ML19207B798

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Comments on Draft NUREG-0553 Re Funding of State & Local Radiological Emergency Programs.Citrus County,Fl Will Deploy Version on Ring Sys Only If R&D Funds Are Provided
ML19207B798
Person / Time
Site: Crystal River, Crane  Duke Energy icon.png
Issue date: 05/17/1979
From: Allen G
CITRUS COUNTY, FL
To: Salomon S
NRC OFFICE OF STATE PROGRAMS (OSP)
Shared Package
ML19207B799 List:
References
RTR-NUREG-0553, RTR-NUREG-553 NUDOCS 7909050289
Download: ML19207B798 (4)


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Citrus County Department of Disaster Preparedness GEORGE J. ALL EN. ClatCMa Cwnwse Sure

'%ermess. F or ca 32650 Of fice Phone G04 726 6500. E esion 10 m P"one (9048 '35-512o May 17, 19 79 Mr. Stephen N. Salomon, Ph. D.

State Progra=s Officer Of fice of State Programs Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Salomon:

Ihe following co==ents are submitted for your consideration concerning the draft report "Beyond Defense-in-Depth."

Part I, Executive Summary: Some of the information and ideas presented are refreshing and present a new outlook.

I feel the risk of a meltdown is being over emphasized. Chances of a nuclear war are more likely. Next conth I will be going to Japan and most A=ericans can't imagine that the two cities there have rebuilt from out atomic bombs.

I am not quite sure what and whose " pre-ferred approach is recommended" and what the alternatives are.

While agreeing with much o'f the report, I as not sure I would support the SS =1111on for 10 NRC Regional Offices to act as a big brother. The more agencies involved the greater the confusion, in-fighting and costs in radiological planning and response.

While I am not affected by your authority or responsibility on-site, I have some reservations about NRC approving local off-site plans. While not an attorney, isn't the Board of County Cocaissioners an extension of the State Legislature? Doesn't the responsibility for plans and evacuation rest with the local and State Government ? What about State and local govereign rights?

Would it be possible for a local director to stall the plan development, keep-ing a half billion dollar nuclear plant shut down? The industry should not be subjected to such possibilities.

While the NRC has regulatory authority on-site, it should re=ain in a technical assistance role off-site.

Citrus County's plan was a part of the State Radiological Plan, which has been concurred in by NRC.

Mos t locals would probably welcome NRC assistance in obtaining the proper kind of dosimetry and survey instrumentation. Civil Defense CDV-742 0-200 R dosimetry are not practical for nuclear reactor incidents.

The CDV-138 is not available in sufficient quantities or at reasonable prices (COV-742).

Perhaps NRC should buy instru=entation in bulk quantities and then sake it available to State and local government at cost.

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Page Two Mr. Dalomon May 4, 1979 The statement about 100 percent Federal funding for the director, with a

$20,000 mini =um salary, I read with interest.

In some states it may help to attract a better staff, but Florida Counties have adequate and dedicated staffs.

Some need training, which is an important part of the NRC Program.

Most could perhaps coccand higher salaries in other fields but feel dedicated to the program and have a sense of job accomplishment. The cost estimates presented exceeds the entire annual budget for Defense Civil Preparedness Agency (DCPA).

Chapter 2: Your statement that the " Civil Defense Program is far from complete",

is very accurate.

It is unfortunate that so many view Civil Defense as a man with a hard hat, whistle and a bucket of sand.

Even The Honorable Robert Graham, the Governor of our great State, belie,ves Emergency Operating Centers to be a place where Government officials hide in the security of the E.0.C. while the public is unprotected.

Let me coe=end you for viewing the EOC as the nerve center (Communi-cations, Command and Control) that may save the unprotected public.

The importance of tying all communications together for' effective coordination cannot be over emphasized.

Co=munications was out for hours during the Jamestown flood.

How many lives would have been saved if effective co==unications could have been maintained?

I will be writing in an ef fort to bring this =atter before the Nation-al Governor's Association this Fall.

Mr. David McLaughlin with the President's Reorganization Project could brief them on the FEMA Concept and the problems with fragmented operations. You may be in a position to provide some support or input in this area.

Chapter 3: Reference was made concerning a need for a better system for notifying off duty personnel. Communications and low level radiation instruments are needed.

Disaster Preparedness budget requests will list items contained in the draft report:

Radiological instrumentation (Low-Level)

$5,000.00 Portable 'Jalkie-Talkie Systec 5,000.00 2 channel with repeater for use of Monitorings Teams thru Cocmo Van Protective Clothing & Equipment 1,000.00 SOAA Storm Alert Radio Sets (100 ea) 4.000.00 Pagers for Coc=issioners/ Consitutional Officers / Staff for EOC

  • l,000.00
  • Includes EOC Staf f Only-Others to be included in their respective budgets.

Since discussing a proposed siren system with you for the Plume Exposure Pathway, I believe that the SOAA Storm Alert Radio =ay be less costly and more effective. One hundred radio sets at $40.00 each would provide ample coverage at this ti=e.

If approved, each home in the Plu=e Exposure Pathway would be issued a radio to receive warnings for all emergencies.

Page Three Mr. Salomon May 16, 1979 I agree with your statement that "very few local of ficial's have kept good records of manpower." This is in reference to liaison meetings, analysis, writing, reviewing and finalizing such plans. At the local level so many plans are inter-related that it would be difficult to break it down for accounting purposes.

In my previous paragraph on the NOAA Storm Alert Radio System-it would &lso be used for severe weather warnings i.e. Hurricane, Tornado, etc, so how should I break down the costs. The cost of maintaining good records in this area must be weighed against the benefits. If additional record keeping is required, additional man-power would be required.

Perhaps a full-time person to plan, train, exercise and develop resources to fulfill local government responsibilities with regard to nuclear plants would be desirable.

Chapter 4: This county believes in the economy of volunteer particpation while the paid personnel of Citrus County Sheriff's Department, Health Department, Road and Bridge Department, Human Services, A'griculture, Sdhool Board, and the City of Crystal River do a great job, I am particularily impressed with our volunteers.

Mr. Dean Freeman and Mr. Lane Stark are our RADEF Supervisors. A local Citizen Band Radio group called the Citrus County Communications Task Force do a great job of radiological monitoring and com=unications.

Connell Heights, DeRosa and Crystal River Fire Department handle decontamination and their response has been outstanding. The main complaint cf volunteer groups is that the training programs seldom have courses available and convenient for volunteers.

I completed the Radiological Emergency Response Operations Course about a year ago, which'was excellent.

The other me=bers of our response team have been unable to obtain space for attendance. Your assistance in this matter would be appreciated.

I believe that decision making and control should a joint responsibility of State and local govern =ent.

The Board of County Commissioners have a responsibility to the citizens of this county to protect their lives and property. We should not rely heavily on industry or State for proper judgement. We need a minimum capability to advise our citizens of proper protective actions. While I view it improper for industry to be shutdown for lack of a local plan over which they have no control, our primary responsibility for such a plan rests with the local government.

The Scard of County Co==1ssioners having this responsibility, should assure that a suitable plan has been developed to protect the public.

I don't advise counties to invest in Atocospheric Release Advisory Capability (ARAC) or ring systems.

The survey teams with low level radiation instrumentation are the best choice for local government. The computer syste=s and the ring systems-would still require some monitoring by survey teams to verify projections.

The cost is S100,000.00 or = ore and the state of art has not been developed and tested as fully effective. We have had short response times for deployment of survey teams and with i= proved co==unications they should be ve ry ef fective.

Citrus County plans to deploy a version of the ring system only if it is provided with Research and Development Funds.

A copy of a letter from the Board of County Co=misisoners, supporting this Research and Development Project is attached. While the project has merit, radioactive gases may leap or jump the instrument, as a result of at=ospheric :enditions.

In our situation, Ruskin can't accurately fo recas t our weather condtions, which could have a great inpact on decision =aking.

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Page Four Mr. Salomon May 14, 1979 Citrus County Plans to take a positive approach on its planning. Copies of the overflight photos have been requested (copy attached). When received we plan to upgrade our information files on area residents in the Plume Exposure Pathway.

While not limited to a particular distance, we intend to coc=unicate with every family that lives within 5 miles.

This com=unication may be in the form of a liaison visit which is most desirable. Telephone or written communications may be utilized for those not home at the time or for other reasons.

The purpose is to explain protective actions in the event of an emergency, inform residents of their quadrant locations, collect data of an important nature and answer any questions regarding the plan. Public information is an i=portant part that is often overlooked.

We have less than 100 families living in the radius, it is proposed that each family be provided with a NOAA Storm Warning Radio which would broadcast wa rnings in the event o f an emergency.

I have included funds for this capability in =y budget request for FY 80.

With low level radiation instrumentation, improved radio coc=unications for radiological conitoring teams, and more emphasis on training, we should have an adequate plan and staf f.

We will continue to strive to improve our response capability, and resources.

While we may not be in total agreement, the draft report contained many items of interest.

It was with great interest that I read about the ten outstanding examples, which included Crystal River 3, of the sites sampled (Page 11-68).

If you should desire furtner information or have any questions, please do not hesitate to call on me.

Sincerely,

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George'kJ/ Allen, Directgh,/

V GJA:rch Enclosurer: 2 As Stated

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