ML20078D419

Position on Schedule of Offsite Emergency Planning Issues. Hearings on New Hampshire Radiological Emergency Response Plans & Local Plans Should Be Postponed Until Mar 1984. Certificate of Svc Encl

ML20078D419
Person / Time
Site:	Seabrook
Issue date:	09/27/1983
From:	Cassidy B Federal Emergency Management Agency
To:
References
ISSUANCES-OL, NUDOCS 8310040510
Download: ML20078D419 (29)

Text

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qh3 00CKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 8 O(FICE OF SECRETAN ~

aCKETInc 5 S5gy;;

In the Matter of #NU PUBLIC SERVICE OF NEW HAMPSHIRE, et al Docket Nos. 50-443 OL (Seabrook Station, Units 1 and 2) 50-444 OL FEDERAL EMERGENCY MANAGEMENT AGENCY'S POSITION AS TO SCHEDULING 0FFSITE EMERGENCY PLANNING ISSUES On August 31, 1983, the Board held a hearing at Dover, New Hampshire for the purpose of soliciting the view of Robert J. Boulay, Director of the Massachusetts Civil Defense Agency and Office of Emergency Preparedness, regarding submission dates for the State and local Radiological Emer-gency 1/

Response Plans (RERP's) to the Federal Emergency Managment Agency (FEMA)T Director Boulay indicated that his best estimate was that the Massachusetts Area (site specific) Plan would be ready in mid-October and that the local plans would be ready " hopefully for the end of November." Tr. at 1835. In light of Director Boulay's representations the Board requested that the parties and FEMA prepare briefs on the issue of the timing of the-hearings on offsite emergency plans.

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~ Notice of the hearing was not received at the FEMA's Region I offices until August 31, 1983, the day of the hearing. Since counsel was out of the office that day actual notice of the hearing was not received until Septmeber 1st. No notice, other than the mailgram sent by the Board was received. Consequently, neither counsel nor other representative was present at the hearing.

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. 2 I have- reviewed the schedule submitted by the Applicant in its September i

13, 1983, pleading and find the schedule suggested therein to be acceptable to 2/

r FEMA. -

The question remaining is whether the Board should proceed to hearing 3/

on the New Hampshire State and local RERP's in December or delay hearing on these plans until- March,1984 so that all of the offsite emergency planning ,

. issues can be heard contemporaneous 1y. Although FEMA will be prepared to address the admitted contentions in December, due to the current state of the 4

New Hampshire RERP and local RERP's FEMA's testimony will necessarily be i nconclusive. It is FEMA's position that the hearings on the New Hampshire RERP and the several local RERP's should be postponed until March and, to the extent feasible, all of the contentions on all of the plans be heard together.

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, The FEMA Region I staff and the Regional Assistance Committee (RAC)~

>- have reviewed the New Hampshire RERP 'for Vermont Yankee and provided supple-mental comments pertinent to Seabrook Station to the State of New Hampshire i . for it's consideration (Attachment 1). FEMA has prepared the consolidated Region I staff and RAC comments on the Greenland, New Hampshire RERP -5/

-2/

Due to a change in the schedule _for Kansas Gas and Electric et al, (Wolf I Creek Generating Station, Unit 1) counsel for FEMA will be unavailble for hearings during January and the first two weeks of February of 1984.

-3/

Applying the time table set forth in the Board's May 23, 1983 Memorandum and Order the process for the State RERP will be complete and hearing could commence on December 15, 1983. The process for all of the local RERP's will be complete and hearings could commence on December 24, 1983.'

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The RAC is chaired by FEMA.and comprised of representatives from seven Federal agencies; FEMA, NRC, Department of Transportation, Department of Health and Human Services, the Environmental Protection Agency, U.S.

Department of Agriculture, Department of Energy, and Department of Commerce.

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Since all of the New Hampshire local RERP's are substantially similar most of the comments raised by the FEMA and RAC review for the Greenland, New Hampshire RERP are applicable to all of the other local plans.

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3 (Attachment 2). These comments have been sent to the State.

Due to the fact that sections required by NUREG 0654/ FEMA REP 1. Revision 1 are missing from these plans, the incompleteness of several sections of the State RERT and the the lack of detail in other portions of the State and local RERP's for Seabrook Station it is FEMA's opinion that hearing in December, 1983 will be inconclusive. "[T]his Board is charged with the obligation, pursuant to section 50.47(a)(2), to base our conclusions regarding the adequacy of offsite emergency preparedness as to those matters in controversy upon FEMA's review of the adequacy of state and local emergency preparedness, as presented to us through FEMA's testimony." Cinncinnati Gas and Electric Company, et al. (Wm. H. Zimmer Nuclear Power Station, Unit 1),16 N.R.C. 741, 746 (1982).

Proceeding to hearing on these matters to accomodate an Applicant's proposed fuel-loading date does not justify proceeding prematurely. Cinncinnati Gas and Electric Company, et al. (Wm. H. Zimmer Nuclear Power Station,' Unit 1) 16 N.R.C. at 747.

Postponing a hearing on the New Hampshire State RERP and the local RERP's until March,1984, will provide the State of New Hampshire with additional time to address the issues that FEMA has raised in our comments on these plans.

If appropriate response is forthcoming from the State the process wi.11 be ,

expediated by delaying the hearing until March 1,1984.

RESPECTFULLY UBMITTED, C ,5 . -

mMI BRTANF. USSTDY Regional Counsel Federal Emergency Man _ ment Agency Region I J.W. McCormack POCH Bocton, MA 02109

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i Federal Emergency Management Agency i o . Region 1 J.W. McCormack Post Office and Court House

. . Boston, Massachusetts 02109 June 23, 1983 Mr. Richard H. Strome State Director New Hampshire State Civil.

Defense Agency -

New Hampshire Military Reservation One Airport Road Concord, NH 03301

Dear Mr. Strome:

This is in answer to your request that we provide a brief preliminary reaction to the new New Hampshire Radiological Emergency Response Plan with respect to the Seabrook Nuclear Power Facility. Overall the RAC felt that the plan . pro-vides a solid planning foundation. The following preliminary coments concern plan omissions for Seabrook and problem areas.. identified for Vermont Yankee but applicable to Seabrook (SS). I wish to stress the fact that this review has just commenced and the areas identified only reflect the present state of our review.

A. Plan considerations which have been noted to date are:

1. There. was no disc.ussion of how and why the size and location

,of the EPZ was determined.

2. Concerning the data to be considered in protective action decision-making, the population data for the EPZ as presented is not accurate in that the EPZ goes substantially beyond a 10-mile radius from the plant. Additionally, the evacuation study time estimates should take into account the movement of the entire EPZ population. Finally, if protective action decisions are to be made on a town wide basis, population and evacuation time estimate data should be provided on a whole town basis (Not by sector or concentric ring). -

l 3. The IF0 location, la'yout, procedures are lacking.

i 4. The public alerting system is not described.

5. The public information program is not complete. ,

6. The' dispatch center needs to be' confirmed.

7. The decontamination centers, radiological monitoring locations,

! access control points, seven local E0Cs, reception / host centers are not designated.

8. The CDA SOPS are not included.

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9. The locations of agricultural facilities for the ingestion pathway are not identified.

10. The State snould consider developing early protective action decisionmaking criteria with respect to the transient population.

For example,-the State may wish to consider closing the beaches prior to a General Emergency if a significant release is inuinent.

B. A review of the New Hampshire State Plan with respect to Vermont Yankee (VY) has identified several areas for improvement that are common to both Vermont Yankee and Seabrook Station (SS). ' Areas for improvement identified with respect to VY and applicable to SS include the following:

" 1. Radiological health resources, both personnel and equ'ipment, are not fully documented; State response capability indicated to be dependent upon " adequate augmentation" by other sources.

2. Use of two State EOCs (DPH & CDA) will probably hamper coord-ination. We will withhold final judgment until this coordination is tested in an exercise.

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3. Interstate agreements for coordinating and implementing protective actions need to be established.

4. The NH State plan.provides an index to the letters of agreement but not the full text. RAC review of the text is essential.

5. Resources for the implementation of evacuation are not fully documented and population distribution data are not complete.

The standards of NUREG-0654 Appendix 4 require further attention.

For example, the Vorhees Report (Aug.1980) indicated that the transit-dependent population in the Seabrook EPZ is substantial l and a sizeable fleet of buses (80-90) would be needed for their l evacuation (pp. 7 & 78). It is further indicated that arranging l for this fleet is a sizable undertaking. Additionally, evacuation l of the non-ambulatory population in institutions (Vorhees p. 8 and

! 78) needs to be addressed. Is this covered in EMS SOPS?

Another. example is that estimates of employees in the EPZs are not provided nor are separate estimates of school children and l individuals in institutions. Such estimates have been made for SS (e.g., NRC Feb. 82 report by M. Kaltman) and nay well have been used in evacuation time estimates, but are not available in Sec.

2.6.5 of the State plan. Further, the sectoral designations are not directly congruent with evacuation planning areas, whose l boundaries are defined by such entities as political units and l bodies of water.

6. Traffic control responsibilities between State and locals are not clear.

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7. KI policy is established in an unsigned letter. This letter should be -

signed by appropriate officials. Quantities, storage and distribution should be addressed. -

8. You may wish to reconsider the concept of the IFO. Problems have been identified in other States in use of similar facilities.

9. Phone lists need"to be complet,ed and numbers with 24-hour coverage identified.

10. We suggest that procedures should be established to verify messages received by NHCDA from State Police prior to any action being taken

• on the message.

The State of New Hampshire will assume the lead role f;r radiological health for Seabrook. The RAC is concerned that the State have adequate resources to carry out this responsibility. Improved documentation of resource allocation (including timing and procedures for activation of augmentees) among the State EOC, EOF, IFO and monitoring teams will be essential.

Additionally, because of the larger year-round and transient populations at Seabrook, more detailed procedures for alert and notification, sheltering, and evacuating the public will be necessary. Provisions for evacuation of school children will be important as well.

The means and frequency of public education, given the large transient popula-tion will also need more detailed explanation in the plan.

If you have q'uestions, please call Sharon Stoffel at 223-1197.

Sincerely,

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Edward A. Thomas, Division Natural & Technological Hazards -

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CERTIFICATE-0F SERVICE h[NRC 5 SEP30 fig:ja I, Brian P. Cassidy, state that I served a copy of FEMA's Position As To Scheduling Offsite Emergency Planning Issues by mailing in a Oed SEvlbi BRA CH

- envelop upon the parties identified in the attached service list on this 27th day of September,1983.

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BRTM-P. CASSIDY i

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, SERVICE LIST

' Helen Hoyt, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nulcear Regulatory Commission Washington, D.C. 20555 Dr. Jerry Harbour Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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Dr. Emmeth A. Luebke Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Roy P. Lessy Office of the Executive Legal Director U.S. Nuclear Regulatory Agency Washington, D.C. 20555

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Edward L. Cross, Jr., Esq.

George Dana Bisbee, Esq.

Environmental Protection Division Office of the Attorney General State House Annex Concord, NH 03301 l

Jo Ann Shotwell, Asst. Attorney Office of the Attorney General Environmental Protection Division .

One Ashburton Place, 19th Floor l Boston, MA 02108 l

l Nicholas J. Costello l 1st Essex District Whitehall Road Amesbury, MA 01913 -

Sandra Gavutis

! Town of Kensington, New Hampshire ,

RFD I East Kingston, NH 03827 Edward J. Meany Town of Rye, New Hampshire l 155 Washington Road Rye, NH 03870 L

Beverly H3111ngworth 7 A Street Hampton Beach, NH 03842 Mr. Robert J. Harrison President and Chief Executive Officer Public Service Co. of New Hampshire P.O. Box 330 Manchester, NH 03105 Robert A. Backus, Esq..

116 Lowell Street P.O. Box 516 Manchester, NH 03105 Senator Gordon J. Humphrey U.S. Sentate Washington, D.C. 20510 (Attn: Tom Burack)

Thomas G. Dignan, Jr., Esq.

Ropes & Gray 255 Franklin Street Boston, MA 02110 Atomic Safety and Licensing Appeal Panel

• U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Jane Doughty Field Director Seacoast Anti-Pollution League 5 Market Street Portsmouth, NH 03801 Calvin A. Canney City Hall i 126 Daniel Street Portsmouth, NH 03801 Roberta C. Pevear

, Town of Hampton Falls, New Hampshire l Drinkwater Road Hampton Falls, NH 03844 William S. Jordan, III, Esq.

Ellyn R. Weiss, esq.

Harmon & Weiss 1725 I Street, N.W.

Suite 506 Washington, D.C. 20006 Phillip Abrens, Esq.

i Assistant Attorney General

! State House Station #6 l

Augusta, ME 04333 l

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5 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission

• Washington, D.C. 20555 '

John B. Tanzer Town of Hampton, New Hampshire 5 Morningside Drive Hampton, NH_ 03842 Letty Hett Town of Brentwood

.RF0 Dalton Road Brentwood, NH 03833 Docketing and Services Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 David R. Lewi s , Esq.-

Law Clerk to the Board Atomic Safety and Licensing Board U.S. Nuclear and- Regulatory Commission Washington, D.C. 20555 Town of North Hampton North Hampton, NH 03862 R.K. Gad III, Esq. .

Ropes and Gray 255 Franklin Street Boston, MA 02110 Patrick J. McKeon i Chairman of Selectmen, Rye New Hampshire 10 Central Road Rye, NH 03870 Anne Verge, Chairman .

i Board of Selectmen i Town Hall' South Hampton, NH 03842 l

F Mr. Maynar3 B. Pearson Town of Amesbury, Mass, i

40 Monroe Street .

Amesbury, MA 01913 Senator Gordan J. Humphrey l 1 Pillsbury ' Street Concor d, NH 03301 l (Attn: Herb Boynton) 1 l Charles Cross, Esq.

Shaines, Madrigan, & McEacher 25 Maplewood Avenue P.O. Box 366 l

Portsmouth, NH 03801 -

l rege a REVIEW 0F GREENLAND, N.H. -KEY RADIOLOGICAL EMERGENCY RESPONSE PLAN A -Idequate R - Adequate, but minor change needed

• 1 - Inadequate LOCAL PLAN i NUREG CROSS ADEQUATE STATE RESPONSE SEPTEMBER 8,1983 RAC C0petENTS

!'RITER10N REFERENCE INADEQUATE l

1-15 thru l-25 I The plan identifies local, State Federal, Utility, and ls.l.a private sector organizations that are response organizations for the emergency planning zone. Missing from the plan is the host community that will provide facilities for reception centers and mass care shelters for evacuees from Greenland.

Figure 4, p: 1-24, does identify 5 host communities for Seabrook EPZ evacuaes; however, no spect ficity by twn is indicated. The town of Greenland may also wish to consider the use of the County Agricultural Extension Agent as an advisor on agricultural matters in the town's EOC.

The RAC has a general concern about the resources of the iden-tified response organizations.' Many organizations do not appear to be adequately staffed for their identified response functions; this issue is dealt with specifically throughout the reviews.

There may be a need for planning to deal with how these resources j

can be supplemented during an emergency.

< n.l.b I-15 thru l-25 B On page 1-21, the roles of the two Federal coordinating agencies,

! FEMA & NRC, are not properly identified. As is properly specified in Figure 1.4-1 of the State Plan FEMA and NRC have a joint 4

coordination function with FEMA taking the lead for federal non-

' technical support. ,

2 Even though the actual host community has not been l identified, the role of such has been identified.

\.I.c I-23 & I-24 A The plan illustrates the inter-relationships of response j organization in 2 block diagrams; one showing the Greenland local

• Organization, and the other showing showing the State's response .

i scheme (which included locals and Federal organizations).

)n.l.d I-15 A The plan identifies the Chairman of the Board of Selectmen as the indivic' val who is in charge of all emergency operations for the town of Greenland.

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Page 2 REVIEW OF GREENLAND M.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN fH;7,EG CROSS ADEQUATE STATE RESPONSE SEPTEMBER 6,1983 RAC COMMENTS glTER10N REFERENCE INADEQUATE

.l.e 11-2 thru 11-8 i The plan does not indicate that a 24 hr. capability exists now; A-1 thru A-3 once the pocket voice pagers are purchased (presumably having a sufficient range to reach from Br2ntwood to Greenland),

there should be 24-hour per day capability of manning communica-tions links. Appendix C, part B. p. C-6, indicates that " tone receiver (s)" for the Chairman of the Board of Selectmen and his alternate are proposed, and not existing. Presently, the only means of notifying the police of ficer on call (referi to non-duty hours, when there is no direct access to the police radio) is by commercial telephone, and likewise for the Selectmen and -

Civil Defense Director / Fire Chief, who are also designated to be notified directly by the Rockingham County Dispatch Center.

Currently, there is no indication in the plan that there exists 24 hr. capability for emergency response. In Appendix A. Lines of Succession, there are no back-ups listed for the local emer-9ency response functions of Civil Defense Director / Fire Chief.

Police Chief. Health Officer. Highway Agent and Town Clerk.

- Furthermore there are no individuals at all identified to per-form the key functions associated with the first Deputy Fire

' Chief (communications & EDC), the second Deputy Fire Chief

'(transportation & EMS) and RADEF Officer.

. 2. a 1-25 A - Responsibility Matrix on p.1-25 specifies Greenland emergency Section 11 response functions. Section 11 of the plan describes these functions and responsibilitites for the key individuals.

I-7 A more detailed breakdown of authorities are needed, such as is

. 2.h B found on page 1-3 of the State Plan. Specifically, RSA 107:10 I applies to cities and towns.

.3 Appendix C 1 There are private emergency support resources identified in the State Plan plan which do not fall under law, or statute, or regulation; thereby requiring some kind of written agreement or under-standing. Specifically, in Appendix C, page C-3, Highway Department Inventor' y , three private contractor firms and two towing companies are listed. .

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. REVIEW OF GREENLAND, N.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN NCEG CROSS ADEQUATE SEPTEMBER 8,1983 RAC COP 94ENTS STATE RESPONSE

RI TfRION REFERENCE INADEQUATE 1.3. I Agreements also need to be negotiated for (cont'd.) bus companies, the telephone company (if any special services are planned for), and volunteer agencies whose services are to be relied upon.

1.4 I-17 I There is no indication in this plan that there 11-12 is a capability'for continuous operations on a A-1 thru A-3 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis. In fact. Appendix A indicates a clear insufficiency of personnel resources.

See comment A.I.e for examples of insufficient staffing.

Additionally, the police dept., which is fully staf fed (3 people) is assigned the functions of: notification and comunications, traffic and access control, and providng security.

This seems like more than e a man police. force can handle without specific arranged outside assistance from other governments.

The Director of Civil Defense will, in behalf of the Selectmen, be responsible for coordina-ting support resources for an emergency response.

C.I.c- 11-13 A A meeting room in the EOC and commercial telphones are available to support the Federal response.

C.2.a State Plan. . N/A A State responsibility. No local LdC represen-t tatives dispatched to the EOF.

C.4 I-19 thru l-22 Il-13 I The plan indicates that requests for assistance from surrounding communities will be secured in accordance with existing mutual aid agreements. The organizations and facilities are not identified and letters of agreements are not included. Other additional needs will be

requested through the State EOC in Concord. ,

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REVIEW OF GREENLAND, N.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN NUREG CROSS ADEQUATE .

SEPTEMBER 8,1983 RAC COMMENTS STATE RESPONSE CRITERION. REFERENCE INADEQUATE l

j 0.3 1-26 thru l-27 A Emergency Classification scheme is consistent with that .

of the Utility.

U.4 -

I-28 I Table 3 on p.1-28 summarizes the response levels fcr Section IV the town of Greenland for each of the 4 EAls. For the 2 EAL categories of Site and General Emergency, there is i

an inconsistency with the State Plan regarding the function of pubitc alerting. Specifically, the State Plan in Section 2.1.4 (p. 2.1-7) states that NHCDA

- will order th< activation of the public alert system at the Site Area EAL. However, the Greenland plan, in Table 3, states for both the Site Area and General -

i Emergency levels that, "NHCDA will forewarn local i officials when and if... The "If" should be deleted to be consistent with the State Plan.

In Section IV of the plan, procedures are given for each of ficial for all for emergency action levels.

Discussions of these procedures will be found later '

in this review under the specific functional areas to which they apply.

! 'The procedures in Section IV of this plan can at best

• be described as vague. The reason for this is the very structure of the plan itself. In Section lit, pre-emergency procedures, many basic planning tasks are assigned to town officials which must be implemented and/or resolved before the emergency response procedures in Section IV can be implemented.

, in redlity, most of Section 111 constitutes a checklist d

of planning tasks to be accomplished in order to have a complete emergency response plan. For example; the selectmen are supposed to davelop in conjunction with, the fire chief and school superintendent the towns projected. transportation needs and ensure they are satisfied. 'How do they ensure this (page 111-1)?

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Page 5 REVIEW OF GREENLAND, N.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN Nt2EG CROSS ADEQUATE STATE RESPONSE REFERENCE INADEQUATE- SEPTEMBER 8,1983 RAC COMMENTS

• RI TER10N 4.4 I On page 111-2, the selectmen are supposed to assess deficiencies in supplies and equipment, report them (cont'd) to the NHCDA, and ensure these needs are satisfied. How?

The Civil Defense Director / Fire Chief: Duties include developing transportation requirements for town with exception of pubile school, determine availability i of transportation resources and compare with needs etc.

l Assist school supt. develop his. plan; (pages 111-3 8 4)

Based on what?

Deputy Fire Chief: Transportation & EMS: Develop j internal procedures for handling requests for transportation from people without automobiles and with special needs (p. 111-9); meet with representatives of special facilities to assess transportation needs (p.111-9), etc.?

RADEF Officer: Maintain proficiency in procedures for issuing and using dostmeters and survey instruments (p. 111-10). Where are the procedures for using instruments, particularly for decontamination monitoring? What kind of training will RADEF Officer have? Will he be assigned or certified by the State Radiation control group?

Police Chief: Develop Ilst of police personnel who should attend training; and review manpower requirements for pubite alerting, traffic management, and security operations in Greenland (p. 111-11). Based on what?

Health Officer: Be familiar with methods of evaluating *

( radiation exposure and of transporting contaminated

' individuals. What methods? Where are they in the plan?

(p. 111-13). What kind of training will Health Officer have?

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• REVIEW OF GREENLAND, N.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN i LOCAL PLAN .

NCEG CROSS ADEQUATE STATE RESPONSE

, RITERION REFERENCE . INADEQUATE - SEPTEMBER 8,1983 RAC C0pelENTS I.1 con't I Highway Agent: Designate area for impounding contaminated equipment and articles; develop list of public works personnel needing training; ensure adequate manpower and 4 equipment are available. How? (p. 111-15) i Town Clerk: Become laelliar with the administrative operation of the EOC. Where in the plan is there an S0P for operating an EOC7 (p. 111-15).

All of the above items should be considered as being l part of the planning process. It is a good plans .

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development concept to work with town officials to .

' develop information and procedures of the types

- referred to above; however, this should occur during I the planning formulation stage, not as a part of

• the plan itself.

j j lt is suggested that the entire Section 111 be dropped 4

from the plan. As information is developed, it should be integrated into the body of the plan so that it can 4

. 'be used by the town emergency workers as the working tool its designed to be.

1 in place of Section Ill, you may wish to substitute a

' section siellar to that found in your local plans for Vermont Yankee, Preparedness Functions. Some of the 1

material in the current Section lit appropriately falls under this category.

.I 11-2 thru 11-4 1 The NH State Police Hdqtrs will notify the Greenland IV-25 (Only Police Officer on duty or on call through the -

IV-45 thru 53 because Rockingham County Dispatch Center. The police officer Appendix C equipment will verify the message, then notify key town Appendix F not officials. There would also be simultaneous direct notif-j available) ication of the selectmen and the civil defense I

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I rage i REVIEW OF GREENLAND, N.H.

. RADIOLOGICAL EMERGENCY RESPONSE PLAN

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LOCAL PLAN NUREG CROSS ADEQUATE REFERENCE . INADEQUATE SEPTEMBER 8,1983 RAC C0f9 TENTS STATE RESPONSE

[.RITERION C.I con't I director / fire chief via pocket voice pager (not yet avail'able) from the Rockingham Dispatch Center.

This redundant notification serves as back-up in i case the police officer on duty or call is unavailable.

Notification for schools is included in Appendix F.

i Reliance on " tone receivers" for notification are 4

indicated to be " proposed" in Appendix C, part f.

If school is not in session, the principal of Greenland Central School reports to the Greenland

EOC to evaluate the school system's emergency response.

I f Section IV of the plan contains notification pro-i cedures consistent with the emergency classification l

and action level scheme.

E.2 IV-thru 1 thru 4 B There are procedures in place for the selectmen, 4 IV-13 & 14 civil defense director / fire chief, and of course IV 44 thru 53 the police officer on duty or or call to notify, j alert and mobilize Greenland emergency response

' personnel. However, it should be noted that j

these procedures contains a considerable amount of

reduncancy in that you could have four selectmen and the civil defense / fire chief simultaneously trying to notify town emergency workers (and each 4

other) when the police officer on duty or call is not available. This could be confusing.

E.5 11-2,3,9 8 10 I The public is to be alerted via a yet to be designed public alerting system (consisting of strens, tone activated radios, and mobile pubile address

.i units). The State Plan indicates that the public

. alerting system will be activated at the Site

! Area Emergency Classification. This should be

! indicated under " notification" on p.11-2 and 3.

i Also, see first paragraph of comment D.4. Upon

' hearing.(or hearing of) the alert signal, the

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REVIEW DF GREENLAND, N.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN _

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' LOCAL PLAN NUREG CROSS ADEyVATE SEPTEMBER 8,1983 RAC COMMENTS STATE RESPONSE

] 0: ITER 10N REFERENCE INADEQUATE t.5 can't public should tune in a EBS radio station. Five are listed on p. 11-3; however, no indication is given of which FBS stations cover a particular 1

EPZ area. It would also be helpful if the locations of the EBS stations were given on p.11-3 of the plan. No indication of 24-hour coverage by EBS stations is given or how the

• stations will be activated off-hours. In Appendix C,

p. C-13, the chart does not indicate which station (s) have CPCS status.

Any EBS television stations which are planned to be used to relay official information in an emergency should be 11sted. If not then the reference to

them on p.11-3 should be dropped. Release of infor-

' mation from the Media Center and rumor control are a

. State level responsibility. However, how is the toll free number (when determined to the public? Via Greenland town selectmen in their public information role with the local news media? See Comment E.7.

E.6 11 9 thru 10 1 Since the design for the Public Alerting System is IV-18 still under development, procedures are lacking j  ; for activating the public alerting system (p. IV-18) 11-2 4

and no inventory exists of the physical means for l

carrying out the alerting process by strens. tone i

activated radios, and mobile public address units.

Siren coverage is not determined, tone activated radio requirements have not been established, and -

! the numbers (equipment and personnel) and routes J"

of mobile public-address units have not been j . identified.

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.7 IV-7 thru IV-10 -I The State is responsible for coordinating and generating all pubile information messages over I

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- REVIEW OF GREENLAND, N.H.

. RADIOLOGICAL EMERGENCY RESPONSE PLAN I

LOCAL PLAN 4 FlUREG CROSS ADEQUATE STATE RESPONSE INADEQUATE SEPTEMBER 8,1983 RAC COMMENTS ~

ItI1ERION REFERENCE

'.7 con't I the EBS system. The State Plan, in Appendix C will contain these protective action messages, once they are developed.

The Greenland Plan assigns responsibility to the selectmen for approval of news releases specific to Greenland, prior to their being made public (p.IV-6).

Attachment I has samples of these news releases for each protective action option. This is confusing since this is a State responsibility. 'Also, the nature of these pre-written messages appear more appropriate to Appendix C of the State Plan. Thit; inconsistency needs to be cleared up.

r l.a. 11-2 item 11-8 A See first paragraph of comments for A.I.e. In addition to the above referenced connents, the

. police radio network can provide an alternate communications link to the commercial telephone

. system at the EOC location.

To insure implementability, it would be most preferable for each local EOC to have a dedicated telephone link to NHCDA at the St *e EOC. This way, the potential problem of oversoading a e

rural telephone system would be avoided, and instantaneous communications could be assured.

Page 10 REVIEW OF GREENLAND, N.H.

RADIOLOGICAL EMERGENCY RESPONSE PIAN LOCAL PLAN NDREG CROSS ADEQUATE ,

SEPTEMBER 8,1983 RAC COMMENTS STATE RESPONSE t:RITERION REFERENCE INADEQUATE F.1,b. Il-8 *I Some radio communication links with other local Appendix C. EOCs are proposed or non-existent as indicated

p. C-7 & 8 in Appendix C. Considering the large number of local EOCs, coenercial telephone communications could be very awkward. A description of the capabllttles of the proposed 46.58 radio network

.are needed to avaluate it. Is this part of the short-wave ama.Lur radio band frequency range, or a secure statewide radio frequency? Direct communication with the State of Massachusetts and the Utility are a State responsibility.

F.1.c 11-8 N/A No direct communications with federal emergency 11-13 response organizations; requests for support and resources beyond local communities are directed to the State EDC.

F.1.d State Plan N/A A State responsibility. However, it might be useful to have a system in place 50 that locals could receive frequent updates on events occuring at the plant.

F.1.e  !!.2 thru 11-4 I See A.I.e and E.1.

IV-44 thru IV-53 F.2 Il-6 i The plan indicates that the Greenland ambulance communicates with local hospitals over the HEAR l radio network. It is assumed that this refers to the fire department ambulance identified in i Appendix C, p. C-2. No discussion is given concerning which hospitals are involved and other ambulance sources.

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- REVIEW OF GREENLAND, N.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN 1 .

LOCAL PLAN .

, flDREG CROSS ADEQUATE

XITERION REFERENCE INADEQUATE SEPTEMBER 8,1983 RAC C0petENTS STATE RESPONSE

.3 11-30 A Table 5 (p.11-30) describes the town's communications drills between the State and local agencies as occurring monthly. The State Plan, in Table 3,1-1 (p. 3.1-2), identifles a quarterly schedule. .These g schedules should be coordinated.

.I and 11-9 I The plan indicates that NHCDA and Utility are responsible

State Plan

• for pubile education and information development and dissemination with input from Greenland officials. This local input process, especially information about special-needs population is never clearly spelled out in either the 1 local or state plans. .

Once the pubile information and education program is com-pleted for Seabrook copies of all appropriate materials

' - be included in the local plans for reference by emergency response staff.

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'.3.a 11-10 1 There appears to be a confIlct between the local and state

plans regarding media interaction with local officials. On

j. page 2.3-13 the state plan, in referring to the Media Center, j states: "This is the only facility where new releases will be prepared and distributed, and where official spokepersons i will interact with media. "This is the only location which wl11 I provide this level of supporTTor3 Hews media c',uring the

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i emergency response.'~ On page T.7-IT it states: "None of tee other

! state.or local facilities will be prepared to support media

! acitivities and media representatives will be requested to go to the

; Media Center." Yet the Greenland plan'on page 11-10, it states

i "Ouring emergency periods, the selectmen assume the responsibilities

. for public information in Greenland they will deal with the. local news media." Moreover, it states that a media briefing room I will be established in the selectmen's office. These provisions seem to be in conflict with the state plan, which apparently

, prohibits media contact with local officials.

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• REVIEW OF GREENLAND. N.H.

' RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN NUREG CROSS ADEQUATE SEPTEMBER 8,1983 RAC COMMENTS STATE RESPONSE

CRITERION REFERENCE INADEQUATE G.4.a 11-10 1 -If the state plan is changed to permit local interaction with the media, limited to local issues, then a specific selectmen or alternate should be designated as the Greenland spokesman.

G.1.b 11-10 I If the above change in the state plan is made, then the current provision for coordination of local press releases with the Media Center is appropriate.

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G.4.c 11-10 1 NHCDA will staff a rumor control center which the public State Plan can contact via a toll free number. No number is given in the plan.

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, r. 5 11-9 A The ennual news media briefing is a joint State and Utility

!!I-2 responsibility. Greenland officials will, however, participate.

' 11 . 3 11-11 1 The town office building will serve as the Greenland EOC.

This is not sufficient specificity. Review of the E0C facility will be accompilshed during the exercise, a

H.4 11-11 1 List of EOC staff to be activated to man the EOC is on p.11-11.

To be consistent with this staffing pattern, the Notification 4

Fanout Scheme on p.11-4 should also list the positions of

RADEF Officer and the two deputy fire chiefs. Similarly,

' the notification lists in Section IV of the plan should include these 3 staff personnel in the Site and General Emergency categories.

H.7 11-11 thru.12 I The fire department has 5 CDV-777-1 kits on hand, which j

StateiPlan should include 1 CDV-700,1 CDV-715, and 6 CDV-742 self- '

C-14 reading dostmeters (high range). It is indicated that NH CDA will provide Greenland with CDV-138 and CDV-730

' ' low range self-reading dostmeters and CDV-700 survey instruments. It is not clear, however, when the equipment

' will be provided, and in what quantitles. Also not 1

indicated is where the fire department will store its equipment. ,

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rage na REVIEW OF GREENLAND, N.H.

• RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN huREG CROSS- ADEQUATE SEPTEMBER 8,1983 RAC COMMENTS STATE RESPONSE

RI TERICM REFERENCE INADEQUATE t.10 11-11 thru 11-17 I This is the responsibility of the RADEF Officer; however, there is no person ~1dentified to carry out this function, 1.11 Appendix C I Complete listing of the quantity of radiological equipment and supplies needed at the EOC is not available.

1.12 State Plan N/A A State responsibility.

I.f 11-15 N/A State responsibility.

1.8 11-15 N/A State Responsibility. .

I.2 Appendix E T Evacuation Time Study was not included with the Greenland Plan. It is bound separately and will be reviewed at a later time when available in

, sufficient quantities.

l.9 II-16 thru 11-21 A Cn p. 11-24 (Table 4), PAGs consistent with EPA's 11-24 are given for recommended protective response actions.

It would be useful to incluje in local plans PAGs for human foods and animal feeds too, i.IO.a Appendix E I Appendix E is bound separately. Evacuation routes, evacuation areas, and the reception' facility . - f7 (Woodman Park School, Dover, NH) are identified on 3J..

the " Town of Greenland Facilities and Evacuation h Routes" map included in the sleeve. However, this kf)6 map sh'ows certain evacuation routes going to nowhere. .

Specifically, one evacuation route seems to go directly I into Pease Aire Force Base. Another route shows traffic directed to Rt. 108 then neglects to show '

what direction Rt.108 follows. Radiological sampling and monitoring points identification is the responsibility of the State. It is not clear if the reception area in Dover will also serve as

- REVIEW OF GREENLAND, N.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN NUREG CROSS ADEQUATE SEPTEMBER 8,1983 RAC COMMENTS STATE tESPONSE CulTERION REFERENCE INADEQUATE J.10.a con't I a shelter. More planning in the area of reception center / mass care center designation is needed.

J.10.b I-12, 1-14 I Appendix E was not available for review. Page 1-14, Appendix E Figure 2 provides the distribution of population in i

the 10-Mile EPZ ring. However, the entire EPZ population is not included nor the entire area of Greenland to be evacuated (which is the entire town).

J.10.c 11-9 I General procedures are presented on p. 11-2. However, Appendix F specific instructions on the use of the Pubile Alerting System are not included on p. IV-18.

J.10.d 11-9 1 Appendix F does not inc*!ude procedures for protecting Appendix F the mobility impaired. No estimates are given for the number of mobility impaired requiring transportation or the means of transport. Pre-emergency procedures for the CD Director / Fire Chief (p. 11-3) and the Deputy Fire Chief-Transportation and EMS indicate that transportation needs will be developed. These needs must be identified and detailed procedures developed for protecting mobility impaired individuals.

J.10.e 11-21 N/A State responsibility. Any local resources needed to assist the State in distributing K! should be identified in the local plan.

l J.10.f 11-21# N/A J.10.g 11-18 I Private vehicles are indicated to be the primary thru transportati_on mode. The plan states that special ,,

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11-20 arrangements have been made for institutionalized

• people, students in school, people without autos, and people with special needs. Plans for the public school and kindergarten are included in Appendix F. ,

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• Page 15 REVIEW OF GREENLAND, N.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN NC:EG CRUSS ADEQUATE

. SEPTEMBER 8,1983 RAC COMMENTS, STATE RESPONSE HITERION REFERENCE INADEQUATE I.10.g con't I No estimates are provided for the number and avail-ability of busses and drivers required. No indication j is given as to whether formal written agreements have been made with the bus companies. Detailed arrange-i ments for institutionalized, non-auto owning, and special needs people are not provided, nor is an estimate made of the number of persons who would be involved in these catergories.

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A reception center at the Woodman School in the

]l.10.h Il-18 1 Dover, NH host community has been designated.

thru 20 i

However, is this the only " relocation" facility i planned for use by the residents of Greenland? If

, so, we question the adequacy of this facility to serve as both a reception / mass care shelter and a decontamina- 4 tion center.

l.10.1 Appendix E I Projected capacity of evacuation routes under 4

emergency conditions will be reviewed separately

- as part of the Appendix E review. However, there is no evidence that Appendix E has been incorporated i into local plans.

I.10.j 11-17 I Greenland Police Chief is responsible for controlling IV-41 thru 43 access at two intersections in Greanland. The plan does nbt indicate sufficient resos fes for the police

' department to carry out this function and all the

! other functions assigned to it by the plan. There also does not appear to be sufficient traffic control equipment for the police to do the job.

I.10.k III-3 I The Highway Agent ensures that adequate manpower IV-57 and equipment are available for emergency maintenance

, III-14 of evacuation routes. Specific needs are not identified i C-3 (although they may be in Appendix E, which is bound

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Page 16 REVIEW OF GREENLAND H.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN l NUREG CROSS ADEQUATE STATE RESPONSE INADEQUATE SEPTEMBER 8,1983 RAC COMMENTS gtITER10N REFERENCE i _ separately), and based on these needs, specific l.10.k con't- I emergency procedures for the Civil Defense Director / Fire t

Chief and the Highway Agent are not presented. Appendix C contains lists of resources and equipn.ent but adequacy is dependent upon identification of needs for. emergency maintenance of evacuation routes.

' l.10.1 Appendix E I No time estimatas provided in plan. Although adoption of Appendix E is a State responsibility, the information i

in its findings must be made available to EPZ communities. .

.J.12 11-20 . N/A State has responsibility along with the host community for these activities.

State Plan 4

i K.3.a 11-22 thru 11-24 1 State plan (p. 2.7-2) prvides a list of equipment that is IV-32 thru IV-37 to be available in a local EOC. No indication in the j

Greenland Plan that this equipment is available, partic-ularly TLD availability and numbers of direct-read dosimeters that are available. No clear indication that

' 24-hour per day capability exists for determining doses i

received by emergency workers. Provisions for distribution of dostmeters unfulfilled because a RADEF officer has not been designated. State Plan also indicates (Section 2.7.2) that dostmeters will be issued at the " Site Area Emergency" this is not as stated in the local plan.

1 K.3.b  !! 22 thru 24 I The frequency at which dosimeters will be read is not indicated in the plan or included in any SOP. Intervals i

IV-32 'thru 37 Intervals of 15 to 30 minutes are generally satisfactory, unless radiation fields are above 1 R/hr; adjustments f

in the intervals can be made according to the magnitude of the radiation field. The Personnel Dose History Record (p. IV-36) should record radiation levies in f "mR" rather than " CPM".

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• Page 17 REVIEW OF GREENLAND, M.H.

RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN NCIEG CROSS ADEQUATE STATE RESPONSE REFERENCE ' INADEQUATE SEPTEMBER 8,1983 RAC COMMENTS

RITER10N

.4 II-23 I The local plan is inconsistent with the State Plan, in that it states: "The Director DPHS authorizes exposure in excess of PAG guidelines, except for Ilfesaving situations."

The State Plan assigns the authority to the Director, DPHS, for authorizing all exposure in excess of PAG guidelines (including lifesaving) for all State and local emergency

. workers.

.5.0 II-24 II-23 1 State Plan indicates the need for decontaminating personnel and State Plan and equipment at the action level of 100 CPM above -

background. The local plan, on p.11-23, specifies 200 CPM. This inconsistency needs to be cleared up.

.5.b  !!-22, 11-25 1 Specific procedures and locations for monitoring and decontamination of emergency response personnel are not included. There are no details on the disposal and State Plan of contaminated wastes.

.1 II-25 I The two primary hospitals (Portland & Exeter) are located in the EPZ. In the event of a general evac-

• uation, will the hospitals also be evacuated? If not, what alternate protective actions are planned for?

.4 Il-25, IV-55, I Greenland Health Officer is responsible for this function.

No arrangements are apparant in the Ikalth Of ficer's

. III-13 Emergency Procedures for transportation of radiological victish to medical facilities. Also, the wording in the plan (pg. 11-25) is confusing concerning the interface between the Health Of ficer and the State (DPH), and volunteer agencies relating to the care of contaminated and/or injured individuals.

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' REVIEW OF GREENLAND, M ll.

RADIOLOGICAL EMERGENCY RESPONSE PLAN LOCAL PLAN tlUREG CROSS ADEQUATE STATE RESPONSE INADEQUATE SEPTEMBER 8,1983 RAC COMMENTS C,RITER10N REFERENCE 11-26 I General plans and procedures for recovery and reentry 1.1 are not described.

fl. l .a . 11-27 thru 30 A Reference to Annex R of the State Plan is obsolete.

Correct reference should be Section 3.0.

1.1.b II-27 thru 30 A I Communications between State and local agencies tested 1.2.a II-27 thru 30 monthly. However, Table 3.1-1 of State Plan Indicates -

a quarterly schedule.

4.2.c 11-27 thru 30 A Emergency medical drills are to occur annually.

3.2.d II-27 thru 30 N/A Radiological monitoring is a State responsibility.

In Table 5 (p.11-30), Radiological Monitoring Drill category is not appropriate. It could be changed to reflect a dosimerty drill.

1.3.a-f 11-27 thru 30 A 1.4  !!-27 thru 30 A I The Civil Defense Director / Fire Chf er is responsible

't . 5 11-27 thru 30 for attending the Federal Critique, but it is not clear whether this individual is responsible for assigning tasks to implement corrective measures or exercise management control of such). .

fl.1 II-31 thru 40 A NHCDA and the Greenland CD Director / Fire Chief State Plan responsible'for training. An outline of proposed training courses is given in the plan which seems to take into account the local training needs.

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RADIOLOGICAL EMERGENCY RESPONSE PLAN LDCAL PLAN NUREG CROSS ADEQUATE SEPTEMBER 8,1983 RAC COMMENTS STATE RESPONSE

.kliER10N REFERENCE INADE QUATE I.I.b 11-31 A See above comment.

State Plan 8.4.a 11-32-40 A Note 0.4.b (accident assessmentj) not applicable.

thru 11-15 A State responsibility 1.4.j ,

'.1 I1-31,'111-5 A The CD Director / Fire Chief and selectmen will be State Plan present at all local training courses. .

'.2 1-15 I Not clear if the chairman of the Board of Selectmen or the CD Director is responsible for planning.

'3. 1-16 A CD Director responsible.

i t'.4 I-16 A CD Director responsible.

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'5 . 111-5 A -

'6 I-8 and 9 I At this stage of plan development. many supporting plans have not been developed.

' .1 Sec IV I See comment for D.4.

'*8 . v1 - vii A Appendix D l

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. 111-2 A CD Director responsibility.

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