ML20023C067

Supplemental Testimony of a Lookabaugh & J Benton Re Emergency Preparedness

ML20023C067
Person / Time
Site:	Comanche Peak
Issue date:	05/05/1983
From:	Benton J, Lookabaugh A Federal Emergency Management Agency
To:
Shared Package
ML20023C059	List: ML20023C067
References
NUDOCS 8305090592
Download: ML20023C067 (15)

Text

. . . . . - -- .. .. .

e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES GENERATING COMPANY, ) Docket Nos. 50-445 ET AL. ) 50-446 (Comanche Peak Steam Electric Station, Units 1and2) )

FEMA STAFF SUPPLEMENTARY TESTIMONY OF ALBERT LOOKABAUGH AND JOHN BENTON ON EMERGENCY PREPAREDNESS Q.1. Mr. Lookabaugh, please state your name and occupation.

A.I. My name is Albert L. Lookabaugh. I am the Supervisor, Community Planner, Natural and Technological Hazards (" NTH") Division, Region VI, of the Federal Emergency Management Agency (" FEMA") in Denton, Texas.

l Q.2. Mr. Benton, please state your name and occupation.

A.2. My name is John W. Benton, Chief, Training and Education Branch, Resources Management and Administration Division, Region VI, of FEMA.

t Q.3. Messrs. Lookabaugh and Benton, please describe the nature of the responsibilities you have had regarding nuclear power plant emergency preparedness.

A.3. (Lookabaugh) I am responsible for the review and evaluation of all off-site Radiological Energency Preparedness Plans (" REPS") for 8305090592 830505 PDR ADDCK 05000445 G PDR

-- . _ . , . - r ._ ._ -n. - - _

fixed nuclear generating facilities within FEMA's Region VI. I participated in' FEMA's review of the state of emergency preparedness et CPSES.

(Benton) I was formerly responsible for the review and evaluation of off-site REPS for fixed nuclear generating facilities within FEMA's Region VI. During that time, I participated in FEMA's evaluation of the state of emergency preparedness at CPSES.

Q.4. Gentlemen, have you prepared statements of professional qualifications?

A.4. (LookabaughandBenton) Yes. Mr. Lookabaugh's statement of provessional qualifications was received into evidence at Tr. 5762.

Mr. Benton's statement of professional qualifications was received into evidence at Tr. 5761.

Q.5. What official is responsible for deciding to notify the public that evacuation (or other protective measure) is recommended?

A.5. As we stated in our previous written testimony (Staff Exhibit 203, Tr.5750-51), the County Judges for Somervell County and Hood 1

! County are responsible for notifying the public that evacuation (or other protective measure) is recommended. Paragraph 5, Section A of the Hood County Emergency Operation Plan identifies l the Hood County Judge as the official who is responsible for

{

recommending emergency measures within Hood County. Paragraph 5, Section A of the Somervell County Emergency Operation Plan I

4 identifies the Somervell County Judge as the official who is responsible for recommending emergency measures within Somervell County, and also identifies the Mayor of Glen Rose as responsible for recommending emergency measures for the City of Glen Rose.

Q.6. Please explain why the County Judges for Hood and Somervell Counties were assigned the responsibility to recommend protective actions to the public located in their respective counties, as set forth in the State Emergency Management Plan (" State Plan") and the Hood and Somervell Counties Emergency Plans (" County Plans")?

A.6. It is our understanding that the Texas Disaster Act of 1975 delegates the authority for controlling emergency response to county judges. Accordingly, the State Plan and the County Plans reflect that State delegation of authority to the Hood and Somervell County Judges by identifying the County Judges as the officials responsible for coordinating and directing emergency j response actions within their respective counties. The exclusive j_ authority of the County Judges to advise the public to evacuate is specifically set forth in the County Plans:

A recommendation to evacuate threatened areas will usually come from State authorities based on consulta-tion with Comanche Peak and the Nuclear Regulatory l' Commission. In instances when the situation deterio-rates too rapidly for the State to make an informed decision, Comanche Peak officials may directly recommend evacuation of threatened areas to local .

officials. BEAR IN MIND that State and industry officials can only recommend evacuation to local officials. THE DECISION TO ADVISE THE PUBLIC TO EVACUATE IS TO BE MADE BY THE CHIEF EXECUTIVE (S).

G i

- 4-Manual of Emergency Procedures, Procedures for the Executive Group under " General Emergency," Sec. 1, paragraph III, page 13 of the Hood County Plan and Somervell County Plans.

Q.7. Describe the information, and the sources of that information, that the County Judge will receive regarding:

(1) notification that an incident has occurred at CPSES, (2) possible radiological consequences to the public, (3) selection of appropriate emergency protective measures.

A.7. As discussed in our previous written testimony (Staff Exhibit 203, Tr. 5749), notification that an incident has occurred at CPSES will be sent to the County Judges by the Applicants, the Texas Department of Health and/or the Texas Department of Public Safety.

Notification that an incident has occurred at CPSES will. follow format outlined in Tab 1, Appendix 7 to Annex L of the State Plan.

The initial information which will be transmitted to the County l

Judges will include caller identification and class of accident.

! The County Judges will receive additional information following

the initial notification concerning radiological consequences, and recommendations for protective actions from the Texas Department of Emergency Management, the Texas Bureau of Radiation Control, and/or the Applicants.

Q.8. What was the basis for FEMA's Interim Finding regarding the adequacy of the off-site emergency preparedness for CPSES?

'T*W.. wA--- + *mm5-.,ew-, ,, --,g-.c +-a;.=7o .a_,-4._, -

-*f-e

, g - -ep = .eee-e-, ,. - - > e = - .- o .. - -. , -wa e #

d A.8. As discussed in our written supplementary testimony (FEMA Staff Testimony of Albert Lookabaugh and John Benton on Emergency Preparedness), FEMA's Interim Findings regarding emergency pre-paredness at CPSES, which were sent to the NRC on September 29, 1982, stated:

Based on this initial review of the relevant State and county plans, there is reasonable assurance at this time that the off-site protection of the public's health and safety is adequate.

FEMA's Interim Findings were based on the FEMA Region VI interim findings, which we prepared. Our Region VI findings in turn were based upon our review of FEMA's Radiological Assistance Connittee (RAC) Consolidated Comments for the State, and Hood and Somervell County Emergency Plans. These documents are attached to FEMA's Interim Findings for CPSES.

Q.9. Please describe the RAC, and the RAC Consolidated Comments.

4 A.9. The RAC is a committee formed and chaired by FEMA, to assist FEMA

{ in, inter alia, evaluating the adequacy of State and local emer-

, gency preparedness plans. The RAC is composed of 8 reviewing federal agencies, including FEMA and NRC. Each agency is responsi-ble for reviewing the state and local (in this case, the Hood and Somervell County) emergency plans utilizing pre-assigned elements of NUREG-0654/ FEMA-REP-1, Revision 1. The review elements are assigned to each agency according to the agency's jurisdiction and field of expertise. Each RAC member agency is instructed by FEMA to identify those portions of the state and local plans where addi-tional information is necessary, or where deficiencies exist,

within their assigned area. These findings are compiled by FEMA, and consolidated into the RAC Consolidated Coments. FEMA Region VI then transmits the Consolidated Coments to the state and FEMA headquarters in Washington, D.C. The state and/or local governments may meet with representatives of the RAC member agencies to discuss the Consolidated Comments. The state and/or local governments may revise their plans to address the RAC Coments, and resubmit the plans to the RAC. This iterative process continues as often as is necessary to assure that the emergency plans are in compliance with NUREG-0654/ FEMA-REP-1, Revision 1.

As of this date, the RAC has met once with the State of Texas and the Applicant's consultant who was responsible for writing the County Plans, and has issued one set of Consolidated Coments, which

, are attached to our written supplemental testimony. Additional

contacts between the RAC and FEMA have been made telephonically 1

and by letter in order to receive additional clarification and s information regarding the State Plan and the County Plans.

L FEMA Region VI's coments to the RAC reflect FEMA Region VI's consideration of Argonne National Laboratories' ("ANL") review of l

the State and County Plans. ANL is a consultant to FEMA on ,

emergency preparedness; its evaluation of the State, and Hood and Somervell County Plans were attached to FEMA's Interim Findings for CPSES. ANL's coments were included in the RAC Consolidated l

5 .

i u . ._ _ _ .. _. . . -.. _ _ ._ . .. . _.

comments, even though ANL is not a member of the RAC, since FEMA's evaluation for each review element is consistent with ANL's position.

Q.10. When will FEMA issue its Final Finding, pursuant to 44 C.F.R.

5 350, regarding the state of emergency preparedness for CPSES?

A.10. A Final Finding pursuant to 10 C.F.R. 5 350 will not be made by FEMA until public meetings have been held near the site to explain to 1

the public the content of the plans, to answer questions about the review process and receive suggestions from the public concerning improvements or changes that may be necessary and to describe to the public the way in which the plan is expected to function in the event of an actual emergency. FEMA will also evaluate an exercise of the State, and Hood and Somervell County Plans (presently '

, scheduled for October 5, 1983) to judge the adequacy of the plans.

An Alert and Notification Test will also be made before FEMA issues its Final Finding for CPSES.

Q.11. Please describe the basis for FEMA's finding concerning the

adequacy of off-site provisions for public notification and

~

information for CPSES.

A.11. FEMA's finding was based upon a review of the RAC Consolidated Comments which pertain to compliance by the State Plan, and the Hood and Somervell County Plans, with the guidance criteria set forth in Chapter II, Sections E, F, and G of NUREG-0654/ FEMA-REP-1, Revision 1. We determined that the State Plan, and Hood and

Somervell County Plans generally comply with those guidance criteria. In addition, we also reviewed the Applicants' plan for outdoor audible warning devices for the CPSES 10 mile EPZ. This plan was submitted to FEMA Region VI and reviewed using the Standard CPG-1-17 " Outdoor Warning Systems Guide," dated March 1, 1980.

The plan projected a warning system capable of warning the affected populace within the 10-mile EPZ. We also found that the remaining items requiring resolution were not significant, and did not give any cause to believe that the final State and County Plans would fail to adequately address these criteria. Accordingly, we con-cluded that, with regard to public notification and information, there was reasonable assurance that the off-site protection of the public health and safety is adequate, based on an initial review of the plans.

Q.12. Please describe the basis for FEMA's finding concerning the adequacy of off-site provisions for public evacuation.

A.12. FEMA's findings regarding the adequacy of off-site provisions for public evacuation was partially based upon a review of the RAC Consolidated Coments which pertain to compliance by the State Plan, and the Hood and Somervell County Plans, with the guidance criteria set forth in Chapter II, Section J of NUREG-0654/ FEMA-REP-1, Revision 1. We determined that the State Plan, and the Hood and Somervell County Plans generally comply with these guidance criteria. We also found that the remaining items requiring resolution were not significant, and did not give any

cause to believe that the final State and County Plans would fail to adequately address these criteria. Accordingly, we found that, with regard to public evacuation, there was reasonable assurance that the off-site protection of the public safety and health was adequate, based on an initial review of the plans.

Q.13. Have you read, and are you familiar with the February 21, 1983 letter from George R. Crump, County Judge for Somervell County, to Marshall E. Miller, former Chairman of the Atomic Safety and Licensing Board for CPSES?

A.13. Yes.

t

. Q.14. Please set forth your understanding of the event referred to in Mr. Crump's letter.

A.14. Our understanding of the event referred to in Judge Crump's letter i of February 21, 1983, is that the utility conducted a general f condition check of the equipment and to test the operability of

.i j each siren. At no time was FEMA Region VI told that the entire siren system would be sounded at one time. The test of the sirens f

referred to in Judge Crump's letter was not a complete siren system test required by FEMA.

Q.15. Will FEMA require that the siren system is fully operational and has the capability to adequately warn the public in the 10-mile EPZ for CPSES, prior to issuing a Final Finding on emergency preparedness for CPSES?

b _______

A.15. Yes. After final guidance is developed by FEMA, an Alert and Notification Test of the Comanche Peak system will be made to see that it adequately warns the public in the 10-mile EPZ. This test will be required and must pass the established guidance before FEMA will give a Final Finding on emergency preparedness for CPSES.

Q.16. Please describe the Emergency Broadcast System ("EBS").

A.16. The Emergency Broadcast System (EBS) was established in 1964 to provide the President of the United States with an expeditious method of communicating with the American public in the event of war, threat of war, or grave national crisis. In the last several years, the original concept of the EBS has been expanded so that it can also be used during day-to-day emergencies at the State and local levels to provide the means for prompt, reliable receipt and release of life- and property-saving warning as well as emergency information. To activate the EBS at the State level, a request may be directed to an Originating Primary Relay Station (usually i

an FM station located near the State capital) by the Governor, his designated representative, the National Weather Service, the State Civil Defense or Emergency Services Office, or other designated )

State authority. At the local level, a request for activation may i be directed to the National Weather Service, local Civil Defense, local government, or public safety officials. In either case, communciations facilities developed for use in contacting and pro-viding emergency program material may include any of the following:

telephone, remote pickup units, NOAA Weather Wire Service or NOAA i

l 1

)

Weather Radio, police and fire comunications, amateur and citizens band radio. Station management at the Originating Primary Relay Station and/or the Comon Program Control Station authenticates the validity of all requests to activate the system. Other broad-cast stations may activate the EBS on an individual basis as needed. This is important since station management is responsible for all program material broadcast to the public. The Originating Primary Relay Station at the State leve~l, or the Comon Program Control Station at the local level, will take the following steps to activate the EBS:

1) Take action to broadcast emergency programing which may i

include recording the emergency message for use later.

2) Broadcast an initial statement.

3) Transmit the tsio-tone Attention Signal.

4) Broadcast the emergency announcement.

All other participating stations, alerted via their off-the-air monitoring of the two-tone signal, repeat the above procedures.

Additional guidance will be issued to the public through the Public Information Brochure (when it is issued) to advise them what radio L and television stations to turn on to receive emergency information if the siren system is sounded due to a problem at CPSES.

Q.17. Is there any NRC or FEMA emergency preparedness guidance regarding ,

to EBS?

A.17. Yes. NUREG-0654/ FEMA-REP-1, Revision 1, Appendix 3, "Means for

) Providing Prompt Alerting and Notification of Response Organiza-l l

[

u_ . . . - . _ . . . . . . -. .. . . . - - , . . . -.

tions and the Population", Section 4.a, sets forth the joint NRC and FEMA guidance for use of the EBS as a means of notifying and transmitting information to the public.

Q.18. Does NUREG-0654/ FEMA-REP-1, Revision 1, recommend a back-up provision to the EBS for public notification?

A.18. No, there is no requirement in the Appendix 3, Section 4.a of NUREG-0654 that requires, or mentions the desirability of, a backup system to the EBS for public notification. Moreover, there is no NRC/ FEMA guidance tht recommends that the EBS system be utilized at all in the emergency preparedness plans for nuclear power reactors.

Q.19. Is it likely for the EBS to be unavailable for broadcasting warnings and information following an incident at CPSES?

A.19. No. Radio station WBAP in Fort Worth is designated as a Common Program Control Station No.1 ("CPCS-1") for the EBS. WBAP has a back-up emergency generator so that they can continue radio trans-I missions in event of a power failure. Accordingly, we believe that the unavailability of the EBS is not a likely occurrence.

Q.20. In the unlikely event that the EBS system is unavailable, are there backup provisions in the State plan, and the Hood and Somervell Counties Plans for emergency notification of the public in the 10-mile EPZ for CPSES?

A.20. Yes, there are back-up provisions for notification of the public in the unlikely event of EBS unavailability. As we stated in our o, . , " e - -

previous written testimony (Staff Exhibit 203, Tr. 5750), the National Weather Service's Weather Radio System may be utilized to transmit information to the public. The Counties may also dispatch mobile public address ("PA") units to transmit information to the public. Attachment F to the Hood and Somervell Counties' Emergency Operations Plans.

Q.21. Have you read, and are you familiar with a March 22, 1983 Memorandum from Richard W. Krimm Assistant Associate Director, Office of Natural and Technological Hazards, FEMA, to Edward L.

Jordan, Director, Division of Emergency Preparedness and Response, Office of Inspection and Enforcement, NRC, entitled " Comanche Peak Testimony Before ASLB, September 17, 1982"?

A.21. Yes. We have reviewed this Memorandum, and are familiar with it.

Q.22. Does this Memorandum change your conclusions regarding the state of emergency preparedness for CPSES, as contained in your written direct testimony (Staff Exhibit 203), your oral testimony at the September 1982 hearing session, or your supplementary written testimony filed on March 30, 1983?

A.22. No. The Memorandum confirms, and is consistent with, our previous written and oral testimony regarding the satisfactory resolution of these three matters. The Memorandum specifically confirms our oral testimony (Tr. 5708-09), whom we stated that if Hood County Hospital is a County-owned hospital, that no letters of agreement were required. The Memorandum also confirms our oral testimony

(Tr. 5717-18) that if County-owned ambulances provide emergency ambulance services, then no letters of agreement are required.

Finally, the Memorandum states that the oral comitment by the State to FEMA to list hospitals with confirmed capability to treat radiologically-contaminated individuals (Tr. 5715-18) has been satisfied.

a e

4 4

W l

• • O- .e Aw4, .

ENCLO5WE2 i

l l

I i

l

[

f i

h f

r f

i e

-_