ML101520094
| ML101520094 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/19/2010 |
| From: | Greene L D Lake County, OH, Emergency Management Agency |
| To: | Lesar M T Rulemaking, Directives, and Editing Branch |
| References | |
| 75FR10524 00019, NRC-2010-0080, NUREG-0654 | |
| Download: ML101520094 (4) | |
Text
Board Of Commissioners Robert E. Aufuldish, Raymond E. Sines, Daniel P. Troy Lake County Emergency Management Agency Larry D. Greene, Director/;3- 7 May 19, 2010 Michael T. Lesar Chief, Rulemaking and Directives Branch Division of Administrative Services, Office of Administration Mail Stop: TWB-05.-B01M U. S. Nuclear Regulatory, Commission Washington, DC 20555-0001 131 0-7 0--co)C/!)C/')RE: Docket ID NRC-2010-0080
Dear Mr. Lesar:
Please accept the attached comments from Lake County (OH) EMA relative to Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. Thank you for providing the forum that allows input from my agency.Lake County EMA'8505 Garfield Roa4 Mentor, OH 44060 440-350-5499 Fax 440-350-5397
~2, ~O2/H/~VS Lake County Ohio (Perry Nuclear Power Plant county)DRAFT NUREG-0654 FEMA-REP-1, Rev.1 Supplement 3 Docket ID NRC-2010-0080 NUREG 0654 COMMENT LANGUAGE/REFERENCE General Comment Section 1, Page 1 In theory, the concept of staged-evacuation sounds The study results, documented in NUREG/CR-6953, "Review of good and modeling may show it to be more effective.
NUREG-0654, Supplement 3, 'Criteria for Protective Action However, are there any independent "behavioral Recommendations for Severe Accidents,"'
Volumes 1 and 2, (NRC, studies" that support the assumption people will 2007a and NRC, 2008), (hereafter referred to as the PAR Study), show comply with such a request? Any "real world" examples that shelter-in-place and staged evacuation can be more protective to that verify populations won't just mass-evacuate when a public health and safety than radial evacuation, providing a technical Protective Action is issued. If they do exist, both should basis for improving NRC PAR guidance.
be cited in the guidance.5/17/2010 Page 1 of 3 Lake County Ohio (Perry Nuclear Power Plant county)DRAFT NUREG-0654 FEMA-REP-1, Rev.1 Supplement 3 Docket ID NRC-2010-0080 4-Section 3, Page A-6 Explanation regarding what to do with pets. Informational materials typically state that pets should be left at home or that pets are not allowed at congregate care centers. Research shows that residents are more likely to comply with an evacuation order if they can bring their pet (NRC, 2005; NRC, 2008a), thus, public information materials should not suggest that pets be left at home. Statements such as "pets are not allowed at congregate care centers" do not tell residents what to do with their pets. A statement such as "Pets may be brought to congregate care centers, provided they remain in a pet carrier, in the vehicle, or outside at all times," informs the recipient that pets may evacuate with the family but restrictions may apply. The policy on pets must be discussed with the operator of the congregate care centers, as some operators do place restrictions on pets.Ensure any suggested pet guidance aligns with proposed FEMA guidance on pets. Latest FEMA release is: "Incorporating Household Pets and Service Animal Considerations Into Emergency Operations Plans" (March 2009 Draft)Section 2.3, Page 7 Should licensees be unable to provide this assessment, the prudent action would be to implement precautionary protective actions.Heightened preparedness is one appropriate precautionary protective action."Heightened Preparedness" should not be deemed a valid protective action. The term tends to imply that potential "at risk" populations should be doing something, a perception that could foster confusion and place unnecessary stress on off-site communications capabilities and direction
& control functions when needed most. A better suggestion may be to cultivate a general sense of "Heightened Awareness" beforehand, a planning goal best achieved through robust public education campaigns and, during actual events, timely media releases employing a wide array of communication mediums.5/17/2010 Page 2 of 3 Lake County Ohio (Perry Nuclear Power Plant county)DRAFT NUREG-0654 FEMA-REP-1, Rev.1 Supplement 3 Docket ID NRC-2010-0080 Section 3.5, Page A-9-Describe how authorities expect transit-dependent residents to get to a bus route-Discuss when the bus runs will start, taking into account that it may take an hour, or longer to mobilize drivers and buses-Discuss how long residents may expect to wait for pickup.Such detail related to public information is not practical.
Emphasis should rather be placed on individual responsibility for contingency planning and identification of Special Needs populations.
EPI publications should display exact locations of strategically-placed pick-up points and encourage neighborhood involvement to ensure everyone finds a way to get to one if a Protective Action is issued.Section 2.1, Page A-2 More specifically, the following items are necessary for assembling effective public warning messages (Mileti, 2000): Define a "public warning message".
Is it an EAS message? EAS Messages in Ohio are limited to two minutes by Encoder memory capacity and should contain a specific protection action for the public to follow (Evacuation, etc).Any information in excess of the two-minute EAS message will be disseminated through the Joint Information Center via Special News Bulletins and/or Special Information Bulletins.
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