ML20083Q571

Testimony of FEMA on Emergency Planning Contentions

ML20083Q571
Person / Time
Site:	Catawba
Issue date:	04/16/1984
From:	Hawkins T, Heard J Federal Emergency Management Agency
To:
Shared Package
ML20083Q566	List: ML20083Q571
References
NUDOCS 8404230139
Download: ML20083Q571 (39)

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6 TESTIMONY OF FEMA REGARDING EMERGENCY PLANNING

, CONTENTIONS ADMITTED BY THE BOARD IN THE CATAWBA PROCEEDING l- , ,

e h s 01. State your names and positions with FEMA.

Al .

• John C.

%. Heard, Jr. - Chief, Technological Hazards Branch, C s Natural and Technological Hazards Division,

. FEMA Region IV - Atlanta, GA A1. Thomas I. Hawkins - Emergency Management Program Specialist a,

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02. Have each of you prepared a statement of professional qualifir .

l cations?

A2. Yes, a copy of our statements of professional qualifications are attached to this testimony.

03. State the nature of the responsibilities that each of you have had with respect to your review of Catawba nuclear station units 1 and 2 emergency planning.

A3. John C. Heard, Jr.:

As Branch Chief, it is my responsibility to see that the Catawba Nuclear Station Emergency Response Plans for South Carolina and North Carolina are reviewed by the Regional Assistance Committee-(consisting of eight other Federal dept./ agencies) ~and the FEMA Region IV staff to assure that all-NUREG-0654-FEMA-REP-1, Rev. 1 standards and criteria applicable to State and county government are met. Additionally, I have reviewed the South Carolina,.

j North Carolina, and County Radiological Emergency Response Plans for the Catawba Nuclear Station. I have also reviewed the ob-jectives and the scenario of tl.. February:15-16, 19841 exercise, which were developed jointly by Duke Power Company officials and representatives from South Carolina and North Carolina. I par-ticipated_as a Federal evaluator at the North Carolina State i Emergency Response Team (SERT ) Headquarters during the February 15-16, 1984, exercise. I reviewed and approved the post-exercise assessment report of the Catawba exercise.

Thomas-I. Hawkins:

i I have reviewed the North Carolina and South' Carolina State and

. local ~ radiological emergency response plans for the Catawba Nuclear. Station; I have-observed and assisted in the development

of the objectives and scenario for the exercise of those plans; i I observed and evaluated the S.C. FEOC operation during the exercise, and I have written a post exercise assessment report l of the Catawba exercise. All of these efforts were accomplished' I as partcof my responsibilities as the emergency management pro-gram specialist assigned to the liaison position between FEMA-

-Region IV~and the States'of North and South Carolina.

O 3 T PDR .

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04. What is the purpose of this testimony?

A4. The purpose of this testimony is to address joint intervenors contentions numbered 1, 3, 6, 7, 8, 9, 11, 14, 15 and 18.

Cententicn 1 Contention 1 provides:

See next page.

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• f b' <. c D r- r 5 b% f7 IMERGENCY PLANNING CONTENTIONS NOV 161933

1. public information provided by Applicants and state and )

local officiala is not adequate to ensure appropriate responses ,

to notification procedures.

The principle source of information la Applicant's brochure, which La inadequate, intentionally deceptive regarding potential health effe=ta of radiation, and sfaleading, in that:

A algnificant body of acientific evidence that ind,feates health effects e,t very low levels of radiation la not cited.

Therefore, people with compelling reasons to stay (such as '

farmera tending to 11 vast,ock) may not take the threat seriously, especially after being repeatedly told in the past that radiation la not particularly harmful, and that a serious accident is extremely unlikely. It does not indicate that there la danger in accumu3ated radiation dosage. It does not give adequate information on protection from beta and gamma raya. It does not speeffy how young "very young" is. There- is no chart to indleate overexposure during non-routine releases or accident to put into perspective the possible done received before or during an.

• evacuation. It does not specify ingestion dangera from contaminated food and water. It does not specify the imp =rtance of getting to reception areas for registration for purposes of notificat,lon for evacuees * "re-entry to their hoana, nor of' energency notiffeation for evacueen, accounting for fiscal aspects of evacuation and for.the basis of establishing legal ~

elaima which night result.fron the" evacuation, as speeffled,in. ,

" Catawba site Speelfie NUREG Criteria" p. E2,'t3. In fact, citicena are told they may go-directly1 to " stay with friend's or

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relatives living at least 15 miles from the plant" (p. 20 a5 )

Xeither doma it state that the reception armas exist to provide decontar.ination of people an" vehicaea. It states that in an energency~st Catawba, citizens "wou3d be given plenty of tir.e to #

take ne=easary action." This cannot be guaranteed in the event of a audden pressure vesse2 rupture, where sheltering would be indicated. This eventuality is not mentioned. It ammunes all recipienta can read, and at a certain level of cowprehension. As a primary source of information, it la imperative that all have access to and underatending of the energency procedures to'ba taken. There la no information concerning the existence of a

" plume expcaure pathway," which wou3d influence a citizen's choice of ea: ape route. Although thia information may be ava!!able via other media during a crisia, it la Jap =rtant for.

citizens to be aware of this phenomenon beforehand. A3though the North Carolina state plan ca33a for er.ergency inforsation to be distributed an detailed in Part 1,Section IV, 2,3, and 4, no such material other than Applicants' brochure has~been made available. When and if such material is formulated, it abould include information on points of concern as listed in this contention. The emergency brochure falsely reassures residents that they "would be given plenty of time to take necessary action" in the event of an eteigency. In the event of a vessel rupture, auch as one resulting from a PTS incident, a catastrophic failure of the containt.ent is a proximate likelihood. In that event, significant releases would reach o . .

residents well before they were a$le to remove themselves from harm even under Duke's overly optimistic evacuation time , i estimates.

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{ 4 l 05. What are the requirements of FEMA regulations and what is the ,

regulatory guidance with regard to the provision of information to the public for radiological emergency preparedness?

i AS. NUREG-06 54 -FEMA-REP-1/Rev. 1,Section II, G, "Public Education

and Information"

Information is made'available to the public on a periodic basis on how they will be notified and what their initial

actions should be in an

emergency (e.g., listening to a local broadcast station and remaining indoors), the prin-

cipal points of contact with the news media for dissemina-tion of information during an emergency (including the physical location or locations) are established in advance, I. and procedures for coordinated dissemination of information to the public are established.

06. What public information provisions have been undertaken, or are planned for radiological. emergency planning for the

Catawba facility?

A6. State of N.C. Emergency Response Plan, Part I, pp. 53-56;

Gaston County Procedures, Part II, pp. 25-28; necklenburg l

County Procedures, Part III, pp. 27-30. South Carolina Site-Specific REP Plan, Annex "A", pp. A-2, 3; Catawba j brochure;. York County Emergency Operations Plan, Annex D, pp. D-1 to D-5. SCORERP, Annex C, pp. C-1 to C-23.

07. Is information made available to the public on a periodic basis 1 on how they will be notified and what their initial action

{ should be.in an emergency?

A7. Yes. Via Catawba brochures, and,1in N.C.: N.C. Emergency Response Plan, Part I, pp. 53-55; Part II, pp. 26-28; Part-III, pp.-27-29.

• i S.C.: SCORERP, Annex C, Appendix 1,Lpp. C-10, 11; York County Plan, Annex D, pp. D-14, 15. .,

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i' 08. Does the Applicants' brochure.includefsufficientfeducational information on radiation? Explain.

A8. Yes. Regional' Assistance-Committeen(RAC), especially EPA,xDOE,;

and' Department of Health.and Human Services.(DHHS) representa-tives, have reviewed the brochure and found it adequate. Serv-

! ing on the RACiare several health physicists and at least one nuclear engineer who have-approved the brochure for. technical.

I and; educational adequacy.

0 9 ~. Does the brochure give adequate warning ofEthe L health ef fects  ;

of low levelJradiation',--the danger.of accumulation of.radia-1 tion,.and:information regarding protection from-betaEand gamma radiation? Explain.

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4 A9. Yes, pp. 4, 5 of the brochure clearly states types of radia-tion, their effects and what protective steps can be taken.

Q10. Is there need for a chart in order to inform the public how to cctimate dose? Explain.

A10. While there it no FEMA requirement for such a chart, the brochure chart (p. 5), is helpful in understanding sources and amounts of radiation on a comparative basis.

011. Is it necessary that the brochure specify dangers from inges-tion of contaminated food and water? Explain.

All. No, the planning standard and criteria of NUREG 0654 do not require that dangers from ingestion of contaminated food and water be specified in a brochure; however, the brochure does provide that water, milk and food supplies will be monitored on page 9 (bottom).

012. Is the reference in the discussion of radiation in the bro-chure with respect to "very young" adequate? Explain.

A12. While the NUREG standards do not require an explanation of radiation with respect to the very young, the brochure does explain on page 4 (tottom) that the very young are more likely to be harmed by radiation.

Q13. Does the brochure provide adequate information on how the pub-lic may obtain additional information? Explain.

A13. Yes, emergency management officer phone numbers are listed on the front inside cover.

Ql4. Does the brochure provide adequat.e information for protective measures, e.g., evacuation routes'and relocation centers, sheltering, respiratory protection, radio-protective drugs?

A14. Yes, page 9, through remainder of brochure satisfactorily complies with the criteria of G.l. of NUREG 0654. There are no provisions for administc.;ng radio-protective drugs to the general public in the i.c~th Carolina or South Carolina plans. Also, information is provided in the York County plan, page Q-26.

015. Does the brochure contain sufficient information concerning the existence of a " plume exposure pathway"? Explain.

Y

A15. While there is no reference to " plume exposure pathway", the brochure explains that if there were an accident at Catawba Nuclear Station, that the areas affected would depend on wind speed and direction (brochure, page 9).

Ol6. Is the brochure deficient in that it does not state that recep-tion areas exist to provide decontamination of peop'e in ve-hicles? Explain.

A16. No, page 10 explains that shelters would have facilities for decontamination of evacuees and their vehicles.

017. Is the brochure deficient in that it does not specify the im-portance of registration for purposes of (a) notification re-garding later reentry of homes by evacuees, (b) emergency nucification of evacuees and (c) establishing legal claims of evacuees? Explain.

A17. No, the specifications of the importance of registration is not required by NUREG 0654. However, the purposes of regis-tration are indicated on page 10 of the brochure.

018. Is the brochure inadequate because the level of comprehension is inappropriate? Explain.

A18. No, it is comparable to other brochures of the region reviewed and accepted by the RAC and FEMA. Also, the general public brochure is supplemented by a student brochure.

Q19. Is the brochure inadequate because it indicates there is suf-ficient-time available to take appropriate action? Explain.

A19. No. In the event of a large release, sheltering may be a more appropriate protective action if adequate time is not avail-able for evacuation. . .

Q20. Is there adequate information regarding the special needs of the handicapped? Explain.

A20. Yes, the front inside cover advises the handicapped to inform the emergency agency of their special needs.

Q21. Have the principal points of contact with the news media for dissemination of information during an emergency (including the physical locations) been established in advance? Explain.

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A21. Yes, these contact points are established in accordar.ce with l I

NUREG 0654 and listed in the following plans: SCORERP, Annex C, p. C- 3 ; S.C. Site-Specific, pp. A-2, 3; York County Plan, p. D-2; N.C. Emergency Response Plan, Part I, p. 56; I Part II, pp. 26-27; Part III, p. 28.  !

022. Have procedures for coordinated dissemination of information to the public been established? Explain.

A22. Yes, and these procedures are listed in the following plans:

SCORERP , Annex C, pp. C-9-ll; York County Plan, Annex D, pp. D-6-9; S.C. Catawba Site-Specific, Annex A, p. A-22; N.C.

Emergency Response Plan, Part I, p. 55-56; Part II, pp. 27-28; Part III, pp. 28-29.

023. Based upon your review, is the brochure adequate and is the emergency planning standard regarding public information--

satisfied? Explain.

A23. Yes, using NUREG Planning Standard G, all five evaluation criteria, the RAC and FEMA have approved the brochure.

Contention 3 Contention 3 provides:

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The energency plana do not provide for adequate facilities er.ergency and equipnent to support the omrgency response as '

required. by 10 CFR 50.47 (b) (S) in that:

a) the plana do not provide for sufficient food, clothing, and bedding for para =na uneentaminated who are evacuated. The plan does not attenpt to eet:aate these neede nor provide specific iniornation on how they are to be set.

b)

The p3ana do not denonatrate that the unlikely proposition Just 14 reception center / shelters are adequate t o register and process a o r,e 75,000 evacuena.

Indeed, the Catavba Nuclear Station Site Specific plan (Part 4, SCORERP) provides that "all evacueen, both those ordered and those spontaneous, will be proccaaed through their respec'tive reception centers" (p. B-2).

With no clear plan for controlling entry and exit from the rsception centers, and no restrictions on who say enter, it la very likely that reception centers will boccae overcrowded.

Persons from outside

• the evacuat1en ares *will be understandably concerned about whether or not they have been exposed to radiation and r.ight well proceed to a nearby rec eption center --

oxacerbating probJens  !

of crowding that already loor. as serious  !

given the enornity of the taak of processing- EPZ evecueen reception centera at with limited apace and supplies.

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Q24. What is the purpose of relocation shelters?

A24. The purpose of relocation shelters is to register evacuees, monitor and decontaminate evacuees and vehicles if necessary, and to provide food, shelter and medical assistance to those evacuees who might need it for a limited period of time.

Q25. Do the State or Federal regulations require, or regulatory guidance provide, that evacuees must be processed through relocation shelters?

A25. No.

Q26. From FEMA's experience, what level of usage of relocation shelters by evacuees relying on such centers for shelter and a place to stay during an evacuation would-be expected?

Explain.

A26. Natural disasters experience indicates that approximately 20%

of evacuees avail themselves of relocation shelters.

027. Do the plans adequately provide for " sufficient uncontaminated food, clothing, and bedding for persons evacuated"? Explain.

A27. These provisions are not required by NUREG 0654 to be contained in the plans; however, the brochure asks evacuees to bring bedding and extra clothing.

Q28. What are-the plans for controlling entry and exit from the relocations centers?

A28. There is no NUREG 0654 requirement for controlling entry and exit from relocations centers; however, shelter SOP's gener-ally contain these procedures.

029. Will the fourteen relocation shelters be able to adequately register and process the number of evacuees asserted by joint intervenors (85,000)? Explain.

A29. There are 38 primary shelters, not 14, and over 100 shelters.

Also, as indicated in A26. above, only approximately 20% of the total 85,000 figure can reasonably be expected to seek public shelter.

Q30. Do NUREG 0654 standards require that provisions be made for sufficient shelters and uncontaminated food, clothing and bedding for evacuees?

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A30. No , NUREG .06 54 requirements regarding shelters are confined to requiring that the means for registering and monitoring evacuees at relocation shelters be described. This require-  !

ment has been met by the plans submitted.

Contention 6 Contention provides as follows:

See next page.

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6. The energency plana do not provide reasonab3e assurance that adequate protective weesures can and will be taken I1O CTR 50.47 (a)(1)3 in that:

c) There are no adequete proviatona for preventing contaminated peracna from entering a non-centaminated zone. The p3ana do not make claer whether or not registration at a

• reception center / shelter la mandatcry or not; if mand tory, by what procedures will it be enforced and what effort will these procedures have on evacuation times and treffic flow?

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031. Is there a requirement that registration at relocation shel-ters is ma'ndatory? Explain.

A31. No. This is an option of the individual. Facilities are provided and their use encouraged.

032. Would provisions for registration at relocation centers have an effect on evacuation times and traffic flow? Explain.

A32. No. Shelters are outside EPZ, and located so that they do not affect evacuation times.

033. Is it necessary that plans provide for preventing contaminated persons from entering a non-contaminated zone? Explain.

A33. No. There is no NUREG 0654 requirement for this prevention.

Q34. Are there such provisions for Catawba? Explain.

A34. No. There are provisions for decontamination, however.

035. Does failure to require registration at relocation shelters prevent a finding that emergency plans do provide reasonable assurance that adequate protective measures can and will be taken pursuant to NUREG-0654-FEMA-REP-1/Rev. l? Explain.

A35. No.

Contention 7 Contention states:

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7. The App 11cints' emergency plans and public brochure and f the plans of the relevant State and local authorities do not adequately address the preparations that should be made to achieve effective sheltering, nor the actions that people should take when advised to seek shelter. Hence, the plans and brochure fail to provide a reasonable assurance that adequate protective measurer can and will be taken in the event of a radiological emergency as required by 10 CFR 50.47(a)(1).-

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• 036. What pre-planned creparations are necessary for effective sheltering i. , event that protective action sheltering is required in a radiological emergency?

A36. No pre-planned preparations are required by NUREG 0654 for in-place sheltering.

037. What provision is made to advise the public of preparations that should be made for effective sheltering?

A37. Brochure and listen to EBS and follow instructions.

038. Are the applicant's emergency plans and public brochure ade-quate to inform the public with regard to preparations that should be made to achieve effective sheltering and what actions the public should take when advised to seek shelter?

Explain.

A38. Yes. As stated in A36. above, no preparations are required by NUREG 0654. The actions the public should take when advised to seek in-place shelter are given in the brochure and will be given in the EBS messages.

039. Are the plans of the State of South Carolina and the State of North Carolina adequate with regard to preparations that should be made to achieve effective sheltering and advising the public wnat actions they should take when advised to seek in-place shelter? Explain.

A39. Yes. These sections adequately advise the public of actions they should take when seeking shelter. S.C.: SCORERP , .

Annex C, page C-17; N.C. State Procedures, Annex D.

040. Do the plans of the appropriate local authorities adequately address the preparations that should be made to achieve shel-tering and indicate the actions that the public should take when advised to seek shelter? Explain.

A40. Yes. These sections adequately advise the public of actions they should take when seeking shelter: York County Plan,

p. Q-26, and Annex D; Mecklenburg County Plan, Part 3, p. 31; Gaston County Plan, Part II, pp. 29-20.

Q41. What standard of NUREG-0654-FEdiA-REP-1/Rev. 1 does this con-cern relate to?

A41. J.10.m.

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042. Does this concern with regard to adequacy of preparation for effective' sheltering and advising the public as to what actions should be taken when seeking shelter prevent a find-ing that this standard is satisfied? Explain.

A42. No, as explained above, the NUREG 0654 requirement relevant to the concerns raised by Contention #7 has been determined by FLMA to be satisfied.

Contention 8 -

See next page.

Q43. Describe the assignment of primary responsibilities for emer-gency response in the emergency planning for Catawba.

A43. SCORERP , p. 7: In accordance with State law and written agree-ments (table 7.7), te Department of Health and Environmental Control (DHEC) and the Emergency Preparedness Division (EPD) have been delegated the authority to coordinate off-site RER planning, training and response. Their duties are: DHEC -

Technical radiological control; EPD - Operational control.

Specific responsibilities of State agencies are listed on pages 11-19 of SCORERP and on pages 55-58; local government responsibilities are also listed in SCORERP on pages 55-58 and on pages 19-20; York County Plan, pp. 5-12 (also see chart of responsibilities p. 18). (The Departments of Crime Control and Public Safety (DCCPS) and Human Resources (LHR) have the

, primary responsibility for responding to emercencies resulting from an incident at the Catawba Station. However, any State agency may be tasked with an emergency mission.) N.C.:

charts: Part I, State, pp. 28-30 (and p. 26); Part II, Gaston County, pp. 14-18; Part III, Mecklenburg County, pp. 12-16.

044. Do the emergency plans of the States of North and South Caro-lina and the counties of Mecklenburg, Gaston and York assign clear and effective primary responsibilities for emergency response and specific responsibility of the various support-ing organizations? Explain.  %

A44. Yes, see A43. above, and, these assignments of responsibilities worked well in the Catawba exercise last February.

045. What arrangements have been made with respect to primary re-sponsibilities while the North Carolina State Emergency Re-sponse Team (SERT) assembles and travels from naleigh to the South Carolina Forward Emergency Operations Center (FEOC)?

Explain.

A45. SERT does not travel from Raleigh to the South Carolina FEOC but locates at Douglas Airport. The N.C. area coordinator assists counties until SERT arrives at Douglas Airport.

County governments are in charge of operations until the State assumes control in both South and North Carolina.

2. There la no reasonable easurance that adequate protective amasures can and will be taken in the event of a radiological

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energency in that .the energency plans of Applicants, the States of North Carolina and South Carolina, and the Counties of Xecklenburg, Caston and York fail to saalgn clear and effective primary rea~ponsibilities for er.ergency response and fail to -

establish specific resp nalbilities of the various supporting organizations. .

Conflict, confusion and lack of co=rdination are likely to prevail.

Conditions any be the worst during the 7 to 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> .

after notification of state autherities of the existence of an accident at the Catawba Station while the North Caholina State Er.ergency Response Team (SERT) masambles and travels from Raleigh to the South Carolina Torward Emergency Operations Center (TEDC),

located dangerously within the 10 miles EPZ at C1over, South Carclina. _

The TEOC itself would require .

at least three and one-half hours to be anaembled and staffed from Colunbia, South Carolina. While the formal authority to order evacuation of tha plume expcaure .

pathway EPZ atraddling the North Carolina-South i

Caroline border rests with the respective state gover nors, a

• confusing and' ineffective array of consultative and delegati ve authority appears to cloud the lines ef primary responsibilit y.

T'he realdual reapenalbilitima of the

• respective County governments, agencies and the support organizations are either unspecified or inadequate to the task of effective protective response.

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' l Q46. Do the respective emergency plans of the State, and the local i government's provide for clear effective assignment of primary responsibilities for emergency response during the period of time that it would take to establish and staff the FEOC?

Explain.

l A46. Yes, local governments in both States would be in charge of emergency response during the time it takes to establish the SERT and the FEOC.

047. What are the standards of NUREG-0654-FEMA-REP-1/Rev. 1 that relate to the conc ~ erns raised by the intervenors in this contention?

j A47. NUREG 06 54, "A. Assignment of Responsibility", "H. Emer-

! gency Facilities and Equipment", "P. Responsibility for the Planning Effort: Development, Periodic Review and Distribu-tion of Emergency Plans".

048. Addressing the appropriate evaluation criteria, have the pri-mary responsibilities for emergency response b: the State and local organizations within the emergency planning zone been assigned? Explain.

A48. Yes. All items under Planning Standard "A", NUREG 0654. but one, have been approved by the RAC and FEMA. (Evaluation

criteria item A.3. was found deficient in both States in the latest RAC plan review due to absent and/or inadequate letters of agreement from private sector agencies.

J 049. Have the emergency responsibilities of the vnrious supporting i organizations been specifically established? Explain.

A49. Yes. York County Plan, pp. 5-12; SCORERP , pp. 55-58; local government responsibilities also listed in SCORERP, pp. 55-58.

N.C.: Part I, pp. 28-30; Part II, pp. 14-18; Part II, pp. 12-16.

050. Has each principal response organization been staffed to re-1 spond and to augment its initial response on a continuous basis? Explain.

A50. Yes. N.C.: Part I, pp. 26-27; Part II, p. 15; Part III, c. 15.

1 S.C.: SCORERP, p. 11; York County Plan, p. 12.

051. Have the respective State and local facilities and centers provided for timely activation and staffing enabling a find-ing consistent with standard "H" that adequate emergency facilities and equipment to support the emergency response are provided and maintained? Explain.

18-a A51. Yes. Generally, emergency facilities and equipment have ,

been found' adequate by the RAC and FEMA. (Evaluation cri-teria item H.ll. has been questioned in the South Carolina plan review. We expect this to be corrected and noted in the State response before May 1, 1984. Plan provisions which address this question are as follows: SCORERP, p. 39, pp. 67-69, pp. 55-58; York County Plan, p. 15, 0-34-36, N.C. Emergency Response Plan: Part I, pp. 82-85 and Part II, pp. 39-42; Part III, pp. 41-45 and Attachment 3.

052. With respect to Planning Standard "P", have the plans made adequate provision fcr an assignment of responsibilities for plan development and review and for distribution of ener-gency plans and proper training? Explain.

A52. Yes. N.C. Emergency Response Plan, Part I, p. 99; Part II,

p. 47; Part III, pp. 50-51. SCOREFG: Annex B, p. B-1, p. 12,

p. 38. York County Plan: p. O-39, p. 8, p. 12; Site-Specific Plan: p. 20.

Contention 9 Contention 9 provides:

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The plana do not adequately provide for the early notification and clear instruction to state and local resp =nse I

organizations and the public that are required by 10 CTR -

50.47(b)(5) in that: "

Secondly, if the airena do mound, not all citizens who would be affected and therefore require notiffeatien would be a bl e to hear a warning airen. "Such a attuation could arise as a result of heering impairments, weather conditions, distance from sirena, etc.

c) In the event of a power eutage the public's access (and possibly the access of state and leral authorities with energency reapensibilities) to emergency broadcast information could be -

seriously inpaired. [Without a specifle, reasonable plan to deal ^

with auch a contingency, the energency plana do not meet 10 CTR 50.47(b)(E) as well as (b)(5).J g) For exanple, neither the Carowinda TheEe park nor the Heritage U.S.A.

re'11gious retreat appear to have any notification plans or procedures.

A conservative entirate of a peak ausser crowd at Carowinda la 30,006 to 35,000 people.

• For auch a crowd to be notified and given instructions on how to leeve the park in a quick, orderly, and safe manner clearly requires acae set of speelal procedures that la yet to be formulated.

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053. What provision is made for notifying the public of an emer-gency at-Catawba and advising the public of actions to take?

A53. The S.C. Site-Specific Plan states " fixed and mobile sirens in the 10 mile EPZ are used for alerting the populace" (S.C.

Site-Specific Plan, p. 3). "The primary means for initial verbal notification of residents in the 10 mile EPZ of Catawba Nuclear Station will be the local Emergency Broad-cast Stations (EBS), while the primary means for follow-up EPI will be the SC-ETV" (York County Plan, D-7). Five pri-mary EBS stations are listed for York County (York County Plan, D-8).

In North Carolina, fixed sirens serve as the primary public alerting system within the 10 mile EPZ in Gaston and Mecklen-burg Counties. Emergency service vehicles equipped with sirens and public address (PA) systems and operated by emer-gency services and law enforcement personnel provide a back-up system. (N.C. Annex C, p. C-2. For additional de-tails see N.C. Part 2, pp. 22-24; N.C. Part 3, pp. 20-23.)

EBS for the Charlotte area will be activated following sound-ing of the sirens. Details concerning the emergency situa-tion and conditions and instructions or protective actions will be included in EBS messages. (N . C . Annex C, p. C-3.)

The plan lists one Common Program Control Station (CPCS) and 40 other EBS stations. (N.C. Annex E.) These stations moni-tor the CPCS and can rebroadcast the message.

Additional information on how to respond to protective action recommendations, including in-place sheltering and evacuation, is detailed in the public information brochure which is dis-tributed to all households in the 10 mile EPZ.

The public warning and notification system in North Carolina includes water areas on Lake Wylie and the Catawba River.

Aircraft, boats with and without sirens and PA systems, and marina radios will be used to warn people on the water. The National Weather Service Radio Broadcast System, in addition to EBS, may support operations, if needed. (N.C. Annex C,

p. 2.)

During the exercise in February, 1984, effective coordination of sirens and EBS messages were demonstrated in York, Gaston and Mecklenburg Counties.

054. Is the siren system adequate to provide early notification to the persons'in the EPZ (plume) (1) generally, (2) who have hearing impairments, (3) who are inside homes with perhaps competing sounds from TV programs and record players, and (4) who are asleep, giving consideration in each case to the effects of veather conditionc such as snow or excessive winds with howling or strong wind noise? Explain.

A54. Alert and notification systems have been satisfactorily opera-tionally tested periodically. The official, engineering and agoustical testinc will be accomplished utilizing guidance pro-vided by the publication entitled FEMA 43 at some future date.

055. What consideration, if any, is given in the emergency plans of the State and local governments or the plans of the applicant with respect to the possibility of a power outage affecting prompt notification due to the inability because of the power outage of radio and TV stations to operate and further in-ability of residents to hear a message at their homes when the power at their homes is out? Explain.

A55. Plans for North and South Carolina describe mobile sirens and alerting systems that could serve in the event of a power out-age. (S.C. Site-Specific Plan, p. 3; York County C-4; N.C.

Annex C, p. C-2.) The North Carolina plan provides a back-up system, whereby emergency vehicles would be dispatched along preassigned routes, and stop every h mile in populated areas to issue a verbal announcement. (N.C. Part 2, pp. 23-24, Part 3, p. 20.) The plan goes on to state that, "if necessary, door to door alerting will be accomplished by the back-up warning system." (N.C. Part 2, p. 22, N.C. Part 3, p. 20.)

The CPCS EBS station should continue as an effective means to transmit messages during a power outage as official EBS sta-tions are required to have emergency generators. Persons with battery operated radios should receive tF2 message over the radio in the event of a power outage at home.

056. What provisions have been made for notification of special facilities such as Carowinds Theme Park or the Heritage U.S.A.

Religious Retreat? What assurance is there that the poten-tially large number of persons at the facilities will be prop-erly and timely notified of an emergency at Catawba and ad-vised as to necessary protective ac(ions? Explain.

A56. In a conversation between Region IV staff and a Duke Power Company representative on March 19, 1984, the utility per-sonnel stated that tone alert radios will be supplied to the Carowinds Theme Park and the Heritage U.S.A. Religious Retreat to assure early notification of events occurring which might require protective actions. Evacuation plans have'been developed by owners of these facilities which discuss how notification of persons will take place and describing pro-cedures for their evacuation. In Heritage U.S.A., security patrol officers will make house to house and building to building searches to notify persons of evacuations. The Carowinds plan details procedures for preparing for an evac-uation, notifying guests, and carrying out the evacuation.

(Duke Power Company transmittal of March 21, 1984, including both evacuation plans.)

057. Do the concerns expressed by the intervenors in this contention prevent a ~ positive finding pursuant to NUREG-06 54-FEMA-REP-1/

Rev. l? Explain.

A57. No, but a standard caveat would be included in the approval that the alert and notification syctem will be officially evaluated by FEMA at a future date.

Contention 11 i

Contention 11 provides:

The size and configuration of the northeast quadrant of plume exposure pathway emergency planning zone (Plume EPZ) surrounding the Catawba facility has not been properly determined by State and local officials in relation to local emergency response needs and capabilities, as re-quired by 10 CFR 50. 47 (c) (2) . The boundary of that zone 4 reaches but does not extend past the Charlotte City limit.

l There is a substantial resident population in the south _

west part of Charlotte near the present plume EPZ boundary.

Local meteorological conditions are such that a serious accident at the Catawba facility would endanger the resi-dents of that area and make their evacuation prudent. The likely flow of evacuees from the present plume EPZ through Charlotte access routes also indicates the need for evacua-tion planning for southwest Charlotte. There appear to be suitable plume EPZ boundary lines in southwest Charlotte.

The boundary of the northwest quadrant of the plume EPZ should be reconsidered and extended to take account of these demographic, meteorlogical and access route condi-tions.

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057a. Based on your review of the State and local plans, what is your conclusion regarding the adequacy of the present con-figuration of the northeast quadrant of the plume EPZ for Catawba?

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A57a. First, the present configuration meets the "about 10 mile" requirement of 10 CFR Part 50.

Second, FEMA finds the configuration of the northeast quad-rant of the plume EPZ to be sufficiently adequate to insure that the general public in this zone can be promptly notified and be able to take appropriate protective actions in a timely fashion.

t Contention 14 Contention 14 provider,:

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14. The Applicanta have failed t'o der.cnatrate their ability to take effective actions to protect the health and anfaty of the general public in the event of an accident in that the evacuation time study presented by the Applicants is a piece of fiction in the gulae of scionee and may not be relied up n for determining the ability of Applicanta and public authorities effectively to evacuate realdents of the Catawba EP2 in a timely manner.

By overestinating the flow of traffic on evacuation routes,

• the Applicants' time study overestimates actual traffic acvaeent by a facter of between three and twelve. A flow of no more than 900 vehicles / lane / hour should be assumed, according to pr elie.inary entie. ate s by Dr. Sheldon C. plotkin of the Southern Califernia Tederation of Scientista.

Traffic flows are further overestimated by failing to account for voluntary evacuation likely to take place from Charlotte via 1-77. All of the study's estimates are premiard They fail to only on estimates of traf fic flow within the EP2.

account for backups caused by extra-EP2 congestion, especially on

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1-77 in Charlotte.

The Applicants' evacuation time., estimates erroneously assume quick response by school buses and multiple a=hool bus trips.

School busca in South Carolina are driven by high school kids.

No public official would dare'to send high school kids into an evacuation zone to transport those without vehicles. Ti e.e must 1

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The Applicants' study la fundamentally uselena to making a deterrination regarding the time within which evacuation can be accorplished in that it makes numerous assumptions r*5arding work and living habits which are apparently ande up out of whole -

cloth. No references or other data bases are given for the assumptions u,nderlying these evacuation tir.e eatinates and they cannot be credited.

The evacuation time estimates should be based only upon l

worst esse cenditions, rather than beat case conditions. The -

- Applicants" study la far too optimistic in assuming that worst t

a case conditions will require only 155% of the time of beat case conditions. The sudges are asked to take notice of their own experience in Applicants' counsel trying to reach York, south Carolina, in the sidst o,f what say be a modest snowstors to Yankee eyes, but which had plainly ir.r.cbilized the entire vicinity.

Turther, Applicants' study naively fails to account for parenta going first to their children's schools to pick up their w

children before evacuating.

Moreover, Applicants' study, by alight of hand, diantanes the anser lapact of the presence of large tr-naient popuistions at Carowinda amusement park and Heritage USA. Those populationa will take longer to evacuate than the study assures and will co-congent I-77 with realdent traffic.

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il The fundanental tost of the adequacy of an evacuation plan la whether it can be imp 2esanted in auch a fashion as to effectively avoid or r.inir.1 e the radiological effe=ta of a

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radiation release. Absent a real life, reel time evacuation drill to test the ayaten, any study presented in support of the evacuetion drill to test the system, any study presented in support of the adequs=y of the energency plana rust be technically valid fror, a theoretical perspective and based upon aamunptions' heving aer.e relationship to the real world attuation to which the study la supposed to apply. This study lacks either baaim.

A sore realistic estiaate of evacuation tiae for the Catawba Nuclear Statio:. in the South Carolina Piedmont la that evacuation will require a sinimum of 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />, masur.ing a conmarvative 600 vehicles / lane / hour vehicle travel tiae.

Applicants are, thus, unable to provide reasonable azaurance of being able to avoid or seaningfully minialze radiation exposure L

in the event of a radiation re: ease at, Catawba.

The Applicants thus fail to seet the requirsent of NUREG 0654, Rev. 1, Appendix 4, in that their eva=ustion tir.e estimates may not be credited by the C=maission and fall to acet Conalsalon requirements that it be able to der.onstrate the ability of local and state authorities to take effective protective actions.

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t 058. Have you reviewed the licensee's study concerning evacuation time estimates?

A58. Yes.

059. What did your review consist of?

A59. FEMA reviewed the Evacuation Analysis in light of State and local plans.

060. Do you find that the assumptions used in developing the evac-uation time estimate (i.e., number of buses and bus drivers to evacuate children, adequacy of traffic control and parents coming into EPZ to pick up children) are reasonable? Explain.

l A60. Based on our review of State and local plans and the "Evacua-tion Analysis" we find that the assumptions concerning the

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evacuation time estimates are reasonable.

! Contention 15 l Contencion 15 provides:

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15. The App 11canta and the local and state Plans fail to provide adequate assurance that effective protective actions can he takan because the provisions in the several plans are f

inadequate with regards to transportation and related evacuatery activities in the event of an evacuation.

The energency plans fail, fundanentally, to address the peculiar conditicns cf the areas surrounding the Catewba Nuclear Some of Statien. Large segnents of these arena are rural.

ther. cent air. Iower in=one cor.nuni ti e s . The time estimates used by Applicants assune that 10x of families are without vehicles.

But 17. nany cf these henes, that vehicle la n=t home during large parta cf the day. Often, those homes will have children and elderly pe ple at home without transportation. No census of j

varying conditiens has been done.

I I E=reover, the plans are premised on using. achool buses to transport those without their own tranportation. School buses in Even if some South Carolina are driven by high school students.

public official were prepared to leave esargency a=tivitica 1n' the hands of air. teen year old youths, none would dare send auch a child into an evacuation zone. No provision is made for back-up 1

drivers. Even if the drivers can be found, in many comeunities not those scho$1 buses are kept at the driver's hese et night an at some central motor pool.

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Applicants and the local and state planning officials have are failed to desenstrate that adequate tranportation facilities available to eve =uate the h=apitala and nursing hopes in the EPZ. ,.

have been Nor do the plana demonstrate that adequate previsions fac!!ities.

sade for tranaperting y ung children at day care Numercus parents have inf=rmed members of Palmetto A111ance will be that in the event cf an evacuation their first resp:nse

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to pera=nelly pick up their children regardlema of peper plana.

The state and local plans fell to addreas this reaction which will a3 w evacuation and add to confusion.

aland den =natrates that many The experience at Three .ti l e S utherners citizens will not leave the face of a sa3er threat.

have a special ecznitrent to lar.d and here which no government to date has ben able to cvercer.e. Absent a full-scale exercise which der.cnatratead that these hard-headed Sectch Irlahpen are going to leave, no assurance can be had that the public will

- leave in the event of an evacuation order.

The energency plana manuse, but do not demonstrate, that adequate buses are available to move school children out An a tirely renner. F.ultiple bus pickups may be needed.

Evacuation plans which f ail to assure that hur.an beinga dand not computer redelled fa: air.iles thereef--are to be evacuated and local -

cannot but fail in the test. Applicants and atste amaurance that the plana emergency planners are ut,able to provide effectively irplemented to protect the residenta.

can be ,

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061. Do the State and local emergency plans adequately consider, with regard to transportation and related evacuation activi-ties in the event of an evacuation, the fact that: (1) seg-ments of the EPZ are rural, (2) some part of the population I will not have personal vehicles for evacuation, (3) some i households have only one vehicle which is not at home during i a large part of the day, and (4) the homes have children and elderly people at home without any transportation at all?

Explain for each item what provisions have been made.

A61. (1) Yes. Knowledge of population distribution is basic to the preparation of any evacuation time study. Swremaries of evacuation times by sector is included in both the North and South Carolina plans as is the population in each sector (N.C. Part 1, p. 62, N.C. Operations map; S.C. Site-Specific, 4

p. 14).

I (2) (3) & (4) The Gaston County plan states that " pick up i points will be established for those without transportation.

These evacuees should start walking to the nearest traffic control point." (N.C., Part 2, p. 31.) For Mecklenburg l County, the Charlotte Department of Transportation has the ,

responsibility of dispatching buses to designated pick-up points. In addition, school buses may be used to transport j evacuees. (N.C., Part 3, p. 33.)

The S.C. plan states that, " persons in the evacuated areas who do not have transportation, and those confined who re-i quire special transportation, will be provided means for ,

j evacuation by using all available transportation within York

{ County and through Mutual Aid Agreements with nearby counties, j State assistance will be available upon request." (S.C.

i Site-Specific, p. 17.)

l Elsewhere, the plan reiterates, " York County will utilize all available school buses and county owned vehicles to transport any residents without transportation. Non-ambu-latory residents will be transported by the Piedmont Medical Service (ambulance) and York County Rescue Services (ambu-lance capabilities). Residents without transportation will j be transported to their predesignated shelters." (S.C., York County, 0-25.)

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The Transportation Service Coordinator is to develop and main-i tain a transportation resources list by type and availability, i

develop procedures for obtaining buses and other vehicles from j adjacent counties in accordance with mutual aid agreements,

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develop and maintain a list of drivers, and do other necessary i functions to prepare for an emergency evacuation. (S.C., p. L-3.)

. The Duke Power Company brochure advises individuals to call

! the emergency agency in their area if they are without trans-portation. It also urges residents to make plans now if members of the -family are sometimes home without transportation. /

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062. What provision is made for transportation to evacuate the hospitals 'and nursing homes in the EPZ? Explain.

A62. According to the Evacuation Analysis, there are no hospitals or nursing homes in the North Carolina portion of the 10 mile EPZ (Voorhees, p. 10.) Nevertheless, the North Carolina Plan provides for the transport of non-ambulatory persons. The Gaston County Plan specifies that, "non-ambulatory patients will be transported by the county rescue squads. Mutual aid agreements with the rescue units in surrounding counties will be implemented when necessary." (N.C., Part 2, p. 31.) For Mecklenburg County, the plan states, "non-ambulatory patients will be transported by MEDIC. Mutual aid agreements with rescue units in surrounding counties will be invoked where necessary." (N.C., Part 3, p. 32.) In the York County Plan, it states, "all available resources will be used to provide transportation for non-ambulatory patients, lame and insti-tutionalized persons and those persons who do not have pri-vate means of transportation. Vehicles of the county, public and private, and volunteer organizations will be used to the maximum extent possible. Ambulance for hospitals and nursing homes will be coordinated through the Emergency Medical Service." (S.C., York County, L-1, L-2.) Hospitals and nursing homes are to " develop plans and procedures for evac-uation of hospitals and nursing homes, if required." (S .C. ,

York County, H-5.) The two hospitals and their capacities in the 10 mile EPZ are listed (S.C., York County, H-15) but the nursing homes are not listed in the plan.

063 What provision is made for transportation for young children at day care centers in the EPZ? Explain.

A63. There is no discussion of transportation of children in day care centers. According to the Evacuation Analysis, while there are several day care centers in the South Carolina por-tion of the 10 mile EPZ, there were Ju3 day care centers in the N.C. portion of the 10 mile EPZ. (Voorhees Study, p. 10) 064. Do the State and local emergency olans provide for parents who will personally attempt to pick up their children at school regardless of any direction? Explain.

A64. No. State and local plans do not discuss effects of parental attempts to pick up their children at school. The public information brochures adequately describe plans for the evac-uation of school children and list shelters where parents are to pick up their children.

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i 065. Do the State and local plans provide for those individuals who will not leave in the face of a major threat? Explain. i l

! A65. The plans rely on voluntary compliance.of individuals with i evacuation orders. '

t 066. Do the State and local plans provide for the fact that l multiple bus pickups may be necessary to evacuate school children in a timely manner? Explain. ,

A66. The North Carolina State Plan does not discuss a need for multiple pick-ups, stating, " students in public school sys-tems will be transported on school buses and other available transportation to shelters." (N.C., Part 1, p. 58.)

i The South Carolina Plan discusses the possibility of multiple bus pick-ups as follows: "The 26 public and 5 private schools l

located in the 10 mile EPZ will be evacuated by assigned school buses and available privately owned vehicles to their predesignated shelters. Each school has immediate access to school buses that are parked on the school grounds. Addi-i tional school buses as required will be dispatched to schools to transport the remaining , school students. School teachers

• with their own vehicles will also transport students. No

! student driver will be required to drive back into the EPZ.

A return trip will be made by county emergency workers or others designated by county authorities." (S.C., York County, 0-25.)

j 067. Have the State and local plans made provision for the use of transportation using school buses driven by 16 year old youths given the concern that such youths might not be sent into an evacuation zone? Explain.

j A67. The plans do not discuss the use of sl6 year old bus drivers.

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068. What are the applicable standards'and appropriate evaluation

. criteria with regard to the concerns raised by joint inter-

, venors in this contention?

A68. NUREG-0654 provides the standards for evaluating this condi-i tion. Appropriate NUREG eierents are as follows: J.8.,

Evacuation Analysis; J.10.b., Population distribution; and J.10.d , Mobility impaired.

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069. Do the State and local emergency plans meet these particular mandatory standards and evaluation criteria? Explain how.

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• l A69. N.C. has satisfied the.three NUREG elements above. S.C. has  !

satisfied all but J.10.d., and has been asked to provide further information regarding this subject. The RAC is con-I cerned that there is no listing of "special facilities," with

! the number of occupants, for the mobility impaired or insti-l tutionalized, nor a listing of resources to assist in the evacuation of this segment of the population.

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, Contention 18 i

Contention 18 provides: -

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18. In the event of an emergency, local telephone systems are inadequate to har.d2e the immensely increaamd volune of telephene ,

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cella. Since net,facation of energency personnel relies upon telephones and ainee these without vehicles are expected to call 4 for a ride, ma]cr parts of the er.ergency cor.r.unications syster.

! will be effe:tively knocked out. This applies especially to the 3

i notification of a hool bus drivers as specified in the plan.

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• l 070. Are the local telephone systems adequate to handle the in-creased volume of telephone calls during an emercency?

Explain.

A70. FEMA Region IV does not have the technical knowledge to answer this question; however, we contacted the Regional Emergency Communications Coordinator (RECC) of the General Services Administration, (NCS), for assistance in answering this ques-tion. The RECC stated that the Charlotte-Rock Hill area

telephone systems had electronic switching devices which should be adequate during emergencies and consequent heavy usage. He also stated that, of course, it is presumed that energency workers would be called in advance of the general 1

public notification of the emergency.

071. What are the applicable mandatory standards and appropriate evaluating criteria with respect to the concerns raised by j the joint intervenors in this contention?

) A71. NUREG- 0 6 5 4 -FEMA-REP-1/Rev. 1 (Item E2)

I 072. Do the emergency plans meet these standards and criteria?

j Explain. -

t A72. The RAC review on March 21, 1984, of the Catawba Plans sug-gested five improvements in the North Carolina Plans and seven improvements in the South Carolina Plans. These in-provements have been made or are scheduled to be made, and, when completed, the standards and criteria of SUREG-0654 will have been met.

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• I John C. Heard, Jr.

• Professional Qualifications I joined the Federal Emergency Management Agency in July, 1979. I i

am presently assigned as the Chief of the Technological Hazards Branch in Region IV. In this position, I am responsible for the review of REP's, conducting exercises to test REP's and conducting f public hearings. Members of my staff and I also assist State and t local governments in preparing REP's and coordinating Federal assis-tance.

I served on the Regional Assistance Committee from December 1974 to December 1981. Since December 1981 I have provided staff support for and participated in all RAC activities.

l From July 1973 to July 1979, I was Regional Director, Federal Pre-paredness Agency. The Federal Preparedness Agency was responsible i for fixed nuclear facility off-site planning from December 1975 (Federal Register Notice) until made a part of the Federal Emer- )

gency Management Agency in July 1979. In December 1979, the Presi-i dent assigned off-site responsibility to the Federal Emergency Management Agency.

j Prior to 1973, I was employed by the of fice of Preparedness, Execu-tive Office of the President. I was the representative on an ad hoc Regional Radiological Emergency Planning Committee December 1971 to August 1973. Committee was chaired by EPA and composed of repre-sentatives of Federal department / agencies, State radiological health officials, nuclear power industry representatives, and reprasenta-i tives of the academic community. Federal Register Notice January 1973, published by OEP assigned planning responsibilities to Regional Offices. ,

I My formal education is as follows:

Attended the " Interagency Course in Radiological Emergency Response Planning in Support of Fixed Nuclear Facilities." Course conducted ,

by RAC agencies at Staff College in Battle Creek, Michigan in June 1975.

i Attended " Work Shop - Seminar on State Emergency Planning in Relation  ;

to Licensed Nuclear Facilities." Seminar conducted by Atomic Energy Commission in September 1972 at Oak Ridge, Tennessee. l Completed nine months course at the University of South Carolina from September 1963 to May 1964. Course was entitled " Radiation Protec-tions Institute". Course co-sponsored by Atomic Energy Commission c and South Carolina State Board of Health.

Completed Radiological Defense Officers course, Staff College, i Battle Creek, Michigan, June 1962.  !

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Conducted and served as Principal Instructor for Radiological J

Monitor Instructors Cource, University of South Carolina July 1961.

Completed United States Department of Agriculture Radiological 4

Monitors Course February 1961.

> Assigned as South Carolina Radiological Was issued Defense AEC Officer from By-Products Material

- January 1961 to July 1964.

License from June 1961 until departed State employment to accept Federal employment in May 1970.

i' orientation While on active military duty, attended Atomic Weapont course, Fort Bliss, Texas December 1958.

While on active military duty completed U.S. Army Command and

! Staff College (extension division), " Technical Considerations in

' Employment of Atomic Weapons", March-August 1958.

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d' Thomas I. Hawkins Professional Oualifications My present position is Emergency Management Program Specialist for I am assigned to the .

the Federal Emergency Management Agency.

Radiological Emergency Planning liaison position between FEMA Region In this position, I IV and the States of North and South Carolina.

am responsible for the review of radiological emergency plans and preparedness for the State of North Carolina and the State of South Carolina and for the local governments within these States.

I have held the position of Emergency Management Program Specialist (or its equivalent) since December 1981. I have been employed by FEMA since July 1978.

From April 1964 to January 1977 I was employed as Planning Directort of Clayton County, Georgia.

My formal education is as follows:

- AB Degree, Emory University, Atlanta, GA, 1958

- Master of City Planning Degree, Georgia Tech., Atlanta, GA, 1963

- Completed Radiological Emergency Response Course at the U.S.

Department of Energy's Nevada Test Site, April 1982

- Ccmpleted Radiological Defense Of ficer and Radiological Defense Instructor Course, Georgia Emergency Management Agency, Atlanta, GA, March 1982

- Completed Basic Management Seminar for Emergency Management Personnel, Valdosta State College, Thomasville, GA, Winter Quarter, 1980 ,

- Completed Radiological Emergency Planning Seminar, National Emergency Training Center, Edmitsburg, Maryland, October 1982 G

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