ML20043H218

Forwards Response to 900515 Request for Addl Info on Emergency Preparedness.Ongoing Emergency Preparedness Programs Address Concerns Raised by Citizens for Fair Util Regulation

ML20043H218
Person / Time
Site:	Comanche Peak
Issue date:	06/15/1990
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-90208, NUDOCS 9006220239
Download: ML20043H218 (11)

Text

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I Lo # TXX-90208 P9

- ~ Fi e # 10013 Ref. # 10CFR50.47 1UELECTRIC ,

June 15, 1990 I.dE,Y, nr a,,,,

U.S. Nuclear Regulatory Commission Attn: Document Control Desk  !

Washington, DC 20555 l

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50 445 AND 50 446 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON EMERGENCY PREPAREDNESS FOR CPSES REF: NRC Letter from C. I. Grimes to W. J. Cahill, Jr.

dated May 15, 1990  ;

Gentlemen:

Enclosed with the referenced letter was a copy of a letter from Citizens for Fair Utility Regulation (CFUR) to the Commission dated April 12, 1990. In the r CFUR letter, a number of concerns were raised based upon a survey of local residents regarding the public education and information program and the Alert and Notification System for CPSES. As req: sited in the referenced letter, TU Electric has assessed these concerns and herein provides the results of that assessment.

The enclosed response, which has been reviewed with officials of the local governments and the State of Texas, contains TV Electric's assessment of eight '

(8) concerns identified in CFUR's letter. In each instance, the existing and ongoing emergency preparedness arograms of TV Electric, the State of Texas and the local governments address tie concerns raised by CFUR. The principal source of the responses to CFUR's concerns is the CPSES Emergency Plan which satisfies the requirements specified by regulation in 10CFR50.47(b) and 10CFR50, Appendix E, IV. To assure that the requirements were addressed, the guidance provided in NUREG 0654/ FEMA REP-1, Revision 1, " Criteria for.

Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," (1980) was used to develop the CPSES, State and local emergency response plans and programs.

l 9006220239 900613 [

fDR ADOCK 05000443 PDC /

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400 hrth Ohve Street Lit it! Dallas. Texas 7201 l \

TXX 90208 June 15, 1990 Page 2 of 2 As shown in the enclosure, these programs, which have been reviewed and accepted by the NRC and FEMA, and which have been demonstrated to be effective in periodic exercises, provide assurance that appropriate protective measures will be taken in the event of an emergency. TU Electric has not identified any additional actions that should be taken with respect to the public education and information program or the Alert and Notification System for CPSES. However, TV Electric is always open for constructive suggestions to improve these programs and encourages local residents and other interested  !

parties to contact the company for additional information or to express Concerns.

Sincerely,

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a= ./

William J. Ca ill, Jr.

GLB/grp t

Enclosure c Mr. C. I. Grimes, NRR-Mr. M. Fields, NRR t Mr. R. D. Martin, Region IV Mr. R. A. Lansford, State of Texas Honorable G. R. Crump, Somervell County Honorable M. Meyer, Hood County  ;

Resident Inspectors, CPSES (3) l 5

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. E'nclosdretoTXXo90208 E. , Page 1 of 9 RESPONSES TO CONCERNS IN CFUR'S LETTER OF APRIL 12. 1990 Mailina of Publication Containina Fearcency Information CFUR Concern ]

CFUR states that 147 out of 219 respondents polled by the Hood County l j

Taxpayers received TUAssociation of Texas.booklet Electric's instructLon  ? Association")

mai led out in 1989 (Letter, responded; pp. 2-3). CFUR characterizes the booklet as "the only piece of information TU l 1s required to provide to the citizens..." (letter, p. 3), and is concerned that the " mailing may be seriously flawed" (Letter, p. 3). ,

Acolicable NRC-FEMA Guidance I

, With respect this concern, the applicable 31anning standard is II.G. of NUREG-l 0654/ FEMA REP-1, Rev. 1, which specifies t1at information be "made available -

l to the public on a periodic basis on how they will be notified and what their l initial actions should be in an emergency (e.g., listening to a local j broadcast station and remaining indoors)..." Under this standard, Criterion 1  !

states that each organization is to provide coordinated dissemination of '

l information to the sublic, at least annually, concerning how they will be notified and what tieir actions should be in an emergency. Means for  ;

accomplishing this dissemination may include publications distributed on an i annual basis. Similarly, Criterion 2 states' that the public information program shall provide the permanent and transient adult population within the j plume exposure Emergency Planning Zone (EPZ) an adequate opportunity to become i aware of the information annually.  !

.TU Electric Response ,

Section 3.8 of the CPSES Emergency Plan addresses this requirement and states that a publication containing the appropriate information will be distributed  ;

' annually.

Such a )ublication has been mailed out six times. The first mailing was in-1982; tle latest was in May 1990. During the years 1986, 1987, and 1988, mailing of the' publication was suspended, with the approval of the Federal l Emergency Management Agency (FEMA), to allow the CPSES emergency planning staff to concentrate on plant activities.

The 1989 mailing was sent to approximately 14,500 addressees, using a mailing list selected by names and addresses within Hood and Somervell counties. This list was purchased from a company which pays the U. S. Postal Service to update the information regularly. Accordingly, reasonable steps were taken to -

assure that the publication was received by residences within the plume ,

exposure EPZ.

1 In 1990, the mailing was expanded to 17,500 by using a list of all addressees within the zip codes in Hood and Somervell counties. This resulted in mailing the information to some locations outside the EPZ, but provided additional assurance that the publication was received by residences within the EPZ. In addition, this publication was provided to public offices, such as post offices, tax offices, utility offices, etc.

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inclos:re to 1XX-902:3 l Page 2 of 9  :

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The publication is not the only method used to provide advance inforr.ation to )j the public on how they will be notified and what their initial actions should be in an emergency. Such information is also published in four telephone j books utilized within the plume exposure EPZ. In addition, a multicolored ,

, poster is provided to more than 30 locations such as post offices, '

restaurants, public halls, etc. Permanent signs providing information about what actions.to take when the sirens sound are installed at public parks and

-boat ramps within the plume exposure EPZ, and stickers providing information are given to motels and hotels around the plant. To supplement this published information, radio announcements will be made periodically during the next I year on public service programs on a local radio station.

Additionally, TV Electric provides a " current events' publication entitled

" Neighbor-to Neighbor," appru imately every four months to the residents of ,

Hood and Somervell counties. Although the principal goal has been to inform I

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the neighbors of CPSES about activities and people at CPSES, occasionally, it j has carried 'what to do in an emergency" type of information.

Thus, TV Electric concludes that a>propriate actions have been taken to provide such information to the pu)11c, and no remedial actions are required.

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Knowledae of Residents i l

l l CFUR Concern CFUR states that 135 out of 209 respondents polled by the Association 'did not i know where to go if they had to evacuate" and only 5 ' knew what evacuation  ;

zone they lived in' (Letter, p. 3).

Anolicable NRC-FEMA Guidance ,

Under planning standard II.G. in NUREG-0654 and the relevant criteria

. discussed in the previous concern, the information to be disseminated to the -

public at least annually is to include information on " protective measures, e.g., evacuation routes and relocation centers, sheltering, respiratory protection, and radioprotective drugs..." The public information program shall provide the adult population 'an adeounte onoortunity to become aware of the information annually." (Emphasis added) The programs should include provision for written material that is likely to be available in a residence I during an emergency. >

'In addition, planning standard II.E. discusses the need to establish means to provide early notification-and clear instruction to the populace within the plume exposure EPZ in the event of an emergency. Criteria 3 and 4 provide the licensee, State and local organizations, guidance to establish the content of initial and follow up messages providing information'for ;se in protecting the public including potentially affected po)ulation and areas, and recommended emergency actions. Criterion 5 states t1at State and local government organizations are to establish a system for disseminating such information to the public, including notification to appropriate broadcast media, e.g., the Emergency Broadcast System (EBS).

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'Encloscre to TXXo90208 I

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TU Electric Response l

The publication disseminated annually, the four telephone books, and the multicolored posters mentioned in the previous response contain the 10 mile  :

EPZ map which shows each evacuation zone delineated by clear geographical  ;

boundaries. Also shown are the routes to use if evacuation is required, where <

to report, and other special instructions. The signs and stickers, mentioned '

above, also 3rovide certain information about what actions to take in an emergency.111s information will be supplemented by periodic radio announcements. Accordingly, reasonable steps have been taken to provide the l adult population "an adequate opportunity to become aware" of suci i information.

The emergency plans do not rely on every resident knowing, prior to an emergency, in which evacuation zone he/she lives or to wiat location he/she >

should report. In accordance with planning standard II.E. and the relevant #

criteria, Sections 2.0 - 3.7 of the CPSES :mergency Plan and Sections I and VI (as well as attachments F, G, H, L, 0 and P) of the local governments' Manual of Emergency Procedures address the system for disseminating information to .

the public in the event of an emergency. These documents provide instructions on the information required to be contained in EBS messages, including clear descriotions of affected evacuation zones, evacuation routes, reporting locations, special instructions, etc. Thus, '.m EBS messages will provide instructions to the residents, even if the' .a a not informed themselves on the basis of previously available document-Accordingly, TU Electric has concluded that actions have been taken to assure that the pubile has been and will be informed of actions to take in the event of an emergency.

Sirens CFUR Confat01 CFUR states that 34 out of 70 residents who responded said that they could not -

hearthesirens(Letter,p.3).

Anolicable NRC-FEMA GuidtDLR Under planning standard II.E., Criterion 5 states that each organization is to establish the means for notifying and providing prompt instructions to the public within the' plume exposure EPZ. Specific criteria applicable to sirens used as part of a prompt Alert and Notification System are contained in Appendix 3 of NUREG-0654. In " Standard Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants," FEMA 43/ September 1983, FEMA u specified the performance level level) and testing frequency requ(atired to least 10 decibels satisfy above ambient these criteria. FEMA-43sound was superseded by FEMA-REP-10, November 1985. FEMA REP-10 clarified some requirements but maintained the 10 decibel sound level.

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, , inclosure to TXX 90208

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TU Electric Resnonse The CPSES Alert System consists of sixty six (66) Federal Thunderbeam Model '

RSH10A 240 sirens rated at 128 dBC by the manufacturer. The activation consoles are located in the Sheriff's office (County Warning Point) of both Somervell and Hood County. The dual consoles, one in each county, provide back up to each other. The Notification System provided to the counties is a  !

closed circuit tele > hone system which allows direct contact with radio station '

WBAP (the EBS), wit) each other, CPSES, and the Texas Department of Public Safety. This allows immediate coordination of information prior to broadcast at the EBS.

The CPSES Alert and Notification System was designed in accordance with the i standards of FEMA 43/ September 1983 and Civil Protection Guide (CPG) 1-14, November 1981, and CPG 1-17 March 1980. In 1984, the system, which at that time consisted of 65 sirens was tested in coordination with the State of Texast with the results exceeding the guidance in FEMA 43. On March 27, 1985, the FEMA test was conducted. FEMA performed a telephone survey, and the system was certified as adequate and a notice was published in the Federal Register (50 f.R. 30011, July 23, 1985). Operability tests required by FEMA are conducted each month and have exceeded FEMA requirements, in 1986, an additional siren was added within the city limits of Glen Rose. Texas, to i

reinforce the sound level during the spring when foliage is heavy along the Paluxy River, and one siren was shifted to improve coverage within the town of Tolar. ,

Accordingly, TV Electric concludes that appro)riate actions have been taken to assure prompt notification of the public in tie event of an emergency.

Evacuation of School Children I l Ef3RConcern l

CFUR states that of the 44 respondents who had children,10 said that they i would not allow the schools to be r'sponsible for the evacuation of their ,

children (Letter,p.3). CFUR exprwsses the concern that this small percentage "could create chaos at the schools and disrupt and delay the safe  ;

evacuation of the children' (Letter, p. 5), J l Apolicable NRC-FEMA Guidance 1

Planning standard II.J. provides that a range of protective actions, including )

evacuation, be developed for the plume exposure EPZ for the public, including schools. Under Criterion 9, each State and local organization establishes a capability for implementing protective measures based upon protective action guides and other criteria. Under Criterion 10, the organization's plans to implement protective measures for the EPZ includes consideration of projected traffic capacities;of evacuation routes and control of access to evacuated areas.

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. -Enclosure to TXX 90208

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6 TU Electric Response The plume exposure EPZ of CPSES includes three independent school districts: l Glen Rose, Granbury, and Tolar, with a total student population of i approximately 6750. Each school has an emergency plan which covers any type i of emergency. Assignments are made for security, traffic control, transportation, accountability, etc. The school staff has been trained in requirements applicable to CPSES emergencies. Buses are provided information packages for student accountability, maps showing routes to relocation centers, etc. At present, one district has radios in all buses. Another has ,

a contract with a radio company and installation should be completed in the '

near future. The third district is obtaining an FCC license and expects to install its radios during the summer of 1990.

Instructions in local emergency )lans provide for early or precautionary evacuation of the schools. -The EBS messages provide for instructions to parents as to where to meet their children. This may occur prior to any other announcement being made to the public. Children are evacuated to other schools near the relocation centers, thus providing for a duplication of ,

teachers for control and a student helping-student situation. Letters of agreement are provided from these schools to the Counties within the plume '

EPZ.

If parents arrived at a school arior to their children having been evacuated, they would be allowed to take t1eir children, as normally occurs on a daily basis. The traffic plans anticipate that some parents will drive to the  ;

schools and provide for control of this type of traffic, which will not create any undue problems.

l Accordingly,1U Electric concludes that plans are in place to assure the timely evacuation of children from the local schools in the event of an emergency.

Relocation of Residents l

l CFUR Concern CFUR ststes that 42 out of 79 residents who responded said they would have no place to go if they were told at an " evacuation center" that they could not return home (letter, p. 3).= CFUR expresses a particular concern because many of the residents are older, retired persons, w1o live alone (Letter, p. 4),

i Anolicable NRC-FEMA Guidance l Under planning standard II.J., Criterion 10 provides that the plans of State .

I and local organizations include relocation centers in host areas beyond the boundaries of the plume exposure EPZ and means for registering and monitoring of evacuees at relocation centers.

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,, Enclosure to TXX-90208

+' Page 6 of 9 l TU Electric Resnonse Two relocation centers have been established: one operated by the City of Cleburne and one by the City of Stephenville. The publications described above inform residents in the plume exposure EPZ that the relocation centers will provide them with a place to stay if they have nowhere to go after i evacuation. Each relocation center has a published plan which provides for  ;

care of any person reporting to that center. Hospitals located in each city I have plans and are trained to attend to any patient, including any contaminated evacuee. The relocation' centers will issue pre printed vouchers to evacuees, which will be accepted by hotels and motels for lodging, as well' as retail stores and food establishments. All persons are instructed to go to the relocation center where they may be monitored if there has been a release )

at the plant and registration can be completed. Names and other vital information, including their location and a telephone number if available, are recorded in order to allow for quick reference in order to locate an individual or a family and for accountability. l l

State and local _ plans also provide for long-term relocation during a recovery .

, period if returning to an area is prohibited. )

Accordingly. appropriate plans have been made for the care of all evacuees in the event of an emergency and no additional actions are required.

Nursina Homes CFUR Concern-CFUR states that there are a number of nursing homes in the area and that "a

, large nursing home, retirement development is in the planning stage" (Letter, pp. 4 5). Apparently, CFUR may be concerned that these were overlooked in the

. emergency planning.

Ano11 cable NRC-FEMA Guidance L Under planning standard II.J., Criterion 10 provides that the plans for State and local organizations include means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement.

TU Electric ResDonse Under applicable State and local emergency plans, nursing homes within the plume exposure EPZ have been identified, and the potential needs for specialized transportation have been taken into account in arranging for necessary resources. In the event of an emergency, the plans provide for contacting nursing homes and providing specific transportation, etc., as required. The actual relocation of nursing home occupants and hospital patients will be determined on the basis of recommendations of staff attendants and medical sources.

Accordingly, nursing homes have not been ignored and are covered by appropriate plans. Any new nursing homes or any new retirement centers having transportation dependent residents in the area will be added to the plans.

Enclosu're to TXX1 90E3

• - Page.7 of 9-8dded Summer Population  ;

CFUR Concern ,

CFUR states that there are dozens of summer camps in the region surrounding the plant which house children from churches in Fort Worth, Dallas,and surrounding communities (Letter, p. 5). CFUR expresses the concern that this added summer population "has not been taken into consideration by a carefully i worked out evacuation plan." The basis for the concern ap) ears to be that '

churches in Fort Worth-Dallas have not been brought into tie evacuation planning and that the camp staffs are only in the areas during the summer and have no access to any information, o Applicable NRC-FEMA Guidance I As noted in the discussion of nursing homes above, planning standard II.J.

Criterion 10 states that plans for State and local organizations include means for protecting persons whose mobility may be impaired or need other special considerations.

TU Electric Response Within the CPSES plume exposure EPZ, there are presently forty three (43) special facilities, including five (5) church and scout camps; and a number of L day care centers, fishing camps, half way houses, parks, nursing homes, etc.

Each of these facilities is individually identified in the applicable emergency plan, with its average occupancy by season (winter, spring, summer ,

and fall). Its potential trans)ortation needs have been taken into account in the planning of resources. Eac1 facility has furnished the local government a telephone number for special notification and coordination.

'Each facility, including church and scout camps, has been provided with an emergency information poster which identifies the emergency zone in which it ,

is located, the evacuation route, and the telephone number to call if it needs special assistance. In addition, each facility has been visited by a member of the emergency plan staff, was advised on what its plan should include for emergencies,'and was offered further assistance, if desired. A limited number of requests for further assistance or information were received, and TU t Electric's Emergency Planners are working with these locations at present.

Contact with special facilities is a continuing planning process, which adds and subtracts facilities from the list and updates seasonal occupancy figures. ,

Accordingly, additional summer population has been taken into account in CPSES emergency planning. Although sponsoring churches for summer camps are not necessarily involved in emergency planning, contacts are made directly with the camps, and appropriate information is provided.

H Enclos'ure to TXX-90208 0

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Community Education and Involvement i

CFUR' Concern CFUR states that the survey. " underscores the need for a much greater degree of community education and involvement than has occurred to date (Letter, p. 5). l It~ suggests that schools should hold parent-teacher meetings with 1 TU Electric personnel, NRC staffers, and county and State officials; and that '

questions need to be answered about different kinds of accidents, the levels I of severity and the importance of adhering to a well understood, disciplined  !

evacuation procedure. CFUR expresses the concern that the survey indicates i that residents are not aware of what they are to do and that this "could skew

.a safe evacuation" (Letter, p. 6).

l Acolicable NRC-FEMA Guidance As noted above. planning standard II.G. states that information is to be made l available to the public on a periodic basis on how they will be notified and 1 what their initial actions should be in an emergency. Criterion 1 states that  !

l such information shall include educational information on radiation, 1 protective measures, and contacts for additional information.

l TU Electric Response t The previously discussed publication mailed annually to all residents contains l educational information on radiation, protective measures and contacts for i- additional information. In addition, the information published in the telephone books and all of the posters identifies contacts for additional information.'

TU Electric's efforts are not limited to the dissemination of written information. TV Electric has made personnel available to visit with or speak

.to groups on CPSES, including its emergency plans; TV Electric personnel do so on almost a daily basis. TV Electric employees are members of numerous civic _  :

groups and are available to explain 'or provide information about plant operation, as well as emergency information. TU Electric emergency planning personnel work within the local communities and also provide information to the residents.

TV Electric would be pleased to expand its current public information efforts by providing speakers for meetings with any interested groups, e.g., churches, additional parent-teachers groups, etc. Some of the radio announcements that will be made concerning the CPSES emergency plan will encourage any interested organization to contact TV Electric to have a speaker attend one of its

, ' meetings or to obtain additional information it would find helpful. Similar announcements will be included in the " Neighbor to Neighbor" publication. <

In addition..TU Electric has recently opened a community office in Glen Rose, Texas and will be opening one in Granbury, Texas (approximately July 15, '

1990). The Glen Rose office is currently open 3 days a week. The Granbury office will be open 5 days a week. These offices will be used to coordinate the dissemination of information about CPSES operations and TU Electric.

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. Enclos6re to TXX 90208

• Page 9 of 9 It should be noted, however, that the advance public information program can only provide the residents with general information about what to do in the event of an emergency. The additional information that will be provided if an emergency were to occur, together with other actions taken by TU Electric and State and local organizations, provide additional assurance that appropriate protective measures will be taken. The overall emergency plans apalicable to CPSES, which have been-reviewed and accepted by NRC and FEMA and w11ch have been demonstrated to be effective in periodic exercises, assure that the public hill be protected.

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