ML20072E466
| ML20072E466 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/22/1983 |
| From: | Krimm R Federal Emergency Management Agency |
| To: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20072E469 | List: |
| References | |
| NUDOCS 8306240435 | |
| Download: ML20072E466 (1) | |
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.a f r !!ock Poir.t in i ts es:cond Init ial Deci sirm, it e orrfe r r ecuired ('ocs.umc rs P<rw r Companf to dmtmt rate that ditticisncien 8
di ecu:;r.ed ir the A5!.P.'s s.. cond In f tial Decision hcve been rer edi er, wre net m rievu, or wre beitic renc< lied throt:".5 adequate inter te conp rnatint twnaures.
%c,'ieq ue n t to the ori?cr. Coucuters Powcr Cor=pany aldrtseed all of the evidentiarv J.*ficienciea icentified by the LSLn in a series or resp care to the MIJ:.
Attac6 e ? for yet r review is FUfA's osscastwnt of the adequacy of the r-smnses t
and renceli ni ect f orm t raen 1.y Consurcrs Pcwr Corpony ne each d.af ic! cncy or d M." A ' r, con c l uc tort r.a to r ne edequacy of tl.e actiona.
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Federal Emergency Management Agency
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Region V 300 South Wacker,24th Floor, Chicago, IL 60606 (312) 353-1500 L
MAR 3 1993 MEMORANDUM FOR RICHARD KRIMM, ASSISTANT ASSOCIATE DIRECTOR, OFFICE OF NATURAL AND TECHNOLOGICAL HAZARDS Attention: Megs Hepler, Field Operations Branch, SL-NT-TH FROM:
Frank Finch, Chief Natural and Technological Hazards Division Region V
SUBJECT:
Initial Decision for the Big Rock Point Nuclear Power Plant This is in response to your telephone calls requesting our review of actions taken to remedy deficiencies identified by the Atomic Safety and Licensing Board on September 14, 1982. Those deficiencies were:
A.
Failure to show the extent of the need for radiological training of local officials or school officials, or to show that the need is being met in a satisfactory fashion by the combined efforts of applicant and State and local governments.
B.
Failure to show the extent of the need for transportation of persons who lack personal vehicles, or to demonstrate that the need is being met in a satisfactory fashion by the combined efforts of applicant and State and local gcVernments.
C.
Failure to show that there is a satisfactory method of alerting school bus drivers who are not on duty, or that such bus drivers have agreed to perform emergency transportation duties at a time when they are not on duty.
D.
Failure to show that, if an emergency is declared while school is in session, there will be adequate transportation available for schoolchildren, including schoolchildren who do not ordinarily rely on school buses for transportation.
E.
Failure to show that an adequate list.of invalids is being kept in order to facilitate their evacuation during an emergency.
F.
Failure to show the method by which emergency bus routes will be established, or that it will be feasible for bus drivers who have never before seen the routes to drive them in an acceptable manner.
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Our findings are:
(a) any inadequacies in the radiological training program that may have existed are being remedied; (b) as additional transportation needs are identified, remedial action is being taken i
to improve evacuation planning; (c) there is a satisfactory method of alerting school bus drivers who are not on duty and they indicate 4
I their willingness to drive during an emergency; (d) adequate transpor-tation is available for all schoolchildren; (e) an adequate list of
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invalids is current to facilitate their evacuation; and (f) a satis-factory method for establishing emergency bus routes exists and only experienced bus drivers who are familiar with the local roads will be j
assigned to drive.
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Frank Finch 7
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ATTICIO!ENT DEFICIENCY "A" DEFICIENCY:
Failure to show the extent of the need for radiological training of local officials or school officials, or to show that the need is being met in a satisfactory fashion by the combined efforts of applicant and State and local governme'nts.
DISCUSSION:
In response to the request by the ASLB, an extensive review of past training activities was accomplished by State, local, and utility company planners. This review was a preliminary step in further defining the scope of need and content of training.
As evidenced in Lieutenant Tyler's affidavit, coincidental activities were initiated by the Emergency Services Division, Michigan State Police, as part of their reorganization into the Emergency Management Division, to develop a more effective means for monitoring training activities along with developing and implementing a more comprehensive training program.
As a result of the joint effort, a complete list of all support groups needing training was compiled.
.ning course was developed to address functions and responsibilities of 1
all support groups and was designed into four modules to allow flexibility and selectivity of training f.or specific groups.
Training needs of the various support groups were analyzed and scheduling will allow presentation of those modules appropriate for the specific support group.
Subject content of the modules was developed in consultation among the Emergency Management Division, the Radiological Health Services Division (Michigan Department of Public Health), the local Emergency Services Directors, and the utilities. Qualified instructors to present the training include a Health Physicist with Consumers Power Company, a Health Physicist with Radiological Health Services, Radiological Emergency Training Unit personnel of the Division of Emergency Management, the local emergency services director, and persons responsible for coordinating the function of particular support groups.
A specific example, cited in Mr. Muma's affidavit, relates to training given school bus drivers.
The course included an overview of emerger.cy planning; basic radiological principles; radiation safety; biological effects and risk; notification procedures; activation of the E0C; alert classifications; communications systems; resources coordination and control and dosimetry procedures; the school's evacuation plan, notification procedures, general operating procedures, bus routing, and specific procedures for bus drivers.
In our review, we noted previously conducted training was attended primarily by supervisory personnel, who, in turn, extended training through their own organizations. There was no focal point from which overall training could l
be monitored and recorded.
An important aspect of the training program now l
being implemented is that it is systematically extended to include workers on the line.
CONCLUSION:
We find a deliberate, comprehensive, and coordinated effort is being made by the utility and State and local government to refine previous definition of the extent of need for radiological training. A joint effort has been made to ieprove the radiological training program. We believe that any inadequacies that may have existed will be remedied through continuation of the newly-implemented program.
DEFICIENCY "B" DEFICIENCY:
Failure to show the extent of the need for transportation of persons who lack personal vehicles or to demonstrate that the need is being met in a satisfactory fashion by the combined efforts of applicant and State and local governments.
DISCUSSION:
Determination of the extent of the need for transportation by persons who lack personal vehicles is a matter that has been, and continues to be, pursued diligently.
This is a complex situation in that identification of permanent residents without automobiles, persons with special needs, and persons within special facilities is required.
Toward this end, Consumers Power Ccmpany retained Stone and Webster Engineering Corporation to prepare an analysis and identification of the transportation of dependent population within the Big ?.ock Point emergency planning zone.
Prior to the commissioning of this study, Sheriff Lasater of Charlevoix County had enlisted the aid of individuals and county agencies to identify invalids in need of trans'portation.
Sheriff Lasater's ensuing list of persons was later expanded to include some senior citiaens who would not to drive during an evacuation, and temporarily impaired persons, as want well as those with permanent impairments.
This listing is updated quarterly through telephone and personal contact with persons whose names are listed.
The listing is expanded as additional persons are identified.
Present indications are that buses with drivers from Charlevoix County Public Transit System assigned to this duty have sufficient capacity.
An additional four school buses for back-up support for evacuation has been offered by the Boyne Falls Public Schools.
In respect to the Charlevoix schools, the affidavit by Mr. Olack,. Business Manager of the Charlevoix Public Schools, contains comprehensive calculations regarding the number of students and teachers to be evacuated.
His figures include the threa public schools (the Elementary School, the Middle School, and the High School), plus the Charlevoix Cocperative Nursery, and St. Mary's School, a parochial elementary school.
In his affidavit, Mr. Olach establishes an ample number of bus spaces, drivers, and supervisors are available to effect evacuation. The on going maintenance and inspection programs are geared to ensure the buses' being in operable condition.
Additional buses are available, however, from two neighboring school districts, if needed.
Sheriff Lasater, in his affidavit, describes procedures for moving county jail inmates if the need arises.
In their study, Stone and Webster identified two private nursery schools (Charlevoix Children's House and Kid's Corner), with a total enrollment of 36 children, that had not previously been included in evacuation planning.
Stone and Webster also suggested an additional vehicle be made available to assist in evacuation of the Charlevoix Area Hospital.
Three other areas Stone and Webster recom= ended further attention to defining transportation needs were Pine River Place, Mt. McSauba Day Camp, l
and the City of Charlevoix.
Pine River Place is an elderly housing facility with approximately 80 residents of whom 12 have been identified to need t
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Mt. McSauba Day Camp is used by approximately 25 to 45 children on week days during an 8-week period between the end j
o' June and mid-August.
These children, plus 1 or 2 staff members, will i
require transportation in the event ef an evacuation.
In the City of Charlevoix, the 1980 Census indicated approximately 300 people were transportation dependent.
Stone and Webster recommended the utility company conduct a survey to refine the 1980 Census figures.
Consumers Power Company planners and staf f members of the Emergency Manage-ment Division, Michigan State Police, have met to develop a time schedule for implementation of the Stone and Webster report recommendations.
Consumers Power Company intends to mail a questionnaire to all households in the City of Charlevoux. The responses to the questionnaires will be used to identify the extent of the evacuation transportation need and provide a basis for evacuation planning, which will be done by the State Emergency Management Division and Charlevoix County Emergency Services, with assistance from Consumers Power Company.
CONCLUSION: The materials submitted by Consumers Power Company reflect a cencerted effort to refine the identification of persons in need of transportation during an evacuation emergency.
This further definition of the extent of need for transportation is being done as a preparatory step to plan use of available transportation resources during an evacuation emergency.
We find that the previously identified transportation needs were being met in a satisfactory manner and that, as additional needs are identified, remedial action is being taken by the utility, State, and county through cooperative planning and exchange of information.
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e DEFICIENCY "C" DEFICIENCY:
Failure to show that there is a satisfactory method of alerting school bus drivers who are not on duty or that such bus drivers have agreed to perform emergency transportation duties at a time when they are not on duty.
DISCUSSION:
The method of alerting school bus drivers during non-duty hours is a basic telephone fan-out notification system.
School District officers are notified by the Emergency Operations Center and, in turn, notify the School Transportation Supervisor.
The Transportation Super-visor is to call three designated bus drivers, each of whom calls another driver who in turn calls the next driver.
There is no evidentiary pro-vision in the Emergency Operations Plan or in the supporting affidavits submitted by Consumers Power Company that an alternate call would be made in event someone does not answer.
It is also recognized that alternate bus drivers, including some school teachers, are available.
We believe it is important the drivers can be contacted while on their routes and note the provision for doing this.
The method devised has proven effective.
There is no explanation, however, of what instructions the drivers would received in this kind of instance, other than to report to the bus garage.
This is of particular significance if a driver is part way through his route, especially if it is corning and he is picking students up.
This could create a situation in which the driver reports to the bus garage with only part of the students for which the school District may be accountable.
There are statements indicating all regular and alternate drivers, including some school teachers, have expressed their willingness to drive in an emergency situation.
CONCLUSION:
We find the method of alerting school bus drivers who are not on duty acceptable.
We are interested in the instructions that would be passed to the drivers in event they are enroute at the time an emergency is declared.
By the same token, we accept and endorse the statements indicating their willingness to perform emergency transportation duties when they are not on duty.
DEFICIENCY "D" i
DEFICIENCY:
Failure to show that, if an emergency is declared while school is in session, there.will be adequate transportation available for school-children, including schoolchild en who do not ordinarily rely on school buses r
i for transportation.
i DISCUSSION:
Charlevoix School District is the primary source of traneportation for emergency evacuation of the three public schools (the Elementary School, i
i the Middle School, and the High School), the Charlevoix Cooperative Nursery, and St. Mary's School.
A conservative estimate, based on lower than average i
absentee rate, determined the total number of persons who would be evacuated by the Charlevoix School District to be 1429.
This includes schoolchildren and teachers to accompany and supervise each bus.
The total evacuation cap-acity of the available vehicles (19 school buses, 2 vans and a station wagon) is 1,489 passengers.
Thus, evacuation could be accomplished in one trip.
The number to be transported includes students (and teachers) who do not normally ride buses to school.
A thorough maintenance program, plus an annual inspec-tion by the State, ensures the serviceability of the Charlevoix School District buses and vehicles.
In addition, two neighboring school districts have made verbal support commitments to provide transportation in the unpredictable event more b us e:. and drivers are needed.
CONCLUSION:
We find adequate transportation is available for schoolchildren, 2
including those who do not ordinarily rely on school buses, to acco=plish evacuation during a radiological emergency while school is in session.
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JdEICIENCY "E" DEFICIENCY:
Failure to show that an adequate list in order to facilitare their evacuation during an emerof invalids is being kept 4
gency.
DISCUSSION:
the process by which his list of individuals win his affadavits, Sheriff L unty, explains these individuals is addressed in the discussion as developed.
Transportation of includes senior citizens and other persons needing trof Deficiency "B."
His list an evac ua tion.
It citizens and invalidsis noted that his list is not ansportation assistance in but only those unable to provide their own transportatii during an emergency ev,acuation.
on Sherif f Lasater describes a conscientious ef fort three separate and periodic news releases car i d ito identify individuals through announcements.
ledge of physically impaired citizens to assist him iHe has show re u ar know-the list current.
form was sent As late as October 1982, a pamphletn compiling and maintaining added to the list.to all residences in the EPZ.
containing a mail-in all persons en the listAccuracy of the list This resulted in 8 persons being to confirm their status.is verified by periodically calling LMatification of all persons with need include a Further efforts to ensure which was retained by the utility company study by Stone and Webster, by the study, mail a questionnaire to all households in the City of Cha lThe utility c evacuation assistance.to further ensure identification of person who wo ldr evoix, as recomm need or desire u
Additionally, Sheriff Lasater has enlisted the aid ment person assigned to the Sheriff's office.
of the County Health Depart-and visited the several nursing homes, This individual has telephoned physically and mentally handicapped adults. care centers, and a work facility for day and hours of operation of the facilitieswere identified, some pending upon time of persons are impaired, they are not It is recognized that, although a particular time of day is considered. stationary.
Their probable whereabouts at Health Services for the District Health Departme tagencies is e per, Director of Personal for identifying temporarily incapacitated persons n.
An improved procedures j
Sheriff Lasater. permanent disabilities, has been implemented and informati, as well as on is provided to CONCLUSION:
and will be given several opportunitier to identify thBased upon t een given dependent.
There has been a teleological effort emselves as transportation who have not t
identified themselves.
to search out any individuals The listing is updated quarterly and includes individA listing cnd maintained.
temporary impairments.
We conclude that uals with kept to facilitate their evacuation in eventan adequate list of invalids is being of an emergency.
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DEFICIENCY "F" DEFICIENCY:
Failure to show the method by which emergency bus routes will be established, or that' it will be feasible for bus drivers who have never before seen the routes to drive them in an acceptable canner.
t DISCUSSION:
This deficiency contains two points that, while co-related, are cach distinct and must be addressed singularly.
One is the method by which the bus routes are established and the other is the feasibility of having the bus drivers drive those routes.
This latter point infers assignment of drivers who are unfamiliar with local roads. We cannot find substantiation of this inference and note statements to the contrary.
In the case of the Charlevoix County Public Transit System, which has 8 buses and 10 drivers, the drivers are all residents of Charlevoix County and familiar with the roads in the county and the City of Charlevoix.
This transit system operates on a " demand-response" basis, resulting in con-stant adjustnent of routes to accommodate persons requesting transportation.
In the case of the Charlevoix School District bus drivers, all regular drivers, except 1, and all substitute drivers, except 1, attended training in October 1982.
The 2 absent drivers had attended an earlier training session in May 1931.
This is an indication,f less than 100 percent attrition, which attests to an experience f actor and, more impor tan t in this instance, that those drivers have been in the local area at least 17 months.
This appears to be more than sufficient time to learn the major roadways in the area, which would be used as evacuation routes.
Evacuation route briefings during the training sessions further enhance the probability of the drivers' understanding of the routes.
Regarding the emergency bus routes, the methodology used in pre-selection of evacuation routes is based on guidance contained in NUREG 0654/ FEMA REP-1, Revision 1, Appendix 4.
Thus, factors considered included roadway networks, traf fic patterns, traffic capacities, time estimates, geographic locations, population distribution and adverse as well as favorable weather conditions.
Three potential population segments were considered; permanent residents, transients, and persons in special facilities.
Schools were considered in the special f acility segment.
As part of pre-evacuation planning, the EPZ is divided into pre-designated routes for the general population.
Exception is made for the school district to follow a pre-designated route which allows them to implement procedures to first evacuate the schools nearest the plant, fill empty spaces, converge at Charlevoix High School (which is the school furthest from the plant) and proceed in convoy to the reception center.
A second exception involves the evacuation procedure for persons in need of transportation and the Charlevoix sheriff office's utilization of Charlevoix County Public Transit System buses to satisfy the need.
In this case, the Transit System bus drivers repcrt to the Emergency Operations Center (EOC) and use their buses with teams assigned to areas, as required by the situation.
A Sheriff's Officer accompanys each team.
Special provision is also made for l
evacuation of Charlevoix County Jail inmates and Charlevoix Area Hospital.
Other special f acilities have been identified in the study by Stone and Webster, whose recommendations are being implemented.
CONCLUSION:
The method by which the emergency bus routes will be established is not specifically described, but is included in the planning process as i
evidenced through the implementing procedures for evacuation.
The resulting procedures effectively accocplish the purpose of establishing routes to be 1
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selected in event a particular area is to be evacuated.
Special facilities are being included in the overall evacuation plan.
In the case of assigning bus drivers, we find repeated evidences that a sufficient number of qualified and experienced bus drivers, all of whom have expressed a willingness to drive during an evacuation due to radiological considerations, are available and assigned this emergency duty.
In the absence of any indication of intent l
to assign drivers who have never seen the routes, we find the feasibility of such action to be a moot point.
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