgh 1250 Respusse (ACTION) 21#

                                                                                                       "            FEMA Evaluatima of J. BRO Seepense     3 41 3 y, 5     I.10  The dowewind distance of the sample wee     ARCA     All     meterial     for    9/l/06         Procedure OFIF 3.5.2, *Section         A           1 F.l.d incorrectly reported me 7000 meters                  transeteston of field                      3.5 has teen revloed to specify 4                     instead of 700 meters for one of the                 date will be reviewed                      that all dietsaces repceted by i                     thyroid doses reported by a DOE RAF                  to ensure 1.ERO and DOE                    DOE-RAF    tease     are 'to   be i                     itold moattorlag team. Ttile error wee             practices     are   con-                   recorded la a11ee.

) caused by a decimal point staplaced eletent. To be ta-t during the converelos of the distance cluded la Rev. S. The plan modifications ade-I units and meant that the initial quotely address the emeretse calculattom of thyroid does based on . tenue. Replenestation of thie l, this measurement was 9000 mRea/hr 'at . change should be evaluated at a

3 4.3 miles downwtad instead of 9000 future eseretee.

, maem/hr at about 0.5 ettee downwind. j l About five (5) s', mutes elapsed before thte error was found and corrected. l A!! dowewind distances from the field i should be reported constatently la either miles or meters. 9 l O O I J h V

I *

TARI.E 3.t l

                                                                                                                                                                                                                        'f SHORENAM NUCLEAR FOWER STATION - SQlEDUL.E FOR C01RECTlHG DErtCIENCIES OE AREAS REQUIRING CORRECTIVE ACTION February 83, 1986 Exercise 1.Emo EOC (Cont'd)                                                                        Page 7 of 16 5n-i. n                             =8                                                       ..
                                                                                                                                                                                                                  $$        .E ;

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=aa . 1.,, :. 3., .-
- -o oo s :" ... -t g No. RAC Recommendation for Corrective Actica jg LERO Respunne (ACTiou) FEMA Evaluation of.1.ERO Besponse I[ uj O 1.50 During the reporting of the initial DOE ARCA 1.ERO procedures will 9/1/86 The plea has been modified. A I RAP thyroid doses, only one ftold be reviewed and a mots 0FIF 3.5.2, Section 3.6, to re-measurement, the 1400 maea/br measure- added to ensure better quire that when field date is sent made at about 1204 at two (2) coordinetton and received, the data is identi-miles from the plant, was available. accurate use of field fled as as actual measurement This value vea used at the R. ERG EOC to data. To be tacor- or as entropolated data. All entrapolate doses at other distances. porated-la Rev. S. entrapolated data are now to be These entropolated data were reported posted under " projected data" *

as actual measurements at other die- on the status board.

tances rather than as projected data on

the dose assessment status board. It The plee modifications ade
I took two and one half (2.5) bours to quately address the esercise

       !          Edentify and correct this error.                                                         1.ERO                                                             tesue. Implemsstattom of this reporting proceduraa should be reviewed                                                                                                                   change should be verified at a to ensure proper coordtaatton and                                                                                                                          future exercise.

proper reportinh. e O W W

d . TAst.E 3.1 l l SHOREHAM NUCI. EAR '.4ER staff 0N - SCHE 001.E FOR CORRECTING DEFICIENCIES a AaEAS REQUIEING CORRECT 1VE ACTION February 83. 8986 Esercise I.Emo EoC (Coat'd) Pase a of is SI^ ,' e GO $G3 a st ou t -

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w -u. I rg =gg He. RAC Recommendallen for Corrective Action fg 1.ERO Response ( ACTION) FEMA Evaluation of J.ERO Response E3 oj 7 1.10 Although he later quoted the FAC ARCA The Health Servicae 6/19/86 Lit.(W e commitment to provide A I correctly when asked to do so by a Coordinator has been the lleelth Services Coordlastor Federal evaluator, during a briefing provided with review with review material on the use held at the E.Z30 EOC at about 1880, the material oa the use and seeming of the EPA FAC's is Health Services Coordinator misstated and meanlag of the EFA an adequate response. 14:11e the EPA FAC as helag mandatory evacu- FAC's. this is not sa tesse requiring ation when the projected thyroid does

revistoa of the plan, the uns five (S) Res. TA. Health Services effectiveness of the Realth Coordinator should review the EPA FAG Services Coord!aator's tralstag gulds.sce la order to avoid any poestble should be evaluated at a future confustoa that could result due to mis- exercise.

infureation givna during briefings. e t e 9

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g OR AREAS REQUIRING CORRECTIVE ACTIust February 13 t h Esercise IARO EOC (Cont'd) Page 10 of 16

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                                                                                                                                                                    =ag Iso. RAC Recommendelloa for Corrective Action    jg        LERO Response ( ACTIONI
                                                                                                                 FEMA Evaluation of .8250 Response        I3     .k h-E.2 There was a delay of about forty-five        ARCA     Procederes and trata-          9/l/86    h plan has been modified (See            A         I 9                                                                                                      0 Fir 3.6.3 Sections 3.1, S.2.4 tag vill be revised to (45) stautes between the 12a0 EOC's                   allow flexibility la                     and 5.4.2), to assure that all                                     ,

first attempt to have Route Spotter ,

                    #1005 verify the fuel truck impedteent                personnel assignment.                    impediments to evacuation will                                     !

and the dispatch of that spotter free This will ensure that be promptly reported, that l the Port Jefferson Stagleg Area. Tlata permannet are lamedt- addittoaal personnet are die-delayed steely verificattom of the stely dtepatched for patched la en expedited manner, lepediment. Personnel need to be tapedissat verifica- sad that there is coordination trataed la the d slopment of alterna- tion or other evacua- between the Traffic Control Co-tive sppsoeches when delays are tion esigency; ordtentor, the Evacuation Coor-reasonably saticipated la the field diastor and the Evacuation' vertitcation of tapediments to evacua- Route Coordtaator. N Evacus- *

         !                    Development of alternatives                                                           tion    Soute    Coordlastor    la tion.

ehoulJ 1actude comeuttation be' tween, at responsible for obtstalag peri-a minimum, the Evacua. ton Coordinator odic updates from Evacuation and the Evacuation Route Coordinator. Route Spotters ($ee Celt 3.6.3, Section S.6.7). h plan modt-fications adequately addrese

                                                                                                           ,        the eseretse       tenue.      h effectiveness of tratalag of the Evaluation Route Coor-dtastor and communications with                               ,

Soute Spottare v1. Stastag Arese should be evaluated at a - future exeretes. A e

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{> I l TAB 12 3.4 ' l SHOREHAPI NUrt rae POWER STATIOtt - SCNEDut2 FOR CORRECTING DEFICIENCIES OR AREAS REQUIRING CORRECTIVE ACT10N '

February 13. 8984 Esercise ENEMCENCT NEWS CENTER page 1 of 4 s.^ Zn 8 -

                                                                  *3 c                                                           ,d*        OCO-3=                                                          ==                                                                                  10.                                                            ==-         3w.3 lal                                                        .$ E ~ .

13j UI 1 *. saa it ::: =5t us. RAC secommendation for Corrective Action jgj t.ERO Response (ACTION) FEMA Evaluation of.3290 Respea w I3 3j 1 C.4. s. Insufficient copytag capabilities at D Copylag machlaes in 8/8/86 The plan has been modified to 1 1 C.4.c the ENC resulted la delays in the the ENC are being create as addittomal position, distribution of taformattoa. These evaluated for upgrade 12RO Spokesperson, and addt-delays af fected the followtag two (2) sad replacement as tional staff have been assigned areams necessary. *

                                                                                                                                          ,,                                        to assure better coordtaation of taformattoa in the ENC. The

Hard copies of ERS messages were not In order to 'espedite 6/19/86 I220 spokespersaa is respons-provided to the media in a timely dissemination of to- ible for coordinattag' the re-sanner. formation, procedures lease of information working in have been revised. conjunction with the County e tumor control personnel were not Essential emergency Executive or his designee. if able to smauer questions received information will be he chooses to participate. The I from the public because they were put la summary fore 1230 spokesperson will repre-not given accurate up-to-date status and simultaneously sent 1280 at press conferences.

reporte, transettted via com- press releases are to be dis-puter to the ENC and talbuted to utt18ty, governesat 12R0 should 'make provisions for rell- all rumr control sad media personnel at the ENC. sble and rapid equipment to reproduce. locations. ta hard copy, a!! appropriate messages As provided la OF1p 3.8.l. Sec. for distribution to the ENC staf f. 5.2.4 changes la toportant emergency Satornation util be electroelcally transaltted to Rumor Control District offices I~ and call boards via TSO print-f out (also see OPIp 3.8.1. Sec. 5.3.4). A O w W I

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1 a 1 l TABLE 3.4 SMOREHAM Injen F AR FOWER STATION - SCIIEDULE FOR CostECTiss DEFICEFJICIES

'{

OR AREAS REQUIRIDIG (DERECTIVE ACTtost , February 13. 8946 Esercise , rasencEmCT senes CEmTE (Coat'd) rase 4 of 4

a.^ - a s-

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a BAC sec - h tien for corrective Action

-u!

za jgy LERO mesponse (ACT1010) It" FDen Evaluation of Mae sospense II :1t 3j see. Some hard copies of ESS messages that AaCA The emergency press 9/8/86 .The plea has been modified. A 1 3 N/E were provided to the press contataed releases, which do not OrtP 3.8.l. Sec. S.4.4 to - entraneous taformation (clearly marked contata deleted mate- tequire the LERO Spokespersea for deletten) that should have been rial, will be posted to have a staff member die-entsted to avoid possible confusion. la the ENC. tribute hard copies of correct Nard copies of EBS messages posted la press releases (EBS messages) the ENC for use by the press should which have been received via contate only that faternatten which was the TSO system. broadcast to the public. The plan medifIcatione ade-aguetely address the exercise 1ssue. Tralming of FIO staff i I et the EaIC should be evaluated

'                                                                                                                                                     at a future exercise to ensure that    entraneous   taformation j                                                                                                                                                     f rom ESS message draf ts is not taedvertently given to the media.

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                                                                                                                  .                                                                                                                                                                            [

TART.E 3.6 j e l SHOREHAM NUCIJAR POWER STATION - SQlEDULE FOR CORRECTIIIG DEFICIENCIES OR AREAS DEQUlitlN3 CORRECTIVE ACTION . February 13, 1986 Emircise FATCHOGUE PACING AREt. tage 1 of 19 n q3 5%O S :t ^d

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I se- . g ~. - - : a ::: .ef" a : g1.. ast co- . g ggj Ilo. RAC Recommendation for Corrective Action 1480 Response (ACTICII) FEMA Evaluation of.LERO Response If uj 1 J.9, Rua drivers were not dispatched untti ARCA There is no require- N/A FEMA and the RAC have reviewed g g two (2) hours after receipt of the $tte ment to dispatch bus addittomat informattom supplied J.80 3 two by Lit.C0 regarding this issue Area Emergency ECL declaration. drivers within hours of a Sita Area and have changed the cristaal (t) An addittoaal area should be Emergency. The dis- rating la the report free a Deficiency to an Area Requiring established for the distributton patch of bus drivers , of dostmetry to reduce Rua Driver was wit,hin the times Corrective Action. As dis- , detailed la the LERO cussed la the esercise report, processtag time. plan. See analysis of the delays in dispatching bue (2) Additional trataed staf f should be dispatch. Attachment drivers were due to issuing provided to the Rua Dispatcher to 2. destaetry and to delays is assist him la deploying over three briefing the number of per-g sonnel, bus drivers and hundred (300) drivers and Transfer transfer potat coordinators, Point Coordinators who are from prior to dispatchlag. FEMA deployed the - Patchogue Staging Area. recognises that there is no requirement within the plan to dispatch bus drivers from the

                                                                                                                                                                                                                      -                        Staging Area withis two (2) hours of a Site Area Emergency.

FEMA sloo recognises that step 5.3.4 of Ortr 3.6.4 requires the Rue Coordinetor (at the LERO EOC), as directed by the TransportotRoa Support Coor-diastor, to begin implementa-ston of bus operations at the Site Ares Emergency; and that the first buses are to be dis-

                  ;                                                                                                                                                                                                                            patched    from    the   Transfer reinte no sooner Elian one (t)
                                                                                                                                                                                                                 .                             bour miter the

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                                      ,   e .r e aeygnir mce rtfdno ra o yd                    .at    n iMcS tb e e o e (r t Et       i af rc ps eaf t ect S

I C mih ssai!d ywt r i hFa p dl sr h usa g ol c i neg eht eini cqnp N cbt esaravee t eel t r sepaaeel t eas w E g euarsrl t euh ohbi osihxvrhhl ad ri l I g r ppaaTaS sbt at t awfidt eat t t apaTdt C g 1 F E D G ,4 N I T c.0* tu CN EO 31 i I R R T OC ) C Ae s N Ei O R O IVcArI I T F Te C E CxAR A L REE G ( U N e

 -      6. D R6 3E t O8 I                 s C9 AC                 n u

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Y t TABLE 3.6 .

                                                                                                                                                          *l'
                            .               SHONEHAM NUCt. EAR F0WER STATIOU - SCHEDULE FOR CORRECTING IEFICIENCIES OR AREAS REQUIRING CORRECTIVE ACTION February 13, 1986 Esercise FATCHOCUE STACING AREA                                                             Page 3 of 19 s.^                .                                                                   Z:              a-c                                                .d*           *O C U
                                                             *m1.,                                                                                                   u-a                                              ou                                ==.
                                                                                                *t cou              4,*

I E*: di 12" I t" c .!E~3 a n: sp;tE me. RAC tecmadatlea for Correctiv- 'rtlee ]gy t.ERO Response-(ACTION) FEMA Evaluat inn of J.ERO Respuase 33 i, i Cont'd , by Section 5.5.8 of 0FIF 3.6.4). Rased on further - analysis of leformation made available by Lilio, FEMA deter-mined that the Evacuation Co-ordinator did not issue instructions to prestage buses to the Transfer Potats untti one hour and tuenty stautes after the Site Area Faergency was known to personnel at the LERG EOC (see page 86 of l LILCO's First Request for Q Adelssione and Third Set of Interrogatories Directed to Suffolk County, New Tork State, , and the Town of Southampton, dated December I, 1986). This is contrary to Section 5.1.1 of 0FIF 3.6.4 which requires the , Manager of local Response to direct the Evacuation Coor-i dinator to begin the prestaging l

                                                                                  .                        of buses to some or all of the l                                                                                                           Transfer Fotato upon declara-I                                                                                                            tion of a Site Area Emergency.

Hence, LERO did not follow the plan (i.e., uttltre available resources and/or make use of training) and thte exercise tesue ut!! _ remain unreso_lved

        .-                                                                                                 uussa sua paan am arvases to I

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                             .                                =

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                                                                             ?a i                                             suome12                         j

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1 I b b t TASt.E 3.6

SHOKEHAM NUCtJAR F0WER STATION - SCHEDUtA FOR CORRECTING DEFtCIENCIES OR AREAS REqutRING CORRECTIVE ACT10N February 11 1986 Esercise FATCHOCUE STACING AREA (Cont'd) Page 5 of 19 hh .5, O Ha 5n

                                                              =-Q
                                                                                             .   .o 3.3 er 4,3 Ec1                                              ::
                                                             -u.             .                   ,eg-a                                       :::
                                                                                                                                             ...          .- g g see.       RAC Recommendatica for Corrective Action     jgj       LERO Response ( ACTION)

FEMA Evaluation of J.ERO Response I$ kuI

                                                                                                                                                         .=   w 2      N/R OFIF 4.7.1 spectites that the calf            ARCA     0FIF 4.7.5 will be         9/l/86    Procedures for security and          A          1 persamaet entrance is to be the Main                   revised in Rev. 8 to                energency utilisattom of the Entrance on the Conklin Avenue side of                 ladicate actue1 flow                 LILCO Fatchogue District Office the buildtag. The entrance actually                of personnel.                        as the LERO Facchogue Stagtag used for this purpose was the one on                                                        Area have been modified in DFIF the north side of the buildtag (Mata                                                        4.7.1 to adequately address Street). Stace the system actually                                                      this exercise      !sene. The used seems to be superior to the Flaa                                                       effectiveness of thee plea due to reduced congesttoa, OFIF 4.7.8                                                       siodtitcations should be evale-should be revised to todicate -ttwat                                .                       ated at a futura exercise.

personnel are to enter the Fatchogue Staging Area through the Main Street

   !            entrance to the but! ding.

8 A A t

b I TARI.E 3.6 , e

SHOREllAM NUCI. EAR POWER STATloel - SCHEntitz Fot CORRECTING DEFICIENCIES OR AREAS REQUIRING CORRECTIVE ACTION . February 13. 1986 Esercise 1

'                                                                 FATCHOCUE STACING AREA (Cont'd)                                                          Page 6 of 19 Ein                                    ,, s

=

                                                                                                                                                      .s-3

30 H" gg" *:. 2.3 #~. *

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              -                                                 . .t a                                1*3" a                                               R. s -      ==~

coa : '8 :: g No. RAC teceamendation for Corrective Action gg 1280 Response ( ACTION) FEMA Evaluation of $ 0 Besponse I$ .k ug$ - 1 3 N/R LERO personnel estered the upper floor ARCA OFIP 4.7.1 Rev. 8 9/l/86 Procedures for security and A 1 repeatedly to use telephones for emer- ut!! be revised to emergency utilisattom of the j gency notificattoa. This practice is indicate that upstairs Lit.C0 Fetchogue District Of fice i aspitettly prohibited by vP!r 4.7.1 phones may be as the 1250 Facchogue Staging (page 38 Stes #3). Elther OFIP 4.7.1 ettltzed. Area have been modified la OFIP should be resteed to reflect the actual 4.7.1 to adequately address practice of usteg telephones on the this exercise issue. The * ! second floor of the ratchogue Staging effectiveness of these plas l Area buildtag. ' or more telephones modificatione should be i should be provided on the first floor evaluated at a future exercise. for 1220 personnel to perform their J' emergency actifIcations. g i i l I i . i 4 + 4 l . 1 - . \- 1 I

0 TAtt.E 3 6 , SHOREllAM NtlCIEAR FoWER STATI0el - SCHEtulLE FOR CORRECTING DEFICIENCIES OR AREAS REQtalNING CURRECTIVE ACT1001 February 13. 1986 Esercise FATCHOCUE STACING AREA (Cont'd) Page 7 of 19 3gn h3 .50 ga a.$ es-4 I g:- -

                                                                                             -       o..

s- g2, g

                                                                                                                                                                          .3   .-
                                                                -u                                                                                           .

a RAC Recommendation for Corrective Action saa i "t" FEM 4 Evaluaties of .t.530 Response a:: Ij

                                                                                                                                                                         =yt gle.                                                      g      LERO ResFww ( ACTION)                                                                              3j 4    N/t   The south door was not locked for           ARCA     Verificattoa          that   9/l/86    Fracedures for security and                     A          1 security as spectfled la 0FIF 4.7.1.                 doors        should     be             emergency utilisation of the A11 doors required to be locked by the               checked by the SAC                     LILCO Fetchogue District of fice Ftse should be vertited as actually                  will be ladicated in                   as the LERO Patchogue Stagtag locked by the Stagtag Area Coordinator               Rev. 8.                                Area have been modified in OFIF or a designee.                                                                              4.7.5 to adequately address                            .

this exercise issue. The effectiveness of these plan modifications abound be evalu-aged at a future esercise. , . i e e l l . 4 > - I

e TA.1 , ,.. ; j j SHoaEllArt NUCIEAR POWER STATION - SOIEDetLE FOR CotRECTING DEFICIENCIES of AREAS REQuia&NG CDERECTIVE ACTiuN February 13, 1986 Exercise FATCHUGUE STACING AREA (Cont'd) Page 8 of 19

                                                            -                                                                                    -%               a Sga                   -

QO 30

            -                                                wt d                               ;$                                      '

3e US~* wuq c== 4 l $2w Ee3 223 E. =- g3 =-- 35

srj

                                                            - 6 c                                                    a!                              me0 arr No.       RAC Seceaumendation for Corrective Action     ]g        LERO Response ( ACTION)             FEMA Evaluat ina of J.ERO Response       3$

S N/R Unauthorised entrance to the staglag ARCA This area of butiding 9/l/86 Procedures for security and 'A 1 area could be achtesed through the open entry is being re- onergency utilisettom of the

fire escape on the second flaor of the visued. A guard wt!! LILCO ratcheg.a District Office east side of the buildlag. The fire be posted at the as the LERO Facchogue Staging escape on the second floor of the east designated ~ location Area have been modified in 6FIF side of the butidtag should be desig- until the factitty 4.7.1 to adequately address

] nated as a guard post in the Flan and review is completed. this exercise 1ssee. The

an individual should be assigned to effectiveness of these plan f staff this guard post. modificatione should be evalu-ated at a future exercise.

t 1 i I l ! e 1 i

                                                                                                                                            -         4

1 a l TAtt.E 3.6 *h - SHOREHAM NUrtrAR F0WER STATION - SCHEDULE FOR CORRECTING DEFICIENCIES on AREAS REQUIRING CDERECTtWE ACTloN February 83, 1986 Esercise . FATCNOCUE STACING ABFA (Cont'd) Page 9 of 19

                                                                                                                                                                  -                                                                                  %        u Sta                                                                              20         .20 g=
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                                                                                                                                                                                                                                                              =a s..                               mAC sec.amendaties t.r Corrective Action                            jgj        LEno me.p.ase (Action)             rEnA cvaimati.a of j.Eno me.p.ase   y g %g

6 J.9, A See Driver took two (2) hours and ten D LAR0's tavastigattoa 4/1/86 The plan has been revised. OFIF A I J.lo.g (10) minutes to proceed from the of the problem re- 3.6.4 Sec. 5.5.13, to require stagtag area to the transfer potat. wealed that destag the bue drivers to show their Another driver went to al.a usong trame- past drt!!s bus dr!- Dispatch Form to the Tramafer for potat, and his statake i.as not vers have repeatedly Potat Coordtaator to ' assure recognised by the Transfer rotat Co- volunteered to go to that the drivers have reached ordtaator. Tet another driver missed a the same transfer the correct locattoa. This segment of an amalgaed evacuation points and bus yards. vertiteattom of arrival at the route. Thus, they had not desired transfer potet is also become fastitar with covered la the Transfer rotat (t) Bus Drivers for general population the other possible . Coordtaster's Procedure evacuattom routes should receive locations. Lilio will (Attachment I, Sec. 7 of 0FIP O tratalog to assure their ability rue " read rallies" to 3.6.4).

to follow directions given to them have the bus drivers so they can (a) follow routes from festitorise themselves These plan modifications ade-the stagtag area to bus garages with other bus yarde quately adJress the esercise and then to tramater potats, and and transfer points. Essues and should be evaluated (b) fe!!ow an asalgaed bene route. at a future esercise. In the future, amer-(2) 0FIF 3.6.4, Attachment 2 (Pages sency preparednese e 13-14) and Attachment I (Pages IO- tratalag v111 force

82) should be reviseJ to require, the use of different respectively, the Bee Driver to t rar. star potats and present, and the Transfer rotat bue yards. The .

Coordtaatar to verify, each Sua Transfer Potat Coor-Driver's ctpy of the sua/ Van Dis- disator Procedure will patehtag Form (OFIF 3.6.4. Attach- tedicate that bus dis-peat 7 Page 62) to assure that patch forma are to be the Bus Driver has arrived at al.a checked upos driver's 2 , proper transfer putat. arrival, A Rev. 7. W

t I 1 TABLE 3.( SHOREHAN eduCIEAR F0WER STATIDst - SCHEDut2 FOR CDERECTING DEFICIENCIES OR AREAS REQUIRING CDERECTIVE ACT10el February 13, 1986 Esercise FATCNOCUE STACING AREA (Cont'd) Page 10.of 19 a %~ s 2 2; S.:i~n

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4.5 E-- .- - : RAC Seceamendation for Corrective Actima

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an o 1.ERO Response (ACT10el) FEMA Evaluation of.LERO 8esponse 3$ u 7 J.9, Traf f te Guides de not have complete er ARCA The Traf fic Culde Pro- 9/1/86 The plan has been modified, A I J.80 g correct Saformation en the appropriate cedure ut!! be eodt- 0FIF 3.6.3 Attachment I, Sec. destinastaa for evacuses. All Traf fic fled la Rev. 8. 10, to teatruct the traffic Culdes should be trataed to advise guides to tafore evacuees to motorists with questions to tune to Etne listem to the EBS radio stattoa . ERS stattee (WAIX-FM) for the latest f for the latest emergency ta-formation. taformattaa en att mattere related to the emergency, tactedtag the location of the Receptima Center. The plan modification ode-quately addresa the exercise issue. The knowledge of traffic guides to tastruct . I evacueen to !! stem to the EBS Statlon for taformattoa should i he evaluated at a future esercise. ! l, .. I . , s l . A A 9 V

C TASt.E 3.6 h e' l SHOREMAM NUCtIAR p0WER STATION - SQtEDUI.E fur CoattECTING DEFICIENCIES 08 AREAS REquittNG CDRRECTIVE ACTiust

February 83,1986 Ezeretse FATCHOCUE STACING Aara (Coat'd) Page 18 of 89 s . q. T : -

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m.. aAc sece.nea4atie. f., c. tract s Acts.a };y R.Eno me.pi.e.e (ACTION u rEnA E Imati.a .f Asmo se.,.ase 32 a J.10.k Appropriate perseemel and equipment ARCA After road crews are N/A 1.EAO's response to adequate to A 1 were not dispatched to clear the dispatched to their address the issue of tempero-a=Istyle .ekicle accident staulated as field peelstems they priate equipment betag seat to am tapediment to evacuattee. The coenmascate via radio respond to the impedteont appropriate personeel at the Patchogue with the EOC. The problee tetroduced in the euer-Stagtag Area should be trataed to IAnd Traf fic Cutdes at 'clee. Plan revistoms made la request more taformation from the t.Eas the Stagtag Area de response te deficiency R. ERG EOC EDC when 8.pedimente to evacuattaa are not decide which I should be sufficient to en-tadicated. trucks are to be dis- sure timely response to evacua-patched to a particu- tion impediments. Procedure tar impediment. OtlF 3.6.3, Sec. S.S.10 has been -added and now makes clear that esce dispatched from their prestaged location to respond te na impediment probles, road 9 crews are to be la radio coa-

                                              .                                                                       tact with the EOC. The Road Crew Frocedure (Attack. 2 of 0FIP 3.6.3, Sec. 6, page 2 of

2) specifies that Road Crewe ,.

are to contact the Road

                                                                                                            .         tagistics Coordtaator at the
                                                                                                .                     EOC if problems arise.          The
                                                                                              .                       effectivemens and 1.130 worker knowledge of these procedures should be evaluated at a future exercise.

e A W 1

l I e TABLE 3.6 , l

ewwrwag asseg ram POWER STATIcel - SCttEDull Foa CotaECTilec DEFICIEstCIES

          .                                                      Og aRFat REqtllR13C CDSRECTIVE ACTIOff                                                                      .

February 83. 1986 Esercise rATCuocuE sTactisc aaEA (Cant'd) tage la of 39

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me. BAC asehties for Caerective Action 3gj LERO Respusse (ACTICII) " FEMA Evaluaties of J.ERO Response I$ .k .h. O J.to.4 teatr=cata=* for the det.or of the - amCa The Trameter rotat s/s/s4 The taso response that trameter a 1 tastitettamatised maht!!Ey-tapaired hos Caerdianters' tratalag Fatat Caerdtaaters tratalag to proceed to the Receps tee Center were material will be modt- will be modified to adequate. eet properly transaltted to the Bee fled to essere they The effectiveness of thte Driver at the Breekhaves httenal relay lastructlana tratalag should be evaluated at 1.sheratory Trameter rotet. Transfer free the SAC's to the a future esercise. rotat Caerdtaaters should he trataed to bee drivers. fellow teatraccleas forthcoelag free , the stagtag area regarJ1ag directione that are to be gives to special pepe-1sttee evacuattee reste Sea Drivere, atace they are trataed to reters to the

    !               traneter pelat for 1.netractions as spectiled la the tito Plan.

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I3 nt g ua 3 J.ta.h amitter et the tus (2) congregate care mara The Bad Cross has ab M/A The revised letter of agree- I I f acilitie s acttwaged for the February reopenetht t s ty fes meat. App. 3, pages 5-81 to S-83, 1944 eserctae are SJeestfied la the estatatalag a IIst el lid, appears to say that the latest sehntastan of the 1230 Flaa. congregate care ces- Americae Bed Cross has not The Flas ehem1A be rewtaed to tactode ters. Stace the Issa agreed to respoed to a radte-all facitttles tan ==aaa far use se to revised pertedt- Regical emergency at Shoreham ahatter facittttes dettag a reite- cally (as particulas (see !!aes 1-4 pages 5-Ita). . Eastemt emergency at Surs. These centers became en- . Fase 5-llh tapttee that the , factittias ehem1A be tactoded ta' the asettable er sa mes American Bad Crees saly works ties attached sa t184*a letter of - are added) 1: with and through the govera-agr - e utth the Amestcme Bad Crees. umeld be taappropriate meat. It else states that to factede the Itst is lettere of agressent between I the 1233 Flaa. In- the American Red Crees and , _ s t ead ,' App. 3 to Eb oumere of a fact 11tw to be used plae will be restaew as a abetter will be entered to contata a met late .: *he Etae of as letter of agresemos tecident. Th'.a policy is me-with the Red Crosa workable. The meet material which utit state thes embattted for App. 8 raises the Sed Crees will many speestiene conceratag the metatata se u M e-data participettee of the American Itst of congregate Sed Crosa la a Sherskan care centers and thai tacident, met only la the the !!st will be end. operation af.sheltere, best also available to t he to connection with EOC e ' appeepriate federal participattes. It is FDta's

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ML20212K419: Difference between revisions

Latest revision as of 08:16, 5 May 2021

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Text

Dear Mr. Kowieski:

Subject:

Subject:

Dear Mr. Daverio:

SUBJECT:

Dear Dick:

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Dear Mr. Speck:

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Dear Mr. Dircks:

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ML20212K419: Difference between revisions

Latest revision as of 08:16, 5 May 2021

Text

Dear Mr. Kowieski:

Subject:

Subject:

Dear Mr. Daverio:

SUBJECT:

Dear Dick:

SUBJECT:

Dear Mr. Speck:

Subject:

Dear Mr. Dircks:

Subject:

SUBJECT:

REFERENCE:

Navigation menu

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