ML20206U896
| ML20206U896 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/14/1999 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20206U878 | List: |
| References | |
| 2.206, NUDOCS 9905260050 | |
| Download: ML20206U896 (20) | |
Text
7590-01-P U.S. NUCLEAR REGULATORY COMMISSION DOCKET NOS. 50-336 AND 50-423 LICENSE NOS. DPR-65 AND NPF-49 NORTHEAST NUCLEAR ENERGY COMPANY ET AL.
RECEIPT OF PETITION FOR DIRECTOR'S DECISION UNDER 10 CFR 2.206 Notice is hereby given that by a petition dated April 14,1999, Mr. Scott Cullen (petitioner), acting on behalf of Standing for Truth About Radiation (STAR), the Nuclear Information Resource Service (NIRS), New York State Senator Ken LaValle, New York State Assembly member Fred Thiele, and New York State Assembly member Patricia Acampora, has requested that the U.S. Nuclear Regulatory Commission (NRC) take action with regard to Millstone Nuclear Generating Station, Unit Nos. 2 and 3, operated by Northeast Nuclear Energy Company. Petitioner requests three specific actions: that (1) NRC immediately suspend Northeast Utilities' license [s] to operate the Millstone power station until there are reasonable assurances that adequate protective measures can and will be taken in the event of a radiological emergency for Fishers Island, New York; (2) the operating license [s] should be suspended until such time as "a range of protective actions have been developed for the plume exposure pathway EPZ [ emergency planning zone] for emergency workers and the public;" and (3) these matters be the subject of a public hearing, with full opportunity for public comment.
As the basis for the request, the petitioner states that Millstone Nuclear Power Station is in violation of 10 CFR 50.54(q) and subsequently 10 CFR 50.47, and also in violation of its operating license [s).
9905260050 990514 gDR ADOCK 05000336 PDR L @IO $ 24v ## 5 I
2 The petitioner states that the law requires that a " licensee authorized to possess and operate a nuclear power reactor shall follow arid maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b) and the requirements in [A]ppendix E of this part."[ref.10 CFR 50.54(q)] Moreover, petitioner maintains that there are not " reasonable assurances that adequate protective measures can and will be taken in the event of a radiological emergency."
[ref 10 CFR 50.47(a)(1)]
Petitioner maintains that the operating license [s] for the Millstone Nuclear Power Station were unlawfully issued and must be revoked. Furthermore, petitioner asserts that prima facie evidence exists to support the conclusion that there are not reasonable assurances that adequate protective measures can and will be taken for Fishers Island, New York, in the event of a radiological emergency at Millstone.
Moreover, petitioner asserts that the initial finding of reasonable assurances by the NRC was arbitrary and capricious. Therefor 6., petitioners maintain that the operating license was issued in direct contravention of the goals of the Atomic Energy Act. Congress has determined that " regulation by the United States of the production and utilization of atomic energy and the facilities used in connection therewith is necessary to assure common defense and security and to protect health and safety of the public." Moreover, the Commission has an " overriding responsibility for assuring public health and safety in the operation of nuclear power facilities "
[ref. In the Matter of Consolidated Edison Company of New York, Inc. (Indian Point Units 1,2, and 3), CLI 75-8, NRCl 7518,173(1975)) Among other things, the Atomic Energy Act charges the Nuclear Regulatory Commission (NRC) with the responsibility for regulation to protect the health and safety of the public. In response, the NRC promulgated emergency planning regulations to allow operation of a commercial reactor if the NRC finds that "there is reasonable
3 l
i assurance that adequate protective measures can and will be taken in the event of a radiological
{
emergency."(ref.10 CFR 50.47(a)(1)] Petitioner contends that at the present time there can be no such finding for Fishers Island and that the operating license [s] must be suspended until such time as a functional evacuation plan can be developed.
Petitioners contend that emergency planning for the Millstone Nuclear Power Station, pursuant to 10 CFR 50.47, has been inadequate to minimize the risk to the health and safety of Fishers Island, New York residents. Fishers Island, New York, is included within the 10-mile EPZ, and the petitioner contends that it does not have a functioning emergency plan.
The petitioner's request to suspend the operating licenses as described in the requested actions (1) and (2) are being treated pursuant to 10 CFR 2.206 of the Commission's regulations.
The request to suspend the operating licenses has been referred to the Director of the Office of Nuclear Reactor Regulation. As provided for by Section 2.206, appropriate action will be taken on this petition within a reasonable time.
Petitioner's request for the immediate suspension of the operating licenses for the Millstone Nuclear Power Station, Unit Nos. 2 and 3 are denied. Title 10 of the Code of Federal Regulations Part 50.54(s)(3) states that "[t]he NRC will base its finding [on the adequacy of emergency preparedness) on a review of the FEMA [ Federal Emercency Management Agency) findings and determinations as to whether State and local emergency plans are adequate and capable of being implemented, and on the NRC assessment as to whether the licensee's emergency plans are adequate and capable of being implemented." FEMA has found that the offsite radiological emergency response plans and procedures, specific to the Millstone Nuclear Power Station, can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken to protect the health and safety of the public in the event of
. a radiological emergency at the site. Further, the NRC has found that the licensee's emergency plans provide an adequate basis for an acceptable state of onsite emergency preparedness in accordance with the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50.
The petitioner's request to hold a public hearing, requested action (3), is denied. This requested action was denied because it did not meet the requirement for granting a public hearing (Part lli of NRC Management Directive (MD) 8.11, page 12-13) in that the petition did not contain new information, with reasonable supporting facts, that raises the potential for a significant safety issue, that results in a significant reduction in the protection of public health and safety, or one that involves the potential imposition of a severity level I or 11 violation.
A copy of the petition is available for inspection at the Commission's Public Document Room at 2120 L Street, NW., Washington, D.C. 20555-0001 and at the local public document rooms located at the Learning Resources Center, Three Rivers Community-Technical College,
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574 New London Turnpike, Norwich, CT 06360 and the Waterford Public Library,49 Rope Ferry Road, Waterford, CT 06385.
FOR THE NUCLEAR REGULATORY COMMISSION irector Office of kuclear Reactor Regulation Dated at Rockville, Maryland, this 14th day of May 1999.
i
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Federal Register / Vol. 55. No. 33 / Friday. February 16, 1990 / Proposed Rules 5603 PART 925--GRAPES GROWN IN A size of the EPZ be reevaluated at least own radiological monitorir.g equipment.
DESIGNATED AREA OF every five years.The petition submitted and that utilities be required to finance SOUTHEASTERN CALIFORNIA by the State of Maine (PRM-5046) the emergency preparedness efforts of 1.The authority citation for 7 CFR requested (1) expansion of the the towns around the nuclear power part 925 continues to read as follows:
emergency planning zone for both plume plants.
exposure pathway and for the ingestion A notice of filing the petition. Docket Authority: Secs 1-19. 48 Stat. 31. as pathway:(2) requiring that emergency No. PRM-50-31. was published in the amended. 7 U.S C. eot-e74.
planning be done before any Federal Register on March 24.1982 (47
- 2. A new I 925.209 is added to read as construction of a nuclear facility is FR 12639). Public comments were follows:
permitted and that the governor or requested by May 24.1982. The governors of any affected state approve comment period was extended to March 5 925.209 Expenses and assessment rate.
the emergency plans as a precondition 9.1987 (51 FR 40335: November 6,1986).
Expenses of $27.825 by the California to construction: and (3) requiring that A total of 74 comment letters were Desert Grape Administrative Committee offsite emergency preparedness findings are authorized and an assessment rate be made before any fuelloading or low received. Twenty.three of the letters were from individuals, of whom 15 of $0 003 per 22 pound container of power operations are permitted.
grapes is established for the fiscal The Commission considers that these favoted the petition and eight opposed period ending Decernber 31.1090.
three petitions have a common theme it. Thirteen letters were from Unexpended funds may be carried over thus warranting simultaneous environmental. nuclear. or energy as a reserve.
evaluation. Additionally, the State of oriented citizen activist groups. Of a
a q
e hat t.. Se these.12 favored the petition and one Dnied FebruarF 13,1990-Maine Petition consolidated with the so-opposed it. Twenty.nine letters were Robert C. Keency*
called Sexton Petition In denying from utilities. their law firms, or other Deputy Director. Trust and Veptob/c the petitions. the Commission concludes
[ndus y bl29 P"
d h
I that its present regulations on p os d e pet r susw (FR Doc. 90.-37o2 bled 2-15-90; 8 45 am) emergency preparedness are adequate Seven letters were received fram state to protect public health and safety.
or local emergency prerm.%ess j
siLLmo coot m&ct-W AconEssEs: Copies of allNRC agencies. All seven opposed the petition.
A letter from a politica! club and a letter documents are available for pubh.c g
NUCLE AR REGULATORY inspection and copying for a fee at the rec ived ot favo d e tion.
COMMISSION NRC Public Document Room at 2120 L PRM-50-45:A petition filed before the 10 CFR Parts 50 and 70 D$ho 8s yW o U G o uments r ay nn Se
. re e
IDocket Nos. PRM-50-31. PRM-50-45 end be purchased from the Superintendent of PR M-50-461 Documents. U.S. Government Printing Commission to amend its emergency Office by calling (202) 275-2000 or by preparedness regulations in 10 CFR part Emergency preparedness at Nuclear wnting to the Superintendent of 50'" Domestic Licensin8 of Production Power Plants; Dental of Petitions for Documents. U.S. Government Printing f,nd qu st the Com issior. o e 10 Rutemaking Office. P.O. Box 37082. Washington. DC AGENCv: Nuclear Regulatory 20013-7082. Copies are also availeNe CFR 50.47(c)(2) for nuclear power plants Commission.
fr m the NationalTechnicalInformation to require that "the plume exposure Service. 5285 Port Royal Road.
pathway EPZ for all nuclear power ACTION: Denial of petitions for Springfield. VA 22181.
plants shall consist of an area to be rulemakinE' determined by the NRC on a site.
FOR FURTHER INFORMATION CONTACT suuuARY:The Nuclear Regulatory Micha el T. la mgochian. Severe Accident speclIic basis, after allowing for review Commission is denying three petitions
!ssues Branch. Office of Nuclear of the determination report by interested for rulemaking concerning emergency Regulatory Research. U.S. Nuclear parties. The report shall list. des : ribe, preparedness at nuclear power plants.
Regula tory Commission. Wa shington, and reference allinput data and These petitions were submitted by the DC 20555 (301-492-3918).
methodologies used and all other factors considered. The NRC shall use Citizens Task Force of Chapel Hill, suert.EMENTARY INFORMATION:
methoriologies and procedures which North Carolina; the Department of PRM-50-JJ A petition filed before the are generally accepted as reasonably Attorney General. State of Maine: and Commission on December 21.1981 by current and appropriate by recognized an individual. Kenneth G. Sexton. Ph.D.
the Citizens Task Force of Chapel Hill.
professional groups in each supporting The Citizens Task Force petition (PRM-NC. requested the Commission to amend field (including the American 50-31) requested that (1) the emergency its emergency preparedness regulations Meteorology Society (AMS) and planning zone radius around nuclear in to CFR part 50. " Domestic Licensing Environmental Protection Agency (EPA).
power plants be extended from 10 miles of Production and Utilization Facilities." Likewise, best available estimates for to 20 miles. (2) independent radiological and part 70. " Domestic Licensing of modelinput (such as source terms) shall monHoring systems operated by local Special Nuclear Material." The petition be used. This distance shall be communities be established. and (3) requested the Commission to amend the reevaluated at least every five years.
mandatory utility funding of the regulations to require that the present using latest techniques and information, emergency preparedness efforts oflocal to-mile emergency planning zone (EPZ) unless petitioned earlier by the NRC.
communities be required. The petition radius for nuclear power plants be another professional group (such as the submitted by Mr. Sexton (PRM-50-45) extended from to miles to 20 miles and EPA or AMS), or the general public.
requested that the size of the plume include any towns bordering on or Generally. the models shall be at least exposure pathway EPZ be determined partially within this EPZ. that towns as complex and realistic as described in on a site. specific basis, using the most within the EPZ with a population in NUREG-0654 for Class B models.
up.to-date methodologies and that the excess of 5.000 persons operate their Meteorological submodels shall 5-041999 on02(00Ml5-FEB-90-1010.53)
F4702.FMT...l16.30].. 7 08-88
5604 Federal Register / Vol. 55. No. 33 / Friday February 18, 1990 / Proposed Rules consider all factors which can have an A notice of filing of the petition, outside the planning zones lof to miles) effect on the impar 'I the release of Docket No.PRM-50-48 was published NUREG-<254 Rev.1 at 11.
radic, active mateneh to the in the Federal Register on December 30.
The petitioner argued that the size of environment.The exact size and 1988 (51 FR 47025). Public comments the EPZ should be based on the worst-configuration of the EPZ surrounding a were requested by March 2.1987.
case core meltdown accident stating "It particular nuclear power reactor shall A total of 37 comment letters were is disturbing that the evacuation be determined in relation to local received. Seven of the letters were from preparedness EPZ zone is limited to 10 emergency response needs and capabilities as they are affected by such individuals, all favoring the petition.
miles despite the clear recognition that 4
Five letters were from environmental.
In a worst-case accident, evacuation conditions as power plant specifics would need to be taken outside the'g (type, power output, age, etc.). local nuclear, or energy oriented citizen meteorology (including data from both activist groups. Of these, four favored zone." The petitioner further argued that the power plant site and local national the petition and one opposed it. Twenty-evacuation should be taken only to s
weather service). demography, two letters were from utilities and law avoid "immediate life threatening topography. land characteristics. access firms. Of these, four favored the petition doses" but other severe adverse health routes. jurisdictional boundaries, and and sixteen opposed the petition. One risks as well.
proximity of seats of local government /
letter was received from a state and Several commenters supported the A notice of filing of the petition.
favored the petition.
idea that the EPZ should be based on the worst-case accident: an accident i
Docl et No. PRM-50-45. was published Each of the three petitioners in the Federal Register on October 8.
requested among other things. a involving a coromelt, a major breach of 1988 (51 FR 35518). Public comments fundamental change to the NRC containment resulting in an atmospheric release oflarge amounts of radioactivity were requested by December 5.1988.
emergency planning regulations that especially during adverse weather A total of 314 comment letters were would or could change the size of the conditions. These commenters said that received of which 278 favored the plume exposure pathway EPZ. Each people beyond to miles were.n danger petition and 14 opposed it.Two hundred petitioner provided a different rationale from such an accident. For example, the thirty.five of the letters were from to support its request and many Union of Concerned Scientists said:
individuals. Four letters were from comment letters surfaced additional Alt environmental, nuclear. or energy reasons to either support or oppose the o398. hough the NRC alleged in NUREG-thet it considered eccidents beyond oriented citizen activist groups. OI petitioners requests. Sixteen separate the traditional design basis. the consideration these, three favored the petition and one issues have been identified in the given such accidenis was minimal ai best.
opposed it. Ten letters were from petition and comments. Issues 1 through it is clear that the 14 mile plume EPZ was utilities, their law firms, or other 11 focus on this common theme, to not directed toward accidents in which the companies associated with the nuclear change the size of the EPZ, while
- " i" * '"' I* 'I' 'i'h ' " C""'"'IY *ith '
industry. All ten opposed the petition *
- * ' " ' " ' ' "".9 "' # * * " " * " ".
Seven letters were received from local addressin8 different rationales. Issues 12 precisely such accider.ts which dominate the through 18 focus on emergency plannin8 nsks to the public from the operation of government emergency preparedness agencies.of whom four favored the areas of tangential concern. Each issue nuclear power plants.
petition and three opposed the petition.
with accompanying rationale is fully PRM-50-46:A petition filed before the discussed and evaluated followed by a Commenters cited large consequences from a severe 6ccident. For example.
Commission on October 14.1988 by the Commission response to that particular Pollution and Environmental Problems.
Attorney General. State of Maine.
concem.
Inc., said:
requested the Commission to amend its issue 1. Extend the emergency planning The Reactor safety Study
- estimates that a emergency preparedness regulations in zone radius from 10 miles to 20 miles core.mett could cause 48.000 fatahties.
10 CFR part 50. " Domestic 1.icensing of because the most severe accidents were 285.0<10 non.fstalillnesses and 5.000 genetic Production and Utilization Facilities."
not adequately considered injuries. These consequences-as bad as they The petition requested that the are-essume that mesi peole downwind of en Commission amend to CFR 50 47(c)(2)
The rationale used for expressing the occident within a 45 degree sector extending for nuclear power plants to (1) expand opinion that a 10 mile EPZ is inadequate 25 miles from a plant could be evacuated both the emergency planning zone for la that following a core melt accident wohin a few hours.The NRC requires--only the plume exposure pathway and for the which results in an atmospheric release
- Ih*fd tha ik'to ccept 1s ingestion pathway;(2) require that of radiation.large does of radiation larger number of deaths and injuries than the emerEency planning be done before any could occur outside the 10-mile radius.
Re.ctor safety study assumes.
construction of a nuclear facility is The petition filed by the Citizens Task permitted and that the governor or Force of Chapel Hill. NC. quoted the Commissl a Response to !ssue 1 governors of any affected state approve joint NRC-FEMA report NUREG-0054.8 The Commission dealt extensively the emergency plans as a precondition to construction; and (3) require that On the other hand, for the worst possible with the issue of the adequacy of the 10 o!Isite emergency preparedness findings acetdents. protective actions (evacuation of mile EPZ in the context of severe be made before any fuelloading or low the population) e would need to be taken accidents, in its deciolon in Long Island IJ hting Co. (Shoreham Nuclear Power 8
power operations are permitted.
Nation. Unit 1) CL!-87-12,20 NRC 383 Subsequently, the State of Maine.
' NURp4. Rev t. Cntena for Preparation Department of the Attorney General,in and Evaluation of Radiolosical Emersrncy p,,pon,e Plans and Preparedness in Support of 8 NUREC-c396. Planning Basis for the a letter dated February 13.1987 Nuclear Power Piants. November teno.
Development of State and Locat Goverriment requested "... that the Malne Petition
- Noie ihai the words in bracheis lesecuation of Radiolosical Emersency Re8Ponee Fians in Support be consolidated with the,so Called the populanon). were added to the qunte by one of of Light Weter Nuclear Power rients. December Sexton Petition. Docket No. PRM-50-45.
the petitioners. The words change the meanmg 1s?s.
Intended in NUREG caS4. wherein protective action
- WASH-1400 (also numbered NUREC46/IXn4).
51 Federal Register 35518 (October 6.
inciud,, oih,, actions beside evaconison. such e.
Reacier Safeiy siudy. onen called the -R..mu. n 1986)..."
seekms shelter indoors Report" or WAS16-14oo." October 1s?S 5-041999 000h00X IS-FEB-90-ta to.56)
Federal Register / Vol. 55. No. 33 / Friday. February 16. 1990 / Proposed Rules 5605 (1987).The discussion in that case A reading of the Report (NUREG-0396) limits to the size of the EPZ or to the scope of summarizes the Commission indicates clearly that the margins of safety required emergency planning. Emergency development of the 10 mile EPZ concept provided by the recommended to mile radius planning can. however, be expected to reduce and it is appropriate to quote were not calculated in any precise fashion.
any public harm in the event of a serious. but extensively from it in rest,onse to the but were qualitatively found adequate as a highly unlikely accident.
maner dsment un se uncataMn ht the rule cleady was intended to n petitions here.The Commission noted in estimatiors of Class 9 accidei such hmits. Even under the Appeal Board (a that.
probabilities and consequences, there was no analysis, the rule amounts to a Commission For design. basis / loss.of coolant accidents other feashle choice in this regard. The EPZ's finding that adequate protection can be (DB A/LOCA), the Report lNUREG-0396]
shape could W eomewhat different than the provided by en EPZ of hmited size.10 miles concluded. among other things, that for most to mile circular sodius implies, without in radius, give or take a few miles, but plants the 25-rem (thyroid) and 5-rem (whole.
compromising emergency planning goals-certainly much less than 20.
body) EPA protective action guides
- would indeed, the Report [NUREG-0396} is explicit
... the proper interpretation of the rule I
not be exceeded beye" to miles from the tha t " judgment.. will be used in would call for adjustment to the exact size of plant, even using conservative assumptions determining the precise size and shape of the the EPZ only on the basis of such and analyses. Report. Appendix 1 at 4-6. As EPZs considering local conditions such as straightforward administrative for serious Class 9 accidents involving : ore.
demography, topography. and land use considerations as avoiding EPZ boundanes melt and containment failure. the Report characteristics, access routes. local that run through the middle of schools or lNUREG-0396l concluded that these jurisdictional boundaries and arrangements hospitals, or that arbitrarily carve out small protective action guides generally would not with the nuclear facility operator for portions of governmental jurisdictions.The he exceeded beyond to miles unless the notification and response assistance." These goalis merely planning simplicity and containment failed catastrophically and there are, of course, the considera tions later cited avoidance of ambiguity as to the location of was a sery large release of radioactive in I SO 47(b)(2) with regard to determining the the boundaries. With such clarity, plans can matenal.. land] that even for very large
" exact site and configuration" of the EPZ.
releases. emergency actions such as Nothms in the Report {NUREG-0396l or in be implemented with an understanding as to who is being directed to take particulst shellering or esacuation within to miles any other material in the emergency planning protective actions. 26 NRC at 394-95.
would result in significant reductions in rulemaking record compels a finding that EPZ deaths and early injuries Id. at 6-7. From a adequacy is especially sensitive to where in conclusion, the Commission still probab.hly standpoint. the Report cuncluded exactly the boundary falls. and any such finds that the 10-mile EPZ should not be that the probabihty nf Inrge doses from core.
conclusion would seem to be at odds with the increased to 20 miles.
melt accidenis dropa off substantially at overall thrust of the Report [NUREC-0396] In about to miles from the reactor. id. at 37.
particular. the task force's analysis indicates issue 2. Extend the EPZ from to miles to Dased on these considerations, the that " adequate protective measures"in the 20 miles because the effect of rainout Report concluded that'.
c nient CIemergency planning is not a was not adequately considered when the precisely defined concept. 26 NRC at 394 size of the EPZ's was determined Emcrpency response plans should be useful lbrackets not in the original).
for responding to any accident that would produce offsile doses in excess of the PACS.
The concept of " adequate protective Another reason given in support of an This would include the more severe design.
measures.' as used in our emergency expansion of the EPZ was that rainout bms accidents and the accident spectrum planning regulations is explatned in was not adequately considered when analyzed in lthe Reactor Safety Studyl RSS.
Long Island Lighting Co. (Shoreham the size of the EPZ's was determined.
After reviewir g the potential consequences Nuclear Power Station. Unit 1). CLI.. Rainout"is the deposition of associmied with these types of accidents. it 13,24 NRC 22,30 (1986), as follows:
radioactivity on the ground due to rain was the consensus (sic)of the Task Force scouring radioactive materials from the that emergency plans could be based upon a
.This root question cannot be answered air. For example, the Seacoast Anti-genene distance out to which predetermined without some discussion of what is meant by pollution League said.
actions would provide dose savings for any
" adequate protective measures." Our such accidents. Beyond this genene distance emergency planning replations are an Yet another reason to extend the EPZ lo at j
it was concluded that actions could be taken important part of the regulatory framework least 20 miles is the danger of reinout of the on en ad hoc basis using the same for protecting the public health and safety.
radionuchdes from the plume. The dosage considerations that went into the initial But they differ in character from most of our estimates in NUREG-0396 assume a uniform i
action determinations.
siting and engineenng design requirements rate of deposition of radioact ve maten,al The Task Force judgment on the extent of which are directed at achieving or from the plume...if half the material the Emergency Planning Zone is derived from rnaintaining a minimum level of public safety remaining in the plume were to be washed the characteristics of design besis and Class protection. See. e g.10 CFR 10011. Our out by a reinstorm between a radius of 15 to 9 accident consequences. Based on the emergency planning requirements do not 20 miles from the reactor, the doses would be information provided in Appendix llof require th9t an adequate plan schieve a as high as they were within the 5. to 10 mile NUREG-0396) and the applicable PACS a preset minimum radiation dose saving or a interval.
radius of about to miles was selected for the minimum evacuation time for the plume plume exposure pathway and a radius of exposure pathway emergency planning tone Commission Response about 50 miles was selected for the ingestion in the event of a serious accident. Rather.
Rainuut was considered. The exposure pathway as shown in Table 1.
they attempt to achieve reasonable and Ahhough the radius for the EPZ implies a feasible dose reduction under the statement that the dosage estimates in circular area. the actual shape would depend circumstances; what may be reasonable or NUREC-0396 assume a uniform rate of upon the characteristics of a particular site.
feasible for one plant site may W be for deposition of radioactive materialis in The circular or other defined area would be another.
error. A full page (p.1-25) of NUREC-for planning wherees initial response would like involve only a portion of the total area.
As the Commission has made clear-0396 is devoted to a discussion of rainout effects. While NUREG-0398 Report or 16. 26 NRC at 393 (brackets not in it is implicit in this concept of " adequate does not explicitly say 30. the calculated the original).
protective measures" that a determination that a particular EPZ size will provide doses presented in Figures 1-10 through
- "ProiecHve action svedes m unHe of radiation adequate protective measures does not in I-15 do,in fact. include the eIfects of ralnout.
v$dut
'n.aa n every nce va le c i
- t. the Reinout is included in the following u
a ent prote tive e i on 2a NRC, at 3s3 N.18 ttser). ethns Manual of Protechv, possibility of serious harm to the public,if manner.The entire release of Action Guides and Protective Actions for Nuclear this were actually the criterion. It would be radioactivity is assumed to be contained incidents. EPA 1:olt-rs-not (September tors).
difficult if not impossible to set any a priori in a small highly concentrated puff. The 5-041999 0004(00X15-FEB-90-1010;$9)
5606 Faderal Regist:r / Vol. 55. No. 33 / Friday. February 16, 1990 / Proposed Rulea probability of such a puff occurring is "Like the '5-mile' plans at TM1 they broadcasting systems that NRC requires approximately 1 time in 100.000 years.
[ emergency plans with a 10-mile EPZ) for prompt notification of the public Wind is assumed to blow the puff may reflect inadequate definitions of the within the 10-mile EPZ does reach directly over a large population center threat, encouraging a false sense of beyond to miles. Third,if emergency during a period of extreme atmospheric readiness, and delay preparations for a actions were necessary beyond to miles.
stability with minimal dilution of the more suitable response to a crisis." The the time available to take those actions puff so it never becomes much more Union of Concerned Scientists noted would be significantly greater than the than a mile in diameter. When the puff that it would require only one to four time available for the taking of is directly over the population center, an hours for the plume to reach 10 miles.
protective actions for persons close to extremely heavy rainfall scours most of Thus, there would not be adequate time the reactor (within 2 miles). This the nongaseous radioactive material to notify people beyond 10 miles t a gnificant additional time (many hours from the cloud and deposits it on the evacuate.
to days) would permit the use of ground. lf such a puffis released, the Commenters opposed to the petition resources from other states, other probability of the puff encounterin8 said that the detailed planning for the utilities. the Federal government and these weather conditions is go. mile EPZ could be applied outside the even the international community.
i approximately 1 in 10.000. The go. mile EPZ if recessary.They also radioactivity is assumed to remain on noted that the Comrnission had already Beyond these reasons. the relationship the surface of the ground with no made a judgment on this question in its between wind speed and hazard may entrance into sewers, no runoffs, and no rulemaking on emergency preparedness have been misunderstood. Higher w nd sinking into the ground to remove or (45 FR 55402 and 55406). For example.
speeds result in lower radiation doses shield the radioactivity. The calculations the law firm of Shaw. Pittman. Potts, because the radioactive plume becomes assume that 100 percent of the and Trowbridge argued:
greatly diluted and dispersed at higher radioactivity will remain on the surface Yhus. it is hkely gnen the means usually wind speeds. This was discussed in without any runoff, but in reality the used to distnbute pubhc information NUREG-0396.
probability of this is near zero.The materials. that the geographic area actually Further, the radioactive plume is not people are assumed to be exposed with covered witl be greater than the plume to ongbate we.out wamMg. He minimal shielding to the radiation from exposure pathway EPZ. Similarly, the nuclear power plant operators. In most radiation from the deposited material;in systems used to notify the pubhc to take cases, would be able to declare on other words, that no one is in an protective actions provide coverage apartment building no one is in an substantially beyond the EPZ boundery.
emergency hours before a release. based office building. no one is in a basement, eince the radio and television stations used in on what they understand to be and no one is in any other type of the Emergency Broadcast System !'EDS"I con happening in the plant.The NRC be received at distances in excess of to maen requires utilities to set emergency action building that provides more shielding than a small one story frame house. The And, with respect to actual protective g fy gg g gg assumed probability of this is one.
- ,'[p['[;(,' ',j'[,',
y p,','p"Ic M
,c oth which emergencies should be declared whereas it is in reality near zero. The inside and outside the EPZ. As to evacuation.
(see to CFR Part 50. Appendix E and people remain where they are with no even that measure can easily be buili apon NUREG-0654. Apper. dix 1.) Thus, esacuation or other protective action for and use evacuation plans developed for evacuation recommendations should be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> The probability of no,
made before releases of radioactivity within the 10 mile EPZ-emergency response for 24 hors is Commission Response would occur, giving people time to que c to be on, but reality NUREG-0396 noted that rri e h petitione r ay at e the probability is near zero. It is this it was the consensus of the (NRC-EPA l Task aware that the need for evacuation specific series of events that gives rise Force that emergency plans could be based beyond a few miles from the plant is to the largest casualty figures that have upon a generic distance out to which extremely unlikely.lf protective actions been calculated for severe nuclear predetermined actions would provide dose accidents and which are presented in savings for any such accidents. Beyond this were needed beyond 10 miles. the action NUREG-0396. Because of these genenc distance it was concluded that required would most likely be sheltering assumptions, the calculated actions could be taken on an ad hoc basis while the plume passes and then consequences are greatly overestimated. using the same considerations that went into evacuation of relatively small areas the initial actions determinations. [Thus), the afterwards if much deposition of Issue 3. Extend the EPZ frorn 10 miles to size of the EPZs need not be site specific. las) radioactive materials on the ground 20 miles because ad hoc actions beyond emergency planning needs seem to be beat were to occur.
10 miles would not be adequate served by adopting uniform EPZs for initial plann ng studies for alllight water reactors.
Another reason not to expand the EPZ Another reason given by the Citizens Task Force of Chapel Hill NC petition Additiotially, the Commission firmly is based upon the fact that risk is highly and several commenters to expand the believes that emergency actions could concentrated in the areas near the EPZ is that they did not believe the be successfully carried out beyond 10 nuclear power plant. rather than spread NRC's statement in its final rule on mile EPZ for the following reasons: First, uniformly throughout the 10-mile EPZ.
emergency planning. 45 FR 55402:
the to-mile planning basis establishes However, the Commission notes that
( August 19.1980) and NUREG-0396.
an infrastructure consisting of despite the technicalinformation to the page 16. that the 10-mile plume EPZ was emergency orEanizations.
contrary, ti.e entire EPZ tends to be "large enough to provide a response communication capabilities, training tnought of by many members of the base that would support activity outside and equipment that are similar to other public as a single homogeneous zone to the planning zone. The Citizens Task normal community emergency be treated in a un. form manner.
i Force petition quoted a FEMA report.a organizations, such as police and fire departments that can be used in the Expanding the EPZ radius from 10 miles a n.cuenon runma m the nt! Ar.cident.
event of an accident at the facility.
to 20 miles might even further aggravate s'ru A. innu. rv wnn Second, the radio and TV emergency this situation.
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Fcd9tal Regist:r / W1. 55. No. 33 / Friday. February 16, 1990 / Proposed Rules 5607 Issue 4. Extend the EPZ from to miles to call for adjustment to the exact size of Report said. "... the NRC itself was 20 miles because the reduction of early the EPZ on the basis of such considering evacuation distances as far injuries and latent cancers fatalities straightforward sdministrative as 20 miles, even though the accident were not considered when the size of the considerations as avoiding EPZ was far less serious than those 10 mile EPZ was determined boundaries that run through the middle postulated during siting."' The Several commenters said a reason to i schools or hospitals, or that Community Energy Action Network expand the EPZ is that in establsihing 8Mr8% c8We d smaU podou of quoted N Rogun hporm the emergency planning zone, not only g vernmental jurisdictions.The goalis conclusion that a 10-mile EPZ is early fatalities, but also early injuries merely planning simplicity and inadequate:
and future disene such as cancer should av idance of ambiguity as to the However, we believe the NRC's proposed be considered. The Union of Concerned I cation of the boundaries.
10 mile planning tone. is, by itself.
Scientists wrote:
Given these circumstances, the inadequate as an arbitrary cutoff point.
Commission has concluded that wider evacuation may clearly be necessary 11 is by no means clear that prompt adequale protection can be provided by in some unlikely accident situations. And. as fatahlies are the dominant health effect from an EPZ that is about to miles in radius.
Three Mile Island demonstrated. en ordered serious reactor accidents. In addition to evacuation out of to miles would prompt fatehties. the following additional Issue 5. Extend the EPZ from to miles to undoubtedly have effects to 20 miles and effects rnust be considered in establishing an 20 miles because the radiation from an more. Therefore. at the very least, significant appropriate plume EPZ: tallatent fatahties.
accident would not stop at 10 miles centers of population beyond 10 rniles from (b) early radiation injuries. (cl non. fatal cancers. (di genetic effects. and. to e lesser Se eral commenters who favored the the plant must be considered in the planning entent. (e) property damage and restrictions recommended change to expand the EPZ as well Rogovin Report Vol 1 p.33-on land une caused by accidents. Risk gave as a reason that radiation "is not Commenters opposed to the petition assessment studies have shown consistently hkely to stop at the 10 mile mark in the said that emergency preparedness had that effects other than prornpt fatalities case of a serious accident." One said, increased greatly since the Three Mile constitute a significant portion of the total "No one believes that people are any Island accident. For example. Barry G.
effects of serious reactor accidents. For safer at 11 miles than at to miles out."
Wahlig. a nuclear engineer, wrote:
instance. Dr. lan Beyce has pointed out that Another said. "There is no 10-mile The vacillation over evacuation at TMI is for the accident in % ASH 1400 which was postulated to cause 10 prornpt fatahties. the island with lead walls to the sky to in no way representative of the post.Tui prevent radioactivity from blowing world. At that time. utihty and regulatory beyond the NRC's emergency planning personnel had scarcely thought about how to c
7 c n e de s gent ic defecin. 60.000 thyroid tumor esses, and 3000 zone."
think about evacuation. The tenor of square mdes ofland contaminated above
"""8'"'#**"' " '"
'I"'
Cor#;.slon Response ecceptable levels.
assures that responsible people have given Obviously, there is no line at 10 miles considerable thought to how to arrive at Commission Response beyond which radiation cannot pass.
defensible evacuation recommendations. To The Commission agrees with the However, the hazard from an accident the extent reasonably possible, emergency commenter that for most accidents, long. tends to gradually decrease as one exercise experience shows that plant term effects-cancer and genetic defects moves further from the accident. How pers nnel could make such recommendationa in offspring-are the most significant far from a nuclear power plant is the in an orderly. timely way, effects.from the standpoint of the gross potential hazard small enough that Commisalon Response number of effects. Only the most severe specific detailed planning is not accidents could result in any prompt worthwhile? In the Commission's The Commission believes that if fstalities or injuries. With the existing judgment, that distance is about 10 miles Protective actions were warranted levels of emergency preparedness it is for the considerations stated in this oeyond to miles, those actions, whether likely that no one who followed the discussion.
evacuations, sheltering or relocation, would certainly be recommended to the recommended protective actions would Issue 6. Extend the EPZ from 10 miles to State officials. Nonetheless, due to the be killed or injured-20 miles because at TMI a 20 mile additional time that is available for the Our emergency planning requirements do evacuation was considered taking of protective actions out to not require that an adequate plan schlese a preset minsum radiation dose saving or a The Citizens Task Force petition and greater distances from the reactor, the commenters gave the 20-mile evacuation implementation of these additional consideration during the Three Mile protective actions would not require exp ur path a em rge cy pla ngzone in the event of a senous accident. Rather.
Island accident as a reason to expand detailed plans.
they attempt to achieve reasonable and the EPZ to 20 miles.The Task Force feasible dose reduction under the quoted a FEMA report as follows:
Issue 7. Extend the EPZ from 10 miles to 20 miles because of the lessons learned l
circumstances: what may be reasonable or Emergency management agencies entered from the Chernobyl accident frasil,le for one plant site may not be for the crisis with contingency plans to evacuate cnother. 24 NRC at 30.
a 5. mile circle around TMI....Two days A few commenters suggested that the A fair reading of the Commission's into the accident, the same scientific NRC should modify its regulations Shoreham discussion is that implicit in authorities (n w faced with a novel and because of the evacuation that took d
the concept of " adequate protective
"",',*[,'[n ieIa*
place as a result of the Chernobyl ile hen a 20 mile measures"is the fact that emergency contingency evacuation plan. Under accident.
planning will not eliminate, in every emergency conditions. local and State conceivable accident, the possibility of officials were forced to scrap a relatively
'lohn C. kemeny. Chairman. Report or the serious harm to the public. Emergent;y undemanding 5 mile evacuation and plan for Pruidents Commluton on the Accident et Three planning can however, be expected to a large, complex population movement on Mile taland. at to senerally called the "kemeny reduce anI Eublic harm in the event of a short notice. (p. vt. reference 9.)
Commission Report." October te79.
- NUREC/CR-1250. Three Mlle Island-A Repoit serious but highly unlikely aceident.The The Seacoast Anti. Pollution league to the Commissionm and to the Publir. senerstly properinterpretation of the rule would noted that the Kemeny Commission
- c. tied Rosovin Report. Ianuary taso.
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5608 Fcdtril R:gister / Vol. 55. No. 33 / Friday, February 16, 1990 / Proposed Rules Commission Response kilometers (18 miles) of the Chernobyl plants. While some prior planning A number of facts
- about the nuclear power plant.This evacuation existed, perhaps for civil defense. Soviet Chernobyl accident bear on emergency appears to have taken place in several authorities indicated that many of the planning and preparedness around U.S.
stages, beginnina for the approximately protective actions taken were ad Nc commercial nuclear power plants. The 45.000 residents of Pripyat about 36 measures. Although a severe accident in implications of the Chernobyl accident hours after the initial release and the United States could require some ad and the Soviet response will now be extending over several days to a week.
hoc measures to be taken a detailed discussed in relation to three aspects of The whole body radiation dose to the planning base exists to facilitate U.S. emergency planning namely:(1) majority ofindividuals did not exceed implementation of the necessary Size of the emergency planning zone. (2) 25 rem. although about 24.000 persons in protective ections.
ingestion pathway measures, and (3) the most severely contaminated areas With regard to the issue of EPZ size.
decontamination and relocation.
are estimated to have been exposed to the Soviets evacuated the population out in drawing a nexus between the whole body doses in the range of 35-55 to 18 miles, or roughly twice the Soviet response to the Chernobyl rem.The population of Pripyat was distance for which an evacuation accident and emergency planning initially sheltered as a protective capability is required to be implications for U.S. plants contrasts measure and then evacuated when demonstrated in the United States.
and differences should be noted. First, radiation readings increased. In addition Similarly, measures were taken to there is a substantial difference in the to radiation considerations. logistics and prevent ingestion of foodstuffs. milk and emergency planning base. After the contamination controlinnuenced the water at distances considerably greater accident at Three Mile Island. large timing of the evacuation. Despite an than the 50-mile ingestion exposure resources were expended to improve s,pparent lack of site-specific planning.
pathway in the United States This emergency planning and response the Soviets mounted a large and might imply that the U S. EpZs are too capabilities around U.S. plants. In generally effective ad hoc response small. However, examination of the contrast. although some prior planning making use of some aspects of civil background leading to the U.S.
appears to have existed in the Soviet defense planning. The high initial plume requirements leads to a different Union, perhaps for civil defense, there is height centributed to relatively low conclusion.
little indication that the Soviets have initial dose rates in the immediate The sizes of the EPZs were derived comparable site. specific emergencv vicinity (by cloud seeding other areas) from accident considerations. including plans for the general public around their and the spraying of a chemical polymer the severe accidents studied in the nuclear power plants. Despite this, the on evacuation routes to minimize Peactor Safety Study (WASH-1400).
Soviets mounted a large and generally resuspension of depostted activity were The more severe and most unlikely effective ad hoc response.
also beneficial. The Soviets took accidents studied in WASH-1400 Seccnd. the specifics of the Chernobyl ingestion pathway protective measures involve releases of radioactivity that are release are unique to the RBMK design.
within the 30 kilometer zone and well comparable or in some instances larger The amounts of radioactive material beyond. Ingestion pathway protective in magnitude to that which was actually released from U.S. plants could be as measures were also taken in several released at Chernobyl. The 10 mile and severe but for many accident sequences Soviet bloc cuintries. in Scandinavia.
50-mile EPZs were chosen as a planning
)
would be considerably less because.
and in Eastern and Western Europe.
basis to demonstrate a capability and to
{
among other things. U.S. plants have Assessment: One difficulty in provide emergency plans with the
)
substantial containments. In addition.
assessing the implications of emergency flexibility of dealing with a broad range although low probability. fast. moving actions taken at Chernobyl for U.S.
of accident releases.rather than being accident sequences may be possible, commercial nuclear power plants is the based soley on a single highly unlikely severe accidents at U.S. plants would. in vast difference in the emergency event, such as the worst case. it was general, progress more slowly resulting planning base between the United recognized that protective actions might in longer warning times before release.
States and the Soviet Union. After the need to be taken beyond these planning Third, some aspects of the Chernobyl accident at Three Mile Island. large zone distances for the most severe i
evacuation defy comparison with resources were expended in the United releases. NUREG-0654 clearly notes:
)
similar aspects at U.S. plants because of States to improve site-specific and.
The choice of the size of the Emergency economic and societal differences. Fe.
generic emergency planning capabilities. Planning Zones represents a judgment on the example, the Soviets had to assemble Utility. State, local, and federal entent of detailed planning which must be j
4000 buses and trucks for the Chernobyl emergency plans were developed.
performed to assure an adequate response 1
evacuation, whereas. in the United reviewed. and exercised. Alert and base. in a particu!st emergency, protective States most people have access to notification systems have been actions might well be restricted to a small private transportation and necessary designed. installed, and tested within part of the planning zones. On the other hand.
alternative transportation is preplanned the plume expcsure pathway EPZs (10 for worst possible accidents, protection around U.S. nuclear power plants, mile radius) for almost all U.S. plants.
acti ns would need to be taken outside the IP ' ""'"8 *""
Size of the EPZ's:The Chernobyl The populations within the plume accident has focused attention on the exposure pathway for U.S. plants are Consequently, a release magnitude adequacy of the size of emergency annually provided with informational similar to the one associated with i
planning zones around U.S. commercial materials that are to be used in the Chernobyl and the possibility that ad nuclear power plants. The Soviets event of an emergency.These materials hoc actions beyond the planning zone evacuated a total of about 135.000 contain protective actions that will be boundaries might be needed for very people as well as considerable farm taken and include telephone numbers unlikely events were considered and livestock from Pripyat. Chernobyl, and for public inquiries.
have been factored into the other towns and villages within 30 in contrast there is little indication development of U.S. requirements, that the Soviets have comparable site.
including the sizes of the EPZs.
WLTREG-1rSt. Vol.1-tmplication of the specific emergency plans for the general In conclusion. the Chernobyl accident Acc6 dent et Chemobyl for Safety Regulation.
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Fcderal R:gister / Vol. 55. No. 33 / Friday. February 16, 1990 / Proposed Rules 5609 any apparent deficiency in U.S. plans although. for most accidents. these dose expected to produce early health and preparedness. including the to-mile phases would be expected to overlap.88 effects although evacuation is clearly plume exposure pathway EPZ size and The first release would be of short much more effective within the first few the 50-mile ingestion exposure pathway duration, usually occurring before there miles. However, the effectiveness of l
EPZ size. These zones provide an is significant core. concrete interaction.
evacuation diminishes substantially if it adequate basis to plan and carry out the and would consist of the more volatile is delayed until after containment full range of protective actions for the radiouclide species (i e., all the noble failure end releace of radioactive populations within these zones, as well gases together with signficant fractions material to the environment. Sheltering as beyond them. if the highly of the more vola'itle species such as Cs.
in large buildings appears to be very improbable need should arise.'s I. and Te).The second major release effective outside the first few miles.
Issue 8. Extend the EPZ from 10 miles to would occur after the core materials Although large building sheltering is not 20 miles because the most current have melted thrcugh the reactor usually evallable for the general d g sw e t sed n pressure vessel and are interacting with population in the env!rons of a site,it Qt the concrete cavity.This second release may be a prudent and valuable option
,db g
source term research information.
c uld usually take place over a period of for special population groups (e.g..
several hours orlonger.
hospital patients, prisoners).
j s
The petition submitted by Mr. Sexton The nature of the expected offsite New technicat informatien from the as well as a few comment letters consequences for the plants analyzed.
plants analyzed in draft NUREG-11E0 suggested that the EPZ size should be assuming no early offsite protective (February 1987) shows that for these based on the most current research action is taken,is shown in draft plants the probability of a core damage information and because the NUREG-1150 (February 1987). Tables accident is small(in the neighborhood of j
methodologies used in NUREG-0396 are M.3 and MA '8 for early and late 1 to 10.000 to t in 100.000 reactor years j
outdated.
containment failure. As can be seen.
of operation) and that the risks and Comm.ission Response there could be a significant probability potential consequence associated with of exceeding a 50 rem u whole body such accidents are no higher than those Draft NUREG-1150 (February 1987) dose within a few miles of three of the predicted in the Reactor Safety Study provides substantial new information plants analyzed. even for late and may be substantially lower.
concerning our ability to predict severe containment failure if no protective However, there is still uncertainty accident progression and the range of action is taken. However, this associated with these estimates.
outcomes. Based on this information. it probability diminishes rapidly with Some insights obtained from this appears that the risks and potential distance from the reactor for both early analysis are summarized below:
consequences associated with severe and late containment failure.
reactor accidents are no higher than Probabilities of exceeding 200 rem nmeyauu,jnjandy t
e o cont s
,g h,
,gn those predicted in the Reactor Safety whule body dose calculated for the resuliing consequences.The consequences of Study and may,in fact, be substantially Surry plant were compared those an early contalnment failure at a given lower. However, there are large obtained using Reactor Safety Study distance are significantly higher than those uncertainties associated with the ability data.
for a late containment failure.
to predict precisely the release amounts Although the probabilities calculated
- 2. While there are calculated dose once the core. melt accident is underway for draft NUREG-1150 (February 1987) differences among the plants. these appear to and the magnitude of the source term are substantially lower at large be secondary compared to the differences associated with a particular outcome.
distances (due primarily to the seen between early and late containment Draft NUREG-1150 (February 1987) assumption of estlier relocation time).
I","f,'r late centainment failure and no provides insights concerning (1) the way the probabilities within a few miles of offsite doses would be expected to vary the plant are comparable.
offset protective action: tal persons beyond with distance for the plants analyzed We have used mformation from the about 1 to 2 miles have a low probability of receiving a dose in excess of 200 rems. and and (2) the relative effectiveness of plants analyzed to calculate how offsite (b) persons beyond about 5 miles have a low different offsite protection actions 8 8 at consequences would be expected to probability of receiving a dose in excess of 50 various distances, vary with distance from each of the tems.
A very important question is the plants if different protective actions While thus far the effectiveness of nature and magnitude of the radioactive were taken.The results of these release to the atmosphere.The calculations are summarized in draft protective actions has been completely magnitude of the potential release NUREG-1150. Table M.5 and M.B.
investigated only for the Surry plant and substantially influences the potential An examination of Table M.5 and M.B no generic conclusions for other plants offsite consequences. The source terms in draft NUREG-1150 (February 1987) can be drawn, some preliminary insights and principal assumptions for the provides several prelimmary insights.
that can be gleaned from draft NUREG-analyses in this se: tion are given in First, either basement sheltenng or 1150 (February 1987) are:
Tables M.1 and M.2 of draft NUREG-evacuation will substantially lower the
- 1. With regard to protective actions. the 1150 (February 1997). Release of probability of exceedin8 a whole body pnnc(psldos se enjaemotai'd y,e,,
,q i,,dng radioactive material to the environment during most severe accidents within the first few miles of the plant.
is Ali Zion releases were modeled as sinsle-
- 2. Within the first few miles, evacuation (particularly those resulting in early phase rei,ases. but this will be revised for the final appear, to be mon effective than sheltering containment failure)is mudeled as vmion of NURT.G-n50.
in schleving dose savings. At distances occurring in two distinct phases
" Unless otherwise specified in the table. the beyond about 5 miles, these differences are source terms and principet sesumptions for Tables y
g "g,[,' containment fallure accidents.
throush M.e are those hated in Tabte M.1 and
This analysis addresses only those emergency 8' a04 rem and sorem whole body doses were any of the protective actions analyzed would actions that would have to tre taken in the vicinity used to allow comparisons with earlier studies le s result in essentially sero probability of a of the plant to provide protecuan from the NUREG c'lil6 because they ame as surrosstes for person being exposed to doses in excess of immediate effects of the plume esposure pathways.
the early fatality and injury thresholds. respect 6vely.
200 rems et distances beyond 1 mile and to i
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5810 Federal Register / V;1. 55 No. 33 / Friday F;bru:ry 18, 1990 / Proposed Rules doses la exceae of so runs at distances bones and in tisose; that these alsmedas emh have climbed sharply for males and beycod 3 miles.
redietion for periods rangire fram a few days females, but this is attributed almost t
te conclualon, the f'amminalon agmes to half a centurr, that fetwas and childres entirely to cigarette smoking.
thct the size of the 10 adle EPZ was under un am asoch mom valoemble to he petitioner's statements that some determined natng the methodologies
'*** tion efectr, and that ce!! damage from radioactive elements "...can in some avauable in 1980 and that today there whawnr cause is a medical conum of smt form enter the food chain and may be exists more sophisticated techniques importance concentrated through the chain"is a and computer models to estimat*
Casumissionv----
long-known and well. documented fact.
radiat!on releases and doses to the he concentration effect was public, Nonetheless, the most
%e statements above representing predictable from knowledge of biology sophisticated and up to date the petitioner's interpretation of various and was first observed almost 43 years methodologies were used in the views of the hazards of radiation ceed ago before " weapons testing in China."
development of NUREG-1150 (February clarification.De statement that "a Since this effect was known long before 19s7) which, as mentioned above, does radiation dose low enough to produce the start oflarge-scale nuclear electric not provide evidence that the sine of the no effect has not been identified" generation, the radioactivity in the picme exposure pathway EPZ should demonstrates an overestimation of what envirorunent and foods near nuclear now be increased.
scienti!!c experiments can accomplish.
power plants is and has always been lasse t Extend the EPZ from is mDes to Experiments on the effects of toxic carefully measured both before and se mues because any radiation can be substances generally do not allow during nuclear power plant operation.
j barmful therefore the public should be experimenters to drgw a conclusion of Radioactivity in foods and water due to able to take protective actions to assure no effect. !f no effect is observed, the nuclear power plants is and has always that they receive no radiation in the experimenter cannot conclude that there been kept at low levels.
l evout of an acddent was no effect because there may have
%e petitioner's statement that " cell been an effect that was too small to be damage from whatever cause is a Citizens Task Force of Chapel Hill, NC, petition and some commenters in observed. There are a number of medical concem of great important"is support of this change gave the reason experiments on low doses of radiation misleading, Scientifically, the that an amount of radiat)on can be that show no observable effect. From importance will depend on how many cg r: ells are damaged, the nature of the nelu th t te is n e t Only an damage, the type of cell damaged, and it is agreed that a radiation dow low upper limit of the size of the effect can the probability of the damage to that cell i
enough to produce no effect has not been ident6ed. In other words, all levels of be estimated.%st bas been done for leading to any further consequences. For radiation rosy produm some affects on radiation, s5d there is general example,if a large group of people are exposed to a radiation dose of 1 rem cell...
agreemeut among scientists on the each, the EPA's lower protective action Some experta state, however, that one approximate upper limit.
guide about 5 out of 10,000 people could sit on the fence of a normaDy operating Likewise, the statement that "others, would be expected to get cancer as a "j der P or a y or a absorb o also wellinformed, argue that our result. And, because not all cancer is n
x-ray. Thus group stresses the fact that people scientific understanding of the long-fatal, about 2 out of 10.000 would be have lived with varying levels of background range effects of low-level radiation expected to die from this radastion-radiation with no demonstrable negative continuously emitted into our induced cancer. (About 2,000 out of results..
environment is inadequate at this time 10,000 people will eventually die of Others, also weD informed, argue that our to measure the damages with any degree cancer, but those cancers are mainly scientMc understanding of the long-range of certainty," misrepresents prevailing unrelated to radbtion exposure.) Of the se c *wpoints. Scknhts am in N M d M & M MW em oo nt in deq s at this time to measure the dangers with any general agreement that the effects of cancer caused by the 1 rem radiation,
degree of certainty. ney are concemed that doses of a few rems are too small to be dose, based on current knowledge, thetr the various effects we get frorn radiation.
measured.
health would be unaffected by their poUution. chemical carcinogens, and so forth De petitioner's statement that, the radiation exposure.On the besis of the may lead to a yet undocumented multipher
- h. demiological evidence, they would
'pi effect.They see the precipitous nae of cancer precipitous rise in cancer rates during ve as long and be as healthy as if they rates during the last couple of decades as the Isat couple of decades is support for strong support for this concinaion.ney the possible axistence of"a yat had not received the radiation dose.
further argue that some radioactive elements "h**nted m'altiplier effect" fasue it Extend the EPZ from 10 miles released into the air or dumped tnto the between environmental pollutants to 20 miles because of the evacuation watem if not immedietely dangerous in seems to be based on an incorrect shadow M==
small accounte-can in some form enter the food chain.nronab a proceu termed premise According to the American Commenters in favor of the
" biological ampt.ficauon." these radioactive Cancer Society, the death rate from all recommended changes gave as a ressou elements may be coowntrated through the cancers empt lung car.cers has the bellef that if an accident occt.ned chain of leuer plants and animala until they dropped slightly for males and dropped many people outside the 10 mile EPZ reach human beings through the food sey sharply for females during the laat would evacuate even though they were est. By tina time the radioactive materiais couple of decades (abown, for example, not advised to do so.%ey said,in this may te heavily r-watrated. ney clie the in Figure 19, page 36 of NUREG/BR-
"evscustion shadow." masses of people d$ s *f 0024 88).De hmg cancer death rates would be fleeing in panic, would congest in China as evidence of eia roads making evacuation of those withm process.... And although the love! of hans the EPZ slower or even impossible. As a which may result is not upon, it is way to plan for this effect these certain that our bo6es e up radioactive a Ninu'clest-atn4. worktes afety in ca commenters suggested extendmg the s
clements and see them is the matria of the staeagraphy. sapiember tsar.
EPZ aone radius from to to 20 miles.
q l
Federal Registee / Val. 55. Na 33 / Friday. F1bruary 18.1990/ Propossa Rults 5811 Commenters oppoems the petition Noclear Genersting Station. Units 3 & 3).
quoted by the petitioner referred to 1
said this was not a problem because IEP 82-39.15 NRC 1183.1171-73 (1983).
- deficiencies in... preparedness." The
(
evaluation of nonradiological incidents ha effect. the Commission accounted for petitioner also cited a lune 1980 FEMA W
which have required mass evacuation ene possibility of spontaneous report. State Radiological Emergency j
has also demonstrated that, even evacuation outside the plume EPZ when Planning and Preparedness in Support of g
without advance planning, an orderly, at established the size of that EPZ in the Nuclear Power Plants. FEMA wrote:
I safe. and prompt evacuation can be Bret lastanos. he petitioca provide no
,,'vhpreparedness of state and local the undertaken.
Justification for expansion of the plume ts with respect to... monitoring EPZ to further account for the possibility lastruments... is genere!!y inadequate to b
c a g,,,,_______
J of spontaneous evacuations.
asset the requirements of the new [ poet.Th0]
L la CIJ-W-12. the Commission noted "I"* ti'" "**-
5 Issue 11: Extsad the EPZ to laclude any e
PPosbg b peMon g
...we think it is entirely reasonable and EPZ said that adequate monitoring
,.1 appropriate for the Commission to bold that arguments for " adjusting" a to mile EPZ to
%e Otizens Task Force of Chapel equipment is now available, that the 3
improve safety, especiaDy ents that Hill. NC. petition requested the NRC to evidence cited by the petitioners is entail complex analysis and litigation amend its regulations to state that any outdated and no longer valid, and that are an impermissible challenge to e rule towns bordering on or partially within euch equipment vrould be too difficult the EPZ be included within the EPZ in for local communities to use properly, sj hcardingly. we think the bener their entirety.
For example. Barry G. Whalig. nuclear interpretabon is that the rule precludes Commenters in favor of this engineer wrote:
edjustments on safety grounds to the sise of said that if, for example, some e s
Petitioners show a lack of appreciation for a
an EPZ that is "about 10 milu in radius" and that Contenbon 22.C (whether the EPZ should of a city were included in the emergency b &fBculty of making securate ntimates of
,3 be expanded by a few miles to minimin the d'""'"a but the city were not, then airborne and groundplane contamination in occurrence and effects of spontaneous Iragmented authority would result.
the post. accident environment. This is especially d fBoult using the sort of survey evacuation from outside the EPZ) should on pw g, n - _ _.
metm which the petitioners seem to want this ground be deemed impermis.sible challenges to the rule. In our view. the proper As discunedin the Commission suppbed in the tens or bundmde to interpretation of the rule would call for response to lesue 1.NUREG 0396 individuals la the nearby communities.
~
I adjustment to the exact size of the EPZ only provides that " judgement... will be Examples of the problems are:(al Prevention on the basis of such straightforward used in determining the precise size and of instrument contamination during the event administrouve considersuons as avoidmg EPZ boundaries that run through the middle shape of the EPZe considering local (bl ensunns un!formity of instrument of schools or bospitals, or that arbitrarily conditions such as... local cahbration and of measurement protocol;(c) h differentiation of plume and groundplane k
carve out small portons of govemmental jurisdicbonal boundaries..
- contributions without samphng and (d)
I turis&cuona. The goal is merely planning Rua. Commission practice already precin reporting of the location where I*
simpbcity and avoidance of ambiguity as to allows for adjustment of the EPZ to meuuremsnts are made. Experience show the locauon of the boundaries. With such accommodate jurisdictional boundaries that even technicaUy competent people are k
clarity. plans can be implemented with an where appropriate to enhance the subject to thne errors.
understandmg as to who is being directed to plan &g basis.
f take partcular protective schons. 38 NRC at he Citizens Task Force petition also d
395 (brackets not in the ongmal).
Issue it: Rat a fund and lastall said that there is a need for independent il As noted above, the Commission tmanh equipment to be. monitoring because there is a credibihty i
determined. based on information used by local communities arand gap between what the utility and NRC available at the time that it promulgated nuclear power plants would say during the course of an 7
the emergency planning regulations, that ne Citizens Task Force of Chapel accident and what the public would g
a plume exposure pathway emergency Hill. NC. petition requested that the believe.ne petitioner quoted a May 12.
planning zone (plume EPZ) of about to communities within the EPZ should be 1979 statement by Dayne H. Broun.
miles in radius was the proper and provided. with utility funding to Director of Radiation Protection Section appropriate area for detailed planning purchase. install. and operate their own of the North Carolina Department of for protective actions in the event of a radiological monitoring equipment. %e Human Resources, and an April 29.1979 radiological emergency. At that time, the petitioner said such independent statement by North Carolina Governor Commission specifically recognized that monitoring will permit detection of James B. Hunt. Ir as evidence of lack of detailed planning in that tone would radio 6ctive materials such as iodine-131 cmdibility:The petitioner wrote:
more readily permit the development in a short enough time to be usefulin N largely spontaneous and unorg.nized andimplementation of ad hoc actions.
making decisions on emergency actions, evacuation of several bundred thousand beyond the to mile plume EPZ should As a reason for twquiring independent people from the area around the Three Mile the need arise. See NUREG-0386.
monitoring the petitioner claimed there Island (TM) accident reflects a serious "P1 Basis for the Development of is a lack in both quality and quantity of probha: the lack of pubbe confidence in the State Local Government radiation monitoring equipment around stihan' commitment and abihty to provide Radiological Emergency Response pian 6 nuclear power plants. Since the timely and accurate warninge regardmg j
in Support of Light Water Nuclear petitioner believes the utilities do not leakages of radioactivity and/or reactor Power Plants." (December 1978);
have adequate equipment, the petitioner problema.h resultant uncertainty trib ed er alpe cho ca j j NUREG-0854. "Criterie for Preparation believes local communities shoald 9,
g and Evaluation of Radiological provide it for themselves. %e petitioner around the reactor.
I Emergency Response Plans and
- cited as evidence a March 30.1979 Preparedness in Support of Nuclear General Accounting Office report. Areas ne Sorghum Alliance wrote:
Power Plants." (November 1980), p.12:
Around Nuclear Facilities Should be Independent radiotion monitorins is Shoreham. 26 NRC at 392-93. Souther.t Better Prepared for Radiological neceuary because of the history of utilitin' California Edison Co. (San Onofre Emergencies.The section of the report and the NRC's reluctance to let the pubhc 5
I 5612 Federal Register / Vol. 55. No. 33 / Friday. February 16. 1990 / Proposed Rules l-
\\
know of danger and also because of problems The Commission alm finds no basis based on those releases because the in utihty. managed monitoring equipment.
for the claim that "NRC officials played radiation dose, actual or projected, was The NRC officists played down the gravity of the accident at Three Mile Island, as they down the gravity of the accident at small.The main threat perceived by the Three Mlle Island."In fact, quite the NRC staff was the potential threat from Iefa7ionIlmpact o he stemen han with contrary occurred. Admittedly, there a hydrogen gas explosion in the reactor technical accuracy.
were confusing af.d contradictory that could conceivably result in added Commenters opposing the Citizens statements which alarmed the public.
core damage and in. turn present added Task Force petition saw little evidence But,if anything. the actual danger may threat to the containment integrity.
of a problem with a credibility gap.The have been exaggerated rather than While the fears over en explosion of the law firm of Shaw. Pittman. Potts, and downplayed.
hydrogen gas were not technically well-Trowbridge wrote:
Furthermore, the proliferation of founded and, of course, the situation did independent radiation monitoring could not materialire,it was the central basis Aside frorri two newspaper accounts of result in conflicting and confusing for the evacuation recommendation that statements made more than three years ago informatioa during the course of an was made.The recommendation was I
by the North Carolina Governor and the State accident. Confusion can be minimized if not based on elevated radiation yi[,'C',',fl Radia ot e on pe (' "
information from all sources flows to a readings offsite because none of the p,g
,d aim d a ' credibility gap
- 8 ingle operations center where it can be offsite readings were high enough to analyzed by experts. Expert opinion justify ordering evacuation as a Barry G. Wahlig. a nuclear engineer could then be presented to the state and protective action.
wrote:
local governments charged with the l
Whether or not they suffer a ' credibility responsibility to order protective issue 13: Current planning is inadequate gep' as alleged by the petitioners. the existing actions.
l monitonna organizations are answerable to Moreover, esen if the reason Hill. NC. petition as a reason for the The Citizens Task Force of Chapel responsible bodies. The diffuse group of advanced by the petitioner and recommended rule change, stated that independent monitors suggested by commenters were valid. independent
" Emergency planning and preparedness Yut thernsel en for thia'c ur e of theirm nitoring w uld not be a solution.
In support of nuclear power plants is e
measurements. the method of their reporting.
Offsite monitoring is not intended and presently inadequate and incapable of or the consequences of poor values.This lack E cannot be used properly by itself to providing an acceptable level of of responsibility would make their b make intitial decisions on protective radiological emergency preparedness /
measurements less reliable. not more so.
3 actions. Elevated radiation levels offsite Since utilities are seen as not providing Commission Responsa T .am ng the very last indicators of a adequate emergency preparedness, o senous accident and tend to occur at a time when protective action decisions communities are seen as having to The Commission agrees that as of V
March 30.1979, there was a need to be F. should already have been made.The provide it for themselves. The petitioner l
better prepared for emergencies around ? earliestindication of a serious accident believes that this situation requires them nuclear power plants. This need T would be seen in the nuclear power to have their own monitoring equipment prompted the Commission to publish in C plant control room. Numerous indicators to detect radioactive materials in a short the Federal Register (45 FR 55402:
and alarms would tell the operators that enough time to allow them to make their August 19.1980) en upgraded emergency there is a problem and should enable own decisions on emergency actions.
I preparedness regulation. The regulation them to assess the problem. By NRC The Citizens Task Force petition
{
required, among other things, the,
regulation, each plant has a set of quoted a FEMA report which said that.
establishment of emergency planning emergency action levels based on for some of the 12 nuclear power plant zones, the development of emergency specific plant conditions which can be sites with the highest population density action levels, the installation of prompt used to project potential offsite doses' within the to mile EPZ. "the current public warning systems, and adequate Projected dose information allows alert and notification systems are judged offsite monitoring capabilities.
protective actions to be taken or at least to be totally inadequate..."(FEMA.
1mplementation of these upgraded considered prior to the arrival of the Dynamk Evacuauon Anaj ses, p. 5.
y regulations has been completed.
radioactive plume.For example,if a N
Equipment capability is continually core. melt were to occur causing a large nu e of ommenters expressed checked by NRC and FEMA.The release of radioactivity, there would little confidence in current emergency
{
Commission does not believe there is a necessarily be some time between the plans saying they should be more site-j lack of monitoring equipment and start of the accident and the release of speelfic, taking into account the,
therefore does not see lack of equipment the radioactivity from the fuel to the population density, large population as a reason to amend its regulations to containment because it takes time for centers just outside the 10-mile EPZ. a require that monitoring equipment be the heat being generated to evaporate lack of sufficient roads or the presence given to and operated by lochl the available water and heat the fuel to of bottlenecks on the roads. geography, communities.
Its r..elting point. During this time, and meteorology of each specific site.
The Commission also finds no bests to projected doses can be calculated and Commenters opposing the petition
}
assume there is a credibility gap that protective actions can be decided upon.
said that present emergency would cause a danger to public health recommended to the state and local preparedness is adequate, that the and safety.There is no evidence that the governments, and ordered before any petitioner based its conclusions on majority of the public would not respond appreciable amount of radioactivity has outdated information. and that the 3
to protective actions ordered by been released to the environment.
upgrade in emergency preparedness by responsible government authorities. At During the Three Mlle Island accident, utilities since the Three Mile Island Three Mile Island, although people the radioactivity actually released came accident should be recognized and given evacuated to a far greater extent than from auxiliary plant systems. The credit. For example, KMC. Inc. wrote:
N officially recommended and without a amount of radioactivity in these systems Bestanins in early test, each operatins iN written plan, the evacuation was quite was relatively small and no protective nuclear facility's emergency plan was
{
orderly.
actions would have been indicated appraised by the NPC us!ng NUREC-o654 as
)
5-041999 00ll(00X15-FEB-90-1&ll:19) l F4702TMT...lin.301. 7-nn-RA
Federal Register / Vol. 55. No. 33 / Friday. February 16, 1990 / Proposed Rules 5613 the basis of the appreisel and each facility preparedneu financing legislation do receive critique and NRC censure with operating exercised its plan In conjunction with the adequate funding.
license ramifications serves as a pragmatic State and local governments with both NRC and FT.MA as judges as to the adequacy of Commenters in support of the inducement for all utilities to provide the the exercise. Utihties were given 120 days to recommended change to require utility radiological emergency response planning correct deficiencies which could have an funding said that utilities should pay the and exercise funding. To include this in a I
adverse impact on the ability of the utility to full cost of choosing to build a nuclear petition for rulemaking and potential legalization may do no more than to create en promptly and effectively respond to an plant instead of some other type of intensely acrimonious relationship between emergency. Further nuclear facilities are generating plant.They said this should state government and utilities. Why legslize
'eq[ red,g thNr program and to ha,,,*"' dependent be considered part of the cost of doing what I know to already be the esse in lows exercise in conjunction with State and local business and that in some cases funding and other surrounding states, on a lurisdictions. In addition. the NRC will of emergency preparedness is a real cooperative basis.
j 1
perform an annual appraisal of each utility's hardship for the municipalities or emergency plan to assure that the utility's counties involved. They said it is unfair Severallaw firms said NRC did not emergency capability does not degrade. !t is to expect local governments to finance have authority to require such funding.
inappropriate to compare performance of these plans since some of the areas The law firm of Shaw. Pittman Potts emergency planning capability and under obligation to plan for nuclear d'
I implementation in 1979 with what has been qu red demonstrated in 1981 and 1982 power plant accidents do not receive The almple answer to this request is that any tax revenues from the plant. One Commission lacks the legal authority to commenter said:
impose such a tax...nis is because the Commission Response provision pursuant to which the Commission
.. considering the unique and deadly collects fees from Utilities. 31 U.S C. 483 a The Commission does not agree with dangers of radiation. it is insane lo reduce the (1976), has been authoritatively construed by the petitioner's claim that emergency already inadequate methods of protection the United States Supreme Court to authorize preparedness is presently inadequate.
and regulations. The utilities and the the imposition of fees only to cover services Emergency preparedness has been gonmment owe it to us to pay for our safety.
considerably increased since the Three They are putting our lives in jeopardy. not the rendered by a federal agency and then only tr
{
those services confer a special benefit on the Mile Island accident. The FEMA report ther **yaround-fee paying entity and not a general benefit on cited was written 10 cvaluate the Commenters opposing the petition the public si.large...This clearly would alerting system existing at that time generally stated that there was no need exclude the tax suggested by petitioner which against draft criteria that had just been for such a funding requirement. They
[" jig',,,d b't in
'C' db e issued for comment and interim use.
said that FEMA has not found state and o
Since the FEMA report was written, local plans inadequate due to lack of public benents rather than specincally identined benefits of the utilities, final criteria have been published and funding and that voluntary utility systems have since been improved to assistance together with state and local Some commenters pointed out that meet the criteria. FEMA and NRC now programs to assess costs for radiological utilities already pay considerable taxes periodially evaluate the emergency emergency preparedness have been and deserve some services in return.
preparedness at nuclear power plants successful. All seven of the state and They said, typically, that nuclear power and have generally found the local emergency preparedness agencies plants tend to be the largest single tax preparedness adequate. Where that commented on the petition say paying organization in their political improvements were thought necessary, there is no need for such a funding subdivision and, as a result. the they have been ordered.
requirement. Commenters said that residents of an area generally benefit The Commission does agree that site.
states should have jurisdktion over this from higher than average tax revenues, specific factors. such as those area of utility funding and that the even though the tax burden on the mentioned by some commenters, should Federal Government does not have the individual is usually lower than average, be taken into account in emergency expertise or the legal right to mandate Thus. municipalities around nuclear plans. In fact. NRC regula tions (10 CFR utility rate structure changes.
power plants already derive sufficient i
50r(c)(2)) already require emergency Some commenters thought utilities funds from the operation of the plant to plans to consider site specific factors.
should not be forced to fund s!! local finance their emergency planning preparedness eff rts because efforts.
- E'"'[e emergency preparedness Issue 14: Utility funding of emergency many of i improvements also improve Commissloo Response Another change recommended by the governmental abilities to cope with Funding arrangements are essentially Citizens Task Force of Chapel Hill. NC natural disasters and other types of a matter of state and local government petition is that utilities be required to man made emergencies The utilities interest; therefore, the Commiss!on finds finance the eme gency planning and should not have to bear the full costs of no factual basis to conclude that the preparedness efforts of the these improvements in plans and proposed funding is necessary to enable municipalities around nuclest power facilities which overlap with other state or local governments to establish plants.The Cittrens Task Force wrote:
functions normally required of the adequate emergency preparedness Lack of funding is the single largest governmenta, plans. Accordingly, we do not reach the impediment to the establishment of an Some commenters said utilities had a question of our legal authority to require adequate level of ememency preparedness strong Incentive to fund local licensee funding in the manner around nuclear reactors....
preparedness efforts.The State of town requested by the petitioner.
Many states clearly have been unable to Office of Disaster Services said that echieve effective legal steps to insure that Iowa already receives fundin Issue 15:That emergency preparedness attilities finance adequate emergency preparedness around nuclear plants, assistance from four nuclear scilities requirements be estab!!shed for low and added*.
Power operations
'the role of the federal government in regard to emergency preparations should be Obviously the utilities do not, by law, have The State of Maine petition requested tiinsure that the commur.ities in those states to provide this funding but practically that the NRC require that offsite which have not, or will not soon. enact speaking. It is being done. The onus of FEMA emergency preparedness findings be 5-041999 0012(00Xt$-FElk9010:ll:22) r.-n. n ew-e....$
5614 Fzderal Register / Vol. 55, No. 33 / Friday. February 18. 1990 / Proposed Rules made before any fuelloading and/or i 50.47 to require that emergency amending its regulations on emergency low power operations are permitted.
planning be done before any preparedness in any of the ways
)
Commission Response construction of a nuclear facility is recommended by the petitioners. The permitted and that the Governor or petitions of the Cititzens' Task Force of in a final rule published in the Federal Governors of any affected State approve Chapel Hill. North Carolina: Mr. K.
Register on September 23.1988 (53 FR the emergency plans as a precondition Sexton: and the Attorney General of the 36955,36960) the Commission addressed to construction.
this specific matter and for the reasons State of Maine are hereby denied.
stated therein revised to CFR 50.47(d) to Cornrnission Response g(
l WaSand h m by a
read...
The intent of the State of Maine's
- *
- no NRC or FEMA review findings, or petiton waa granted in part in a final For the Nuclear Regulatory Commission.
determinations concerning the state of offsite rule published in the Federal Register on lohn C. Hoyl**
emergency preparedness or the adequacy of April 18,1989 (54 FR 15372,153GJ) where A88/8""**""'T " O' C***i'8/*^-
and capability to implement State and local the Commission added new regulations (nt Doc. 90-3735 Filed 2-15-e&, aA5 am]
or utility offsite emergency plans are required to provide for issuance of early site swuo cooe toes.skas prior to i,esuance of an operating license permits. stcndard design certifications, authorizmg only fuelloading or low power and combined construction permits and d po er)?in har as e er3 ncy planning operating licenses for nuclear power NATIONAL. CREDIT UNION I
and preparedness requirements are reactors.The aim of this rulemaking was ADMINISTRATION concemed a license authorizing fuelloedbg to provide procedures for the and/or low power testing and training may standardization of nuclear power plants 12 CFR Parta 722 and 741 be issued after a finding is made by the NRC and the early resolution of safety and that the state of onsite emergency preparedness provides reasonable assurance environmentalissues in licensing Appralaala and Requirements for that adequate protective measures can and proceedings. The new rule requires in 10 insurance wdl be taken in event of a radiological CFR part $2. I 52.79(d) that applications emergency. The NRC will base this finding on for a combined construction Eermit and A0gNcy: National Credit Union l
its assessment of the applicant's onsite operating license must contain Administration (NCUA)-
emergency plans against the pertinent emergency plans which provide ACTION: Proposed Amendments, standards in paragraph (b) of this section and reasonable assurance that adequate Appendix E. Review of applicant's protective measures can and will be
SUMMARY
- This proposed regulation emergency plans willinclude the following taken in the event of a radiological implements Title XI of the Federal j
standards with offsite aspects-emergency at the site.
Financial Institutions Reform. Recovery effectively using offsite assistance on site (1)If the application references an early and Enforcement Act of1989
{
(11 Arrangements for requesting and have been made, arrangements to site permit. the application may incorporate
("FIRREA"). It is intended to protect accommodate State and local staff at the by mfuence emugency plans. or major Federal financial and public policy interests in real estate related financial "8 " hot sn onne tio w th t i suanc o e pe it.
transactions requiring the services of an I
Fa y ave emd organizations capable of augmenting the (2)If the application does not reference an appraiser. Title XI of FIRREA and this planned onsite response have been identified, early site permit. or if no emergency plans proposed regulation provide the affected (2) Procedures have been established for were approved in connection with the Federal entities with added assurance licensee communications with State and local issuance of the permit. the applicant shall that real estate appraisals used in response organlaations. including initial
- [ Ialth e o a c nnection with Federal responsibilities t "
notification of the declaration of emergency
,gp
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and requirements are performed in and periodic provision of plant and response f,*nn n re pons t t$e proposed accordance with uniform standards by
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ie il t status reports.
(3) Provisions exist for prompt emergency plans are practicable,(ii) that individuals whose competency has been communications among principal response these agencies are committed to participating demonstrated and whose professional Pusonnel in any futher development of the plans, condur.1 will be subject to effective w
o 1 be po ig s te including ery required field demonstrations.
supervision.Toward this end, the (4) Adquate emergency facilities and and (111) that these agencies are committed to equipment to support the emergency response execuung their nsponsibiHties undu the proposed regulation identifies which yIt transactions require an appraiser, sets fp*p g,"g,h fn'u' orth minimum standards for performing ensite are provided and maintained.
(5) Adquate methods systems,and ta y rtific ons equipment for assessing and monitoring that have been obtained. If these appralsals, and distinguishes those cctual or potential offsite consequences of a certifications cannot be obtained, the appraisals requiring the services of a radiological emergency condition are in use application must contain information, state-certified appralser from those ensite.
including a utility plan. sufficient to show requiring a elate licensed appraiser, that the proposed plans nonetheless provide Uniform proposed regulations are being se e for con el n t d n in o site ift taken in
,et v mes res can and tegu at a Rs ogical emergency response te' DAfts: Comments must be received on training has been rnade available to those c,ffsite who may be called to assist in an These provisions provide that to the or before April 17,1990.
emergency onsite.
maximum feasible extent emergency ADDRESSts: Send comments to Becky lesus 18: Emergency plans should be
[lans will be approved by the NRC Baker, Secretary NCUA Board,1776 G efore it issues the construction permit Street NW., Washington, DC 20456.
completed and approved by the Governor of the affected State as a pr*
for a new nuclear power plant.
FOR FURTHER INFORMATION CONTACTt condition to construction The petition (s) are denied Michael J. McKenna, Office of General Counsel, at the above address or The State of Maine petition requested in conclusion, the Commission finds telephone: (202) 682-9630, or Timothy P.
that the Commission amend 10 CFR that an insufficient basis exists for Hornbrook. Omce of Examination and s-041999 001)(00XIS-FEB-90-10:lld4)
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Bosm, MA 02M December 29,1997 M W. Roe, Acting Director tJ.S. Nuclear Regulatory Comnussion Headquarters Room N1-H21 11555 '.<ockville Pike Rockville,MD 20852
Dear Mr. Roe:
Enclosed is a copy of the final exercise report for the August 8,1997, full-pa'ticipation Plume pathway exercise and the October 8,9, and 10,1997 ingestien pathway exer-ise of the offsite radiological emergency response plans site-specific tc the Millstone Nuclear Power Station. The State of Connecticut, the City of Groton, and the '. owns of East Lyme, Groten, Ledyard, Lyme, Montville, Old Lyme, and Waterford in Conneticut and the Hamlet of Fishen Island in New York fully participated in these exercises. The O ty el New london participated in the Ingestion portion. The Federal Emergency Management e.gency (FEMA) Region I staff prepared the final exercise report. The FEMA Region I staff wii provide a copy of this report to the State of Connecticut.
There were no Deficiencies identified during the August or October exercise. There were, however, ten Areas Requiring Corrective Action (ARCAs) identified. The FEMA Region I staff will work with the State of Connecticut to correct these actions.
Based on the results of the August and October exercises, the offsite radiological emergency response plans and procedures for the State of Connecticut and the affected local jurisdic+ ions, site-specific to the Millstone Nuclear Power Station, can be implemented and are adequate to provide reasonable assurance tlut appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site. Therefore, the Title 44 CFR, Part 350, approval oMe offsite radiological emergency response plans and preparedness for the State of Connectics site-specific to the Millstone Nuclear Power Station, granted in October, 1984, will remain in afect.
If you should Er.ve any questions, please contact Ihor W. Husar, Chief, State and local Regulatory Evaluation and Assessment Branch, at (202) 646-4%5.
Sincerel) e A. Bean R 'onal Director Enclosure cc:
Hubert J. Miller, Regional Admuustrator, NRC, Region 1 Ihor W. Husar, FEMA Headquarters I.-
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_/$g '? Federal Emergency Management Agency t d + %, y # Region 1 J.W. McCormack Post Office & Counhouse Building. Room 442 Boston.MA 02109 December 29,1997 Jack W. Roe, Acting Director U.S. Nuclear Regulatory Commission Headquarters Room 011-H21 11555 Rockville Pike Rockville,MD 20852
Dear Mr. Roe:
Enclosed is a copy of the final exercise report for the August 8,1997, full-participation Plume pathway exercise and the October 8,9, and 10,1997 Ingestion pathway exercise of the offsite radblogical emergency response plans site-specific to the Millstone Nuclear Power Station. The State of Connecticut, the City of Groton, and the towns of East Lyme, Groton, ledyard, Lyme, Montville, Old Lyme, and Waterford in Connecticut and the Hamlet of Fishers Island in New York fully participated in these exercises. The City of New london participated in the Ingestion portion. The Federal Emergency Management Agency (FEMA) Region I staff prepared the final exercise report. The FEMA Region I staff will provide a copy of this report to tb State of Connecticut. There were no Deficiencies identified during the August or October exercise. There were, however, ten Areas Requiring Corrective Action (ARCAs) identified. The FEMA Region I staff will work with the State of Connecticut to correct these actions. 1 Based on the results of the August and October exercises, the offsite radiological emergency response plans and procedures for the State of Connecticut and the affected local jurisdictions, site-specific to the Millstone Nuclear Power Station, can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site. Therefore, the Title 44 CFR, Part 350, approval of the offsite radiological emergency response plans and preparedness for the State of Connecticut site-specific to the Millstone Nuclear Power Station, granted in October, 1984, will remam in effect. If you should have any questions, please contact Ihor W. Husar, Chief, State and local Regulatory Evaluation and Assessment Branch, at (202) 646-4065. Sincere lly &W e rUf A. Bean R ionalDirector Enclosure Hubert J. Miller, Regional Admuustrator, NRC, Region 1 cc: Ihor W. Husar, FEMA Headquarters 4 OW b I,. f 9 ....--____-...J
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TABLE OF CONTENTS Page I. EXECUTIVE S UMMARY.................................................................................... 1 II. INTRODUCTI ON.................................................................................................. 2 III. EXE R CIS E OVERVIEW....................................................................................... 4 A. Plume Emergency Planning Zone Description............................................... 4 B. Ex erc i se Pani cipants......................................................................................... 5 C. Ex e rci se Ti meli ne............................................................................................ 12 IV. EXERCISE EVALUATION AND RESULTS...................................................... 15 A. Summary Results of Exercise Evaluation........................................................ 15 B. S tatus of Jurisdictions Evaluated...................................................................... I8 f
- 1. STATE OF CONNECTICUT....................................................................
20 1.1 State Emergency Operations Center............................................ 20 1.2 Depanment of Environmental Protection (DEP)........................ 23 1.3 Emergency Operations Facility (EOF)........................................ 25 1.4 State Field Monitoring Teams.................................................... 26 1.4.1 Field Monitoring Team "A"............................................. 26 1.4.2 Field Monitoring Team "B".............................................. 28 i 1.5 S tate Field S amplin g Teams......................................................... 29 1.6 Join t Medi a Ce n ter........................................................................ 30 1.7 State Department of Health (DHS) Laboratory............................ 33 1.8 OEM Area IV, Colchester............................................................. 34 1.9 State Police Access Control Points / Traffic Con trol Poin ts............................................................................... 35 1.10 S tate Compensatory Plan.............................................................. 36
- 2. RIS K J URIS DICTION S............................................................................
37 2.1 East Lyme EOC............................................................................ 37 2.2 Hamlet of Fishers Island, NY, EOC............................................. 37 2.3 City of Groton EOC...................................................................... 38 2.4 Town of G roton E0C................................................................... 38 2.5 Le dy ard EOC................................................................................ 39 i
TABLE OF CONTENTS (Cont.) 2.6 LymeEOC.................................................................................... 40 2.7 M on t vill e EOC.............................................................................. 40 2.8 City of New London EOC........................................................... 41 2.9 Old Ly me E0C............................................................................. 41 2.10 Wate rford EOC............................................................................. 42 2.11 S chool/B u s Evac uation................................................................. 42 2.1 1.1 Town of East Lyme......................................................... 42 2.1 1.2 Town of Ledy ard........................................................... 43 2.1 1.3 Town of Old Lyme......................................................... 43 2.12 Special Populations - Nursing Homes.......................................... 44 2.13 Med i cal Services........................................................................... 44 2.13.1 Transportation -Town of Waterford Ambulance Company...................................................... 44 2.13.2 Facilities - Lawrence and Memorial Hospital, City of New London........................................................ 45
- 3. SUPPORT JURIS DICTIONS....................................................................
45 3.1 Wi n d h am EOC............................................................................. 45 3.2 Windham Reception Center.......................................................... 46 3.3 Windham Congregate Care Facilities.......................................... 46 List of Appendices APPENDIX 1 - ACRONYMS AND ABBREVIATIONS............................................. 48 APPENDIX 2 - EXERCISE EVALUATORS AND TEAM LEADERS........................ 51 APPENDIX 3 - EXERCISE OBJECTIVES AND EXTENT-OF-PLAY AGREEMENT...................................................... 55 APPENDIX 4 - EXERCISE SCEN ARIO.......................................................................... 95 List of Tables Tabl e 1 - Exerci se Ti meli ne.............................................................................................. 13 l l l Table 2 - Summary Results of Exercise Evaleation........................................................... 16 U b' e
L EXECUTIVE
SUMMARY
On August 21,1997, an exercise was conducted in the Plume Exposure Pathway emergency planning zone (EPZ) around the Millstone Nuclear Power Station by the Federal Emergeacy Management Agency (FEMA), Region I. This was followed on October 8,9, and 10,1997, by an exercise conducted in the Ingestion Exposure Pathway emergency planning zone. The purpose of the exercises was to assess the level of State and local preparedness in responding to a radiological emergency. These exercises were held in accordance with FEMA's policies and guidance conceming the exercise of State and local radiological emergency response plans (RERP) and procedures. The most recent exercise at this site conducted on October 5,1995. The qualifying emergency preparedness exercise was conducted in 1982. FEMA wishes to acknowledge the efforts of the many individuals who panicipated in this exercise. The various agencies, organizations, and units of government from the State and localjurisdictions within the State of Connecticut who participated in this exercise are listed in Section III.B of this report. Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities. Cooperation and teamwork of all the panicipants were evident during this exercise. This report contains the final evaluation of the biennial exercise and the evaluation of the following out-of-sequence activities: Ingestion Pathway exercise, week of October 6,1997. School demonstrations in East Lyme, Ledyard, and Old Lyme, week of October 6,1997. Windham Host Community EOC, Windham Reception Center, and Congregate Care Facilities, week of October 6,1997. Access Control Points, week of October 6,1997. Medical Services (MS-1) drill with Lawrence and Memorial Hospital, and Waterford Ambulance Company on October 9,1997. Nursing Homes, week of October 6,1997. The State and local organizations, except where noted in this repon, demonstrated knowledge of their emergency response plans and procedures and adequately implemented i .~rn. n. p,;,. :g g
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s them. There were no Deficiencies and 10 Areas Requiring Corrective Action (ARCA) N,,, identified as a result of this exercise. i I II. INTRODUCTION On December 7,1979, the President directed FEMA to assume the lead responsibility for all offsite nuclear planning and response. FEMA's activities are conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350,351 and 352. These regulations are a key i element in the Radiological Emergency Preparedness (REP) Program that was established following'the Three Mile Island Nuclear Station accident in March 1979. FEMA Rule 44 CFR 350 establishes the policies and procedures for FEMA's initial and continued approval of State and local governments' radiological emergency planning and preparedness for commercial nuclear power plants. This approval is contingent. in part, on State and local govemment participation in joint exercises with licensees. FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following: Taking the lead in offsite emergency planning and in the review' and evaluation e of RERPs and procedures developed by State and local governments; f Determining whether such plans and procedures can be implemented on the e l basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments; Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) j e l pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17,1993 (Federal Register, Vol. 58, No.176, September 14,1993); and Coordinating the activities of Federal agencies with responsibilities in the e l radiological emergency planning process: U.S. Department of Commerce, U.S. Nuclear Regulatory Commission, U.S. Environmental Protection Agency, U.S. Department of Energy, U.S. Department of Health and Human Services, U.S. Department of Transportation, U.S. Department of Agriculture, U.S. Department of the Interior, and U.S. Food and Drug Administration. 2
Representatives of these agencies serve on the FEMA Region I Regional Assistance Committee (RAC) which is chaired by FEMA. Formal submission of the RERPs for the Millstone Nuclear Power Station to FEMA Region I by the State of Connecticut and involved local jurisdictions occurred in 1982. Formal approval of the RERP was granted by FEMA in October 1984, under 44 CFR 350. A REP exercise was conducted on August 21,1997 (Plume Exposure Pathway), and during the week of October 6,1997 (Ingestion Exposure Pathway), by FEMA Region I to assess the capabilities of State and local emergency preparedness organizations in imp;ementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving the Millstone Nuclear Power Station. The purpose of this exercise report is to present the exercise results and findings on the performance of the offsite response organizations (ORO) during a simulated radiological emergency. The findings presented in this report are based on the evaluations of the Federal evaluator team, with final determinations made by the FEMA Region I RAC Chairperson, and approved by the Regional Director. 'Ihe criteria utilized in the FEMA evaluation process are contained in : NUREG-0654/ FEMA-REP-1, Rev.1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980; FEMA-REP-14, " Radiological Emergency Preparedness Exercise Manual," e September 1991; and FEMA-REP-15, " Radiological Emergency Preparedness Exercise Evaluation + Methodology," September 1991. Section III of this report, entitled " Exercise Overview," presents basic information and data relevant to the exercise. This section of the report contains a description of the plume pathway EPZ, a listing of all participatingjurisdictions and functional entities which were evaluated, and a tabular presentation of the time of actual occurrence of key exercise events and activities. Section IV of this report, entitled " Exercise Evaluation and Results," presents detailed information on the demonstration of applicable exercise objectives at each jurisdiction or functional entity evaluated in ajurisdiction-based, issues-only format. This section also contains: (1) descriptions of all Deficiencies and ARCAs assessed during this exercise, recommended corrective actions, and tne State and local governments' schedule of corrective actions for each identified exercise issue and (2) descriptions of unresolved ARCAs assessed during previous exercises and the status of the OROs' efforts to resolve them. 3
III. EXERCISE OVERVIEW Contained in this section are data and basic information relevant to the August 21,1997 Plume Exposure Pathway exercise and week of October 6,1997 Ingestion Exposure Pathway exercise to test the offsite emergency response capabilities in the area surrounding the Millstone Nuclear Power Station. This section of the exercise repon includes a description of the plume pathway EPZ, a listing of all panicipating jurisdictions and functional entities which were evaluated, and a tabular presentation of the time of actual occurrence of key exercise events and activities. A. Plume Emergency Planning Zone Description The area within ten miles of the Millstone Nuclear Power Station is located in the States of Connecticut and New York. The eight Connecticut communities within the Millstone EPZ are entirely located in New London County. The one M:w York community and the Plum Island Animal Disease Center (PIADC), a USDA research facility, are located in Suffolk County. Millstone Station is located on the coast of Connecticut, in the Town of Waterford, and is adjacent to Long Island Sound. Based on the 1990 census, the total population of the EPZ is 128,600, with the permar.ent population of those New York ponions of the EPZ being approximately 300. Two parallel Amtrak freight and passenger lines run east-west along the coast through the Connecticut portion of the EPZ, passing across the utility owner controlled property. Major highways within the EPZ include Interstate 95, running east-west approximately four miles nonh of the site, and Interstate 395 running approximately nonh beginning about four miles nonh of the site. Public institutions, aside from schools and churches, within the EPZ include the PIADC, the Niantic Correctional Facility, Lawrence and Memorial Hospital, the United States Coast Guard Academy, the United States Naval Submarine Base at New London (Groton), the Naval Undersea Warfare Center, and the Rocky Neck State Park. l The EPZ is divided into three zones for the purpose of einergency response ( planning and implementation of protective actions. l l 4
B. Exercise Participants The following agencies, organizations, and units of government participated in the Millstone Nuclear Power Station Plume Exposure Pathway exercise on August 21,1997, and/or the Ingestion Exposure Pathway exercise the week of October 6, 1997. STATE OF CONNECTICUT STATE EMERGENCY OPERATIONS CENTER Governor's Office Office of Emergency Management (OEM) American Red Cross Connecticut National Guard Connecticut State Police Nonheast Utilities Connecticut Department of Consumer Protection Connecticut Health Service U.S. Coast Guard Connecticut Department of Agriculture Connecticut Environmental Protection Agency (EPA) (Parks and Recreation) Connecticut Department of Transportation Connecticut Department of Environmental Protection Connecticut Consumer Protection Division Federal Emergency Management Agency Nuclear Regulatory Commission Department of Health Services DEPARTMENT OF ENVIRONMENTAL PROTECTION Department of Environmental Protection Monitoring and Radiation (DEPM&R) Electric Boat Nonheast Utilities EMERGENCY OPERATIONS FACILITY (EOF) DEPM&R Waterford Town Government (Town Planner) Waterford Police Depanment ,.......oj e.
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STATE FIELD MONITORING TEAMS (Plume Phase) DEPM&R DEP Oil and Chemical Spill Response Division STATE FILD MONITORING AND SAMPLING TEAMS (Ingestion Phase) DEPM&R Connecticut Department of Agriculture Connecticut Consumer Protection Connecticut Depanment of Public Health., Water Services Division JOINT MEDIA CENTER (Plume and Ingestion) Govemor's Press Office Connecticut Office of Emergency Management Connecticut State Police Depanment of Public Health Department of Environmental Protection Nonheast Utilities Connecticut Depanment of Agriculture STATE DEPARTMENT OF HEALTH (DHS) LABORATORY Connecticut Depanment of Public Health (DPH) Connecticut Depanment of Environmental Protection (DEP) Connecticut State Police OEM AREAIV,COLCHESTER(Plume) OEM Area IV Emergency Management Officer OEM Area I Emergency Management Officer State Police RACES Community volunteers STATE POLICE ACCESS CONTROL POINTS / TRAFFIC CONTROL POINTS State Police (Troop E, Montville) Connecticut Depanment of Transponation 1 i 6
RISK JURISDICTIONS EAST LYME EOC Emergency Management Police Department Resident State Trooper Communication (ham operator) Fire Marshal Water Superintendent Sewer Superintendent Visiting Nurse Association, Southeastern Connecticut Public Works Deparunent Superintendent of Schools Health and Sanitation HAMLET OF FISHERS ISLAND, NY, EOC Chief Executive Officer (CEO) Director of Emergency Management Fire Depanment New York State Police CITY OF GROTON EOC Mayor Police Department Fire Department Park and Recreation Department Building Inspectors Office City Utilities Highway Depanment j Finance Depanment TOWN OF GROTON EOC Town Manager's Office Civil Preparedness Office Administrative Services Office Police Depanment Fire Depanment Emergency Dispatch Center Informational Technical Office EMS Coordinator / Fire Service Board of Education Risk Management Office 7 @ 4 /;qy,$4th:( t -g> g..* 3..; +f.:-l:..-< yeg ;i gj -.yp ;,,yggg.;..g, M.Qb.
~~ Public Works Office Economic Development Office Finance Department Parks and Recreation Department Human Services Department Town Library Town Clerk's Office ledge Light Health District Groton Ambulance Association The Mystic Fire Department LEDYARD EOC I Chief Elected Official (Mayor) Emergency Management Director Fire Depa2tment Police Department Volunteer Emergency Medical Services - Ambulance Health Department Resident State Trooper School Department Public Works Department HAM radio operator LYMEEOC Emergency Management Volunteers Fire Police Personnel EMS Volunteer Fire Fighters MON 1VILLE EOC CEO - Mayor Office of Emergency Management (OEM) Fire Department and Dispatch Center School Department Public Works Department CITY OF NEW LONDON EOC The City of New London did not participate in the August 1997 exercise. Emergency response measures for the City of New London were taken by the State of Connecticut by means ofits compensatory plan. 8 1 i m _.ammensum m a-a - - - -
OLD LYME EOC Board of Selectmen Emergency Management Office Fire Department Police Department Public Works School Superintendent Health Director and support staff WATERFORD EOC First Selectman and Secretary Police Department i Public Works Board of Education -- Superintendent Building Depanment Emergency Management Planning, Building and Health Recreation and Parks Fire Marshal's Office Water Pollution Control Authority Town Treasurer Social Services Finance Department Communications Supervisor Dispatcher -- Communications Center Chairman, Emergency Management Advisory Council ARES SCHOOUBUS EVACUATION TOWN OF EAST LYME Lillie B. Haynes School Principal, Lillie B. Haynes School Bus Guide j OEM Area IV Coordinator Laidlaw Bus Company Superintendent of Schools / Designee Emergency Management Director Bus Driver East Lyme Amateur Radio Operator Custodian 1 9
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h' TOWN OF LEDYARD Gales Ferry Elementary School Principal, Gales Ferry School Emergency Management Director Superintendent of Schools Bus Guide and Bus Driver Ledyard Transportation,Inc. TOWN OF OLD LYME j Mile Creek School Principal, Mile Creek School Emergency Management Director Double A Transportation Superintendent of Schools First Selectman Bus Guide Bus Driver and Assistant Bus Driver SPECIAL POPULATIONS - NURSING HOMES E. Lyme: Director of Emergency Management Waterford: Special Needs Liaison, Social Service Coordinator, both EOC staff. Mariner Health Care at Bridebrook Nursing Home Facility Safety Director Bayvie v Health Care Center Nursing Home. Facility Administrator Director of Nursing Center for Optimum Care Nursing Home Facility Director Director of Admissions New London Rehab & Care Center Nursing Home l Facility Administrator Director of Maintenance Greentree Manor Convalescent Center Nursing Home Facility Administrator Director of Nursing 10
MEDICAL SERVICES TRANSPORTATION - Town of Waterford Ambulance Company FACILITIES - Lawrence and Memorial Hospital, City of New London SUPPORT JURISDICTIONS WINDHAM EOC Windham Police Department Windham Fire Department Human Services Emergency Management i f Public Facilities / Works American Red Cross (ARC) Selectman Department of Education WINDHAM RECEPTION CENTER Willimantic Fire Company Windham Department of Public Health Windham Center Fire Department American Red Cross WINDHAM CONGREGATE CARE FACILITIES Willimantic Emergency Management Director Windham Center School North Windham Elementary School North Windham Firehouse Eastern Connecticut State University Sweeney Elementary School Windham Middle School Windham Technical Windham High School PRIVATE / VOLUNTEER ORGANIZATIONS American Red Cross RACES 11 . c e...... ". y .y - + o.,. 3.. .,g,e, 1, 4. 4 g, ;,. f..cf...,s4Q _ x... e. _.. y,n.....s.
I i C. Exercise Timeline Table 1, on the following page, presents the time at which key events and { activities occurred during the Millstone Nuclear Power Station Plume Exposure Pathway exercise on August 21,1997. Also included are times notifications were made to the participating jurisdictions / functional entities. + a o 12 r
1 E My L 0 0 1 1 0 5 0 0 8 8 7 0 7 0 4 1 1 A 2 0 1 1 1 5 3 2 3 0 1 3 3 / 0 2 5 2 3 1 3 3 3 N 1 1 1 1 1 1 1 1 1 1 1 1 1 DR te A te y c D e E p L p 3 0 9 5 6 6 2 2 6 9 8 4 A 0 3 0 3 0 0 1 2 5 3 1 3 t 0 9 3 0 2 5 2 3 1 3 3 3 oN 1 1 1 1 1 1 1 1 1 1 1 1 s A A / P N O N lo tn F o n O h e NT c lti S u e WO le c T O R d ip G e e T s A s e 0 3 0 0 0 5 0 u 3 7 3 9 3 W 0 3 1 3 0 2 5 e o1 2 1 3 3 1 3 2 0 sly 2 2 5 1 3 0 1 3 s r n Do1 1 1 1 1 1 1 1 n o 1 1 1 1 it ito cA ic FN r d e OO d y 6e T r O u e e T J, v I R 5 9 1 1 0 6 6 4 9 3 O O' n ie CG 5 2 1 1 5 5 4 1 1 3 9 1 3 3 4 1 2 5 / 3 3 c i e 0 1 1 1 1 1 1 1 / N 1 1 N l R e C ee S D A m W R N E n i e H A A s S L 8 9 0 0 0 7 5 9 3 T ic 9 9 3 3 / i 2 / 1 3 3 o I S FI 5 2 1 1 A 3 0 A 5 1 3 M 0 1 1 1 N t 1 N 1 1 1 ei y ee s o, 8 1 e i. t o a TE co h P T SM r AY e e 0 7 1 6 0 0 7 3 9 3 er EL m 0 4 1 0 A 4 5 0 O 5 1 3 us i 0 1 3 3 / 0 1 5 / 1 3 3 xo T N n N 1 1 1 1 1 1 1 1 1 1 p io E t E c I e e V e 1 ru A lo ru n E J R 0 9 7 3 9 8 S 8 3 9 3 5 g eni A 5 3 0 1 1 5 O 5 5 1 3 3 in 9 1 3 3 0 1 S 1 1 3 3 3 k l o. 0 1 1 1 1 1 I 1 1 1 1 1 a b t. M t aS n to T O n o lc F t e o n I e c. E 8 2 0 4 0 0 4ry 2ys yK 4 D s 5 2 5 0 3 0 0e R 1 h v h r t e t 0 o 9 1 2 3 0 5 3t A 3t e t e3 i i r s1 D 0 UP ie 1 1 1 1 1 1 UR Uu 1 u N. n E e TC AO tsm TE 8 6 3 6 5 0 6 1 5 5 6 8 0 2 8 4 5 0 S 5 3 1 0 A 3 5 0 5 1 5 15 2 2 2 2 3 3 1 u. 9 1 3 3 / 0 1 5 8 3 1 3 3 3 3 3 3 3 0 1 1 1 N 1 1 1 1 1 1 1 1 1 1 1 1 1 1 7 9 n n d ot e t. ye it n 2 i e r le e r a hme dl e t iee e c s TDe r r .u D 5 2 9 4 ue 4 2 4 0 d Jp u o 9 1 2 3 n t A 0 1 1 1 e pn a r t n eo E e
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W te e f A fR ne he T eeW n n e ae lee c d A le re u d J e g e v n e iq e n c e e O e v i 4 l 1 R c e h O A F m R E A n T i ee A 0 e 3 2 7 0 8 0 8 4 3 9 4 5 T n W 0 3 1 1 A 3 1 0 1 1 5 3 1 3 1 0 1 3 3 / 0 2 5 2 3 1 3 3 3 3 e 1 1 1 1 N 1 1 1 1 1 1 1 1 1 1 m e iv e e e s s p E e a M t ic e h Y P T L r s D 5 4 0 8 7 7 7 9 3 3 8 3 2 e u L 5 3 1 3 0 0 0 1 5 3 1 3 4 h O 9 1 3 0 2 5 2 3 1 3 3 3 3 n x T 0 1 1 1 1 1 1 1 1 1 1 1 1 ito E ce. E. N len O r a W alp D J 1 E n N N 5 0 5 gr y O 5 2 3 no e m d t L 1 3 3 loee 1 1 1 l Mn b e e e s s e v a ia o r n T -TE icC NLL a r OI 4 6 6 8 0 9 0 9 9 3 2 9 2 2 De MV p A 2 0 0 0 1 5 3 1 3 4 0 3 1 1 w 0 1 3 3 / 0 2 5 2 3 1 3 3 3 3 n De 1 1 1 1 N 1 1 1 1 1 1 1 1 1 1 dno L E w ne TC o AO e ie S TF 8 6 3 6 9 0 6 1 5 5 6 8 0 2 8 4 5 0 m S 5 3 1 0 A 3 5 0 5 1 5 5 2 2 2 2 3 3 1 ro M. 9 1 3 3 / 9 1 5 1 3 1 1 3 3 3 3 3 3 3 f 9 1 1 1 N 1 1 1 1 1 1 1 1 1 1 1 1 1 1 e 7 n 9 o 9 nh os 1 ited d ldde o rn i e 2 i m e e n mUed s e t i t c em D 5 2 9 Ja 4 2 4 t t 9 1 2 r n A 0 1 1 n e a ie e So e pf E l pm r ts a e e o n n e e o s o g T d I it W s D a I e f c S' e s n r o s S n n y d e A n e s t e n e c y e p e d e s ie lt la S e ye e n c r M n e i n e y e I c h c O o t r W D esv t o a c e S A e n nsE e n o d S n n A v se g e t v N 9m e r t e g S T e d o e S e e S tt r r s t s e s e e e a e n n e P e h A o in A oc e S inte v c E r c E e n n r A ee n r A r t A r e r u e nse v E n s s c n e o e c o e o - r s v s e s e e T c e n e n im n t Ea E e E s e D s s e s S nn E Co la r de l l y o o e s e S t L e e e r e s D r r e e A h r N T r S E P S E D S E s ls n A o t e f. f. N e c r P 4 Ae E E t r A m r s n d d c e e r t t t d d d d d s e e n r 3 D G D U A S G R le a o s e s s o n n n r 3 3 K n l It e e f F D E E 1 1 t 2 2 2 3 EL g Il l l ( I
IV. EXERCISE EVALUATION AND RESULTS Contained in this section are the results and findings of the evaluation of alljurisdictions and functional entities which participated in the August 21,1997, plume exposure pathway exercise to test the offsite emergency response capabilities of State and local governments in the 10-mile EPZ surrounding the Millstone Nuclear Power Station, as well as the ingestion exposure pathway exercise conducted during the week of October 6, 1997. Eachjurisdiction and functional entity was evaluated on the basis ofits demonstration of criteria delineated in exercise objectives contained in FEMA-REP-14, REP Exercise Manual, September 1991. Detailed information on the exercise cbjectives and the extent-of-play agreement used in this exercise are found in Appendix 3 of this report. l A. Summary Results of Exercise Evaluation - Table 2 The matrix presented in Table 2, on the following page(s), presents the status of all exercise objectives from FEMA-REP-14 which were scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. Exercise objectives are listed by number and the demonstration status of those objectives is indicated by the use of the following letters: M-Met (No Deficiency or ARCAs assessed and no unresolved ARCAs from prior exercises) D-Deficiency assessed A-ARCA(s) assessed or unresolved ARCA(s) from prior exercise (s) N-Not Demonstrated (Reason explained in Subsection B) j i 15 i h ..7 .- n '.
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33 2 3 1 n 3 o i t 0 a 3 t S 9 M r 2 e w 82 M M o P 7 M A 2 ra 6 e 2 M M l e 52 A iN 4 e 2 no 3 M t 2 s ll 2 iM 2 ) 1 y 2 M s n a A 0 C o w 2 M R i h t t 9 A s a 1 i r u 8 io P rp l n 1 t o d v it 7 e M M M M M M M M M M N M M v 1 s E e o n l 8 s ito g A M M M M M M M M M M M M e t a n 1 f r I n a n r ( 5 u t M M M M M A M M M N M M M s i 1 c 7 ro n r 9 4 / o M M M d m 9 1 n 1 a e x 3 d M d d r 1 E 6 e e o s t f 2 f r A s e e e r d 1 t e c b s n u s s l 1 A e o d o 1 a t ) mhe t c 0 s M M M M M M M M M N M M A( D s e c O l 1 u C f t t s o 9 M R o o A N N k R e 8 M = e y W k 7 A M = = n r le d A N B ? n 6 M m.a ~ m ,)a 5 A M M M M A M M M M M M M N M M y u w 4 M M M M M M M M M M M M M N M M S h ta 3 M M M M M M M M M M N M M P 2 e 2 M M M M M M M M M M N M M m d b u 1 M M M M M M M M M M N M M se l h P s ( e c s l T 7 o J s o e )s 9 h sA 9 c AC 1 lo S CR o y o RA h r 1 c a l C l Ar d a t n S n o e n o e 2 ito y s e o c o ri e or e e m h n m p e r t o s Y r c n e t e y e g I ne e o y le c s lu M ne e u T S e s ed t s r e E k m T n o e H y e o m d ov t u N o r sl l E C P t r a ico e n r e H A y a A la e e L 8 e r s ee te f L N m e h Y Ie F C g d A t e Dn y t r n c o m N I ta M u o No ic n r a r n I e le is f o u n E N T e a o o lt I s o c m F a i r r o e e o l d L T, O U n e T I C o n T, t e H o P P n n G N t i I T ( n o C a o e o I S C T iv tt f S l it W r o r h R e t m ed o, lo P I s d u L e y n e i f N C C c N r o o a y d m e t n e B e N S N c E r J; J. D U E y n e t C C T o r Ma D O r n r i n c o s s e h n o o a t y L it e e D L C V. A e N n f p s d d A N O ge o O C a a l a t L v a. ic I lo o o E N C E L O tu O C v I e W d ia e O F t w e y lc S e o G e r E = = r E T F m n o ie e I s e p e e d e ih R m o G f f f e G f r I e d u o o o e T C O E o F F M C A P C U L e S S i r f e N r B P l a E y t o n W m o lo w w w la a l L M D t i A 0 E e s t t io t / n n n p f f f o n e v o y r ic ic ic 1 e e t e D S T t e e J i e t L o o o o o d d M I a e n t m y w d m n y t y t t t n a a a E a a K o R A o W o h T T T e U T S C E S S J S O S S S s e it t r t t t t o a y it c p e e tl E H C T L L M C O W S S M M J S 8 m lll ,j )
l,l 33 2 3 1 3 no 0 it 3 a tS 92 re 8 w 2 o 7 P 2 ra 62 e lc 5 u 2 N 4 e 2 n 3 o 2 ts l 22 M liM 1 n r 2 ) s o s! 0 A 2 C w R it h 9 A c M t 1 r u a o P 8 i d M p r 1 n d v o 7 e i r E 1 t h s c n e 6 s o e g o it 1 r s n n a 5 u tr i I( 1 c s r r 7 o n 4 / o 9 1 d m x 9 n 3 a e d 1 E 1 d d r e e o f 6 2 s t f s a 1 r e r d o t e e s s l 1 s n u a b a 1 o o d t mh ) e t l 0 s c ( e c u O A D s 1 c C t t f 9 R o o e o A N N R k 8 e = y e k 7 = = n W la r: A N B d 6 m na m 5 M )y u a 4 M S w h 3 M M ta P 2 2 M e d e m M e 1 l u ss b lP as a ( s T 7 els 9 sA 9 AC CR 1 RA Ar d o e 1 i s r y or s 2 lo tt p t Y s e y e cd s e o r s T it s 1 i h o ne a u T ac l v c ev g N l S i el l n co e u E o U o ns e F A L e s o ee 9 e h r r Dn y A e e l su o c es c S t r o o S m N n a o h y h o No ic t S o u n o l e C h e E n O C e c s o ( t n r c l T s T n s E l u a S a h I I t S e c t in S c c ed h t S s C it e e F it n n n e r i I o e e Ma D e m m c e a h h O p y n a e n e e e ig e m d c D R I C S e e h h n l D N m R O e o r c n C d d o E M T H N A n U E R C m in i C m m m E = = n J a W W m h h h E a a a G E i. m m m h T d d l L M D T m R a e a d h h e h u h n r r o n n a t t t A O d e d i o o s i i h ia b U W in i W N N E C W W W D w P i W W n n P e J S D t lll lll l l!lI
B. Status of Jurisdictions Evaluated This subsection provides information on the evaluation of each participating jurisdiction and functional entity, in a jurisdiction based, issues only format. Presented below is a definition of the terms used in this subsection relative to objective demonstration status, Met - Listing of the demonstrated exercise objectives under which no e Deficiencies or ARCAs were assessed during this exercise and under which no ARCAs assessed during prior exercises remain unresolved. Deficiency - Listing of the demonstrated exercise objectives under which one or mom Deficiencies was assessed during this exercise. Included is a description of each Deficiency and recommended conective actions. Area Requiring Corrective Actions - Listing of the demonstrated exercise objectives under which one or more ARCAs were assessed during the cunent exercise or ARCAs assessed during prior exercises remain unresolved. Included is a description of the ARCAs assessed during this exercise and the recommended corrective action to be demonstrated before or during the next biennial exercise. Not Demonstrated - Listing of the exercise objectives which were not demonstrated as scheduled during this exercise and the reason they were not demonstrated. Prior ARCAs - Resolved - Descriptions of ARCAs assessed during previous exercises which were resolved in this exercise and the corrective actions demonstrated. Prior ARCAs Unresolved - Descriptions of ARCAs assessed during prior exercises which were not resolved in this exercise. Included is the reason the ARCA remains unresolved and recommended corrective actions to be demonstrated before or during the next biennial exercise. The following are definitions of the two types of exercise issues which are discussed in this report. A Deficiency is defined in FEMA REP-I4 as "...an observed or identified inadequacy of organizational performance in an exercise that could cause a finding that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a nuclear power plant." 18 -W Sk<
An ARCA is defined in FEMA-REP-14 as "...an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety." FEMA has developed a standardized system for numbering exercise issues (Deficiencies and ARCAs). This system is used to achieve consistency in numbering exercise issues among FEMA Regions and site-specific exercise repons within each Region. It is also used to expedite tracking of exercise issues on a nationwide basis. The identifying number for Deficiencies and ARCAs includes the following elements, with each element separated by a hyphen (-). Plant Site Identifier - A two-digit number corresponding to the Utility Billable Plant Site Codes. Exercise Year - The last two digits of the year the exercise was conducted. Objective Number - A two-digit number corresponding to the objective numbers in FEMA-REP-14. Issue Classification Identifier -(D = Deficiency, A = ARCA). Only Deficiencies and ARCAs are included in exercise reports. Exercise Issue Identification Number - A separate two (or three) digit indexing number assigned to each issue identified in the exercise. o 19 ..... :.<, ~. a s.. x-...~...+ u ~ w. +
l l 1. STATE OF CONNECTICUT 1.1 State Emergency Operations Center The Connecticut Office of Emergency Management (CT-OEM) has a modern up-to-date Emergency Operations Center. The various supporting agencies and EOC staff structure are efficiently and effectively organized to support the development of recommendations and decisions necessary for execution and timely emergency management. The Director is a strong and knowledgeable u,dividual. There is no question of who is in charge of the Emergency Management Operations. His staff works extremely well in communicating and coordinating their responsibilities, which results in a well run efficient emergency management organization. During the Ingestion Pathway exercise the Director of the Connecticut of Emergency Management displayed excellent leadership and control of the Emergency Management functions. Personnel from Emergency Management, Environmental Protection, Public Health, Consumer Protection, Agriculture, State Police, and National Guard all displayed professionalism and knowledge in their specific functions. All excelled in being able to communicate and coordinate with one another and to make recommendations to support the emergency operations. Through their supporting recommendations the Director, CT-OEM, and the Govemor were able to make appropriate and timely decisions. During the evening of the second day of the Ingestion Pathway exercise, the Director ^ CT-OEM conducted a training table top exercise for the following participating Federal, State, and Local Agencies: FEDERAL STATE LOCAL COMMUNITIES USDA (facilitator) CT-OEM East Lyme FEMA CT-DEP New London CT-Public Health Town of Groton CT-Dept. Agriculture Waterford CT-Consumer Protection Montville CT-State Police Old Lyme CT-Military Groton - City Lyme This tabletop provided a mechanism for the local communities to become familiar with and understand the intricacies of emergency management activities at the State level. Other State agencies also received a better understanding of what local communities have to experience when executing the protective actions instructions. a. MET: Objectives 1,2,3,4,10,13,15,17,23,26,27,28, and 29 b. DEFICIENCY: None 20 i _m, -w
g ie. c. AREAS REQUIRING CORRECTIVE ACTION: None i d. NOT DEMONSTRATED: None e. PRIOR ARCAs-RESOLVED: Issue No.: 38-95-03-A-01
== Description:== Farmers within the EPZ were not notified to place animals in shelter and use stored feed and covered water because when the initial precautionary action was discussed the Agriculture Representative was not present and no one updated him when he arrived. This delay resulted in the precautionary sheltering of animals and placing them on stored feed and water to follow the order to evacuate zones 1 & 2 and shelter zone 3. (Objective 3) (NUREG-0654, A.I.d, A.2.a, J.11) Corrective Action Demonstrated: Issue corrected at 8/14/96 Haddam Neck exercise. Issue No.: 38-95-10-A-05
== Description:== EBS message #2 included New London in the areas to be evacuated, while simultaneously instructing New London to shelter. (Objective 10) (NUREG-0654, E.5, E.6, E.7) Corrective Action Demonstrated: Issue corrected at 8/14/96 Haddam Neck exercise. Issue No.: 38-95-13-A-06
== Description:== The Extent of Play (EOP) called for six calls per hour per operator after the Govemor's State of Emergency declaration. Only five calls per hour were received at the Rumor Control desk during the three hours following the Govemor's State of Emergency.(Objective 13) (NUREG-0654, G.4.c, N.I.a) Corrective Action Demonstrated: Issue corrected at 8/14/16 Haddam Neck exercise. l Issue No.: 91-25
== Description:== A book of comprehensive prescripted EBS messages, which was used during the 1991 exercise, was not included in, nor referenced in the State plan. Also, the messages contained in the book did not include instructions for transients, schoolchildren, ad hoc respiratory protective measures, and ingestion
- hazards, 21
l 1 At the 1995 exercise it was observed that the prescripted EBS message book has been included in the State's RERP. There are no instructions for ad hoc respiratory precautions and there is no longer a specific requirement to do so. That i portion of ARCA 91-25 is corrected. EBS messages did contain instructions for school children but do not specifically mention transients, therefore this portion of ARCA 91-25 remains open. (Objective 11) (NUREG-0654, E.5, E.7, J.10.c) Corrective Action Demonstrated: Issue corrected at 8/14/96 Haddam Neck exercise. Issue No.: 87-30
== Description:== More time in the scenario was needed to exercise recovery and reentry by all State operation centers. (Objective 28) (NUREG-0654, M.1, N.I.a) Corrective Action Demonstrated: During the 1997 Irgestion Pathway exercise, sufficient time was provided in the scenario and extent-of-play to demonstrate recovery and reentry. The entire second day of the exercise (October 9,1997) at the State EOC was devoted to return and reentry decision making and implementation. This was initiated by Controller Message SEOC-8 which was inserted at 0950 at the State EOC. All key State EOC staff were intimately involved in the decision making and implementation. f. PRIOR ARCAs - UNRESOLVED: Issue No.: 38 95-05-A-02
== Description:== Prior to use, all ::urvey instruments were battery checked and tested with a check source for operability. The procedure and instructions, attached to the instrument, indicate that the survey instruments should respond to the check [ source with a meter movement of one half way up the scale on the times 10 range setting. Not all of the instruments met the source check requirements of the procedure, but they were declared operational and put into use anyway. (Objective
- 5) (NUREG-0654, H.10, I.7, I.8)
Reason ARCA Unresolved: The range of readings was,not found to be posted on survey instruments observed at local EOCs, and field teams during the 8/21/97 Millstone exercise. This was also observed at reception center vehicle monitoring at the 1995 exercise, but was not scheduled for demonstration in 1997. Recommendation: Emphasize instrument operability checks during the annual refresher training. In accordance with the FEMA guidance, a range of readings for the check source should be established at the time the instruments are calibrated and this check source response range should be posted on the instrument. This 22
will provide lower and upper response boundaries that the instrument must meet in order to be considered operational. Schedule of Corrective Actions: Demonstrate at the next scheduled exercise. Issue No.: 38-95-05-A-03
== Description:== Bus drivers were not issued dosimetry. (Objective 5) (NUREG-0654, K.3.a) Reason ARCA Unresolved: Not scheduled for demonstration in 1997 exercise. Recommendation: Bus drivers are considered emergency workers (NUREG-0654), and therefore, should be issued dosimetry. Schedule of Corrective Actions: Demonstrate at a future exercise. Issue No.: 38-95-16-A-07
== Description:== Information available to the SEOC regarding precautionary actions for schools, as implemented by local govemments, was uncertain, and actions were not taken to clarify their status with Area IV or the EOCs of EPZ communities. Detailed information regarding the implementation of precautionary actions for schools was incomplete. (Objective 16) (NUREG-0654, J.9, J.10.d, J.10.g) Reason ARCA Unresolved: The SEOC received a message informing of early dismissal of schools for the City and Town of Groton. Neither the State Director nor PIO staff were informed of this action. The media center at the SEOC did not issue a news release addressing precautionary actions for the schools. Recommendation: Assign responsibility for addressing the status of precautionary actions for schools to a spokesperson for the State, and ensure that such information is proactively given verbally to the media during briefings. Develop a prescripted press release specifically to address precautionary actions regarding schools and ensure that prescripted information addresses sheltering as well as evacuation of schools. l Schedule of Corrective Actions: Demonstrate at the next scheduled exercise. l l l 1.2 Department of Environmental Protection (DEP) l l During the Plume Phase, the DEP staffin the State EOC demonstrated effective and timely PAR development and made significant contributions to the development process. 23
The DEP staff was thoroughly knowledgeable of the plan and procedures, very pro-active and interfaced well with all appropriate State agencies during the PA development process. The demonstrated actions of the DEP staff were highly instmmental in the prompt execution of the PAD development. The DEP Accident Assessment Team maintained excellent communications with the Accident Assessment Groups at the Facility such that plant conditions were accurately and quickly determined for use in DEP dose projections and protective action recommendations. State Field team operations were competently directed from the DEP/EOC area resulting in prompt / accurate location of the plume ahd confirmation of dose estimates. During the Ingestion Phase, the DEP and Nonheast Utilities (NU) assessment team developed an effective sampling plan for the collection of environmental samples and field measurement data needed to evaluate the ingestion pathway and relocation criteria. The assessment team involved other state agencies in the development of a sampling plan to identify the types and locations of commercial crops or farms. Both ingestion and relocation dose projections were completed in a timely manner. Clearly understandable maps were prepared which identified the areas of concem for the ingestion pathway as well as relocation and return areas. a. MET: Objectives 5,9,14,26 and 28 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: Objective 7 Issue No.: 38-97 07-A-01
== Description:== The bases for Protective Actions are that the radiation dose avoided is in correct relation to the risks and costs of the action. The total effective dose equivalent (TEDE) is a measure of the potential risk that may be avoided by the protective action while the Protective Action Guide (PAG)is radiation dose that represents a balance as to the risks and costs of the protective action. When the TEDE is greater than the PAG, a Protective Action is indicated. The DEP did not estimate a projected dose based on a pr6jected time of release when source term information was first made available at approximately 1317 hours (see Millstone Unit I ADAM Data Sheet, Time step 8/15; 1315). Previously they made protective action recommendations based on plant conditions only, with funher considerations based on field team, dose rate information. While this DEP procedure is an acceptable, timely and conservative protection of public health, accident assessment is not complete without also making timely 24
dose projections to assure that the recommended protective actions are adequate and to give a full picture of accident conditions. (Objective 7) (NUREG-0654, I.10). Recommendation: DEP procedures should be revised to include preparing timely l estimates of the projected dose as pan of a complete accident assessment.The l State plan should contain a default projected time of release for use when the Utility does not provide a definitive value. ~ Schedule of Corrective Actions: Demonstrate at t'ie next scheduled exercise. Issue No.: 38-97-07-A-02
== Description:== The current ADAM dose projection code (ver 1.2) does not directly estimate the total effective dose equivalent (TEDE) as required by the State Plan (RERP-9.0, Rev.1,2 of 14). Rather it gives the deep dose equivalent (DDE). This means that it does not include adequate consideration of the radiation dose due to inhalation of radionuclides and for radiation dose due to radio nuclides on the ground. In addition, the code does not directly and easily estimate a projected dose due to a source term that could continue for extended periods. (Objective 7) (NUREG-0654,1.10) Recommendation: The ADAM code should be upgraded or replaced. The new code should provide estimates of the projected dose (TEDE) and the committed thyroid dose equivalent (CDE). Both values are needed for comparison with PAGs to evaluate need for Protective Actions. S;heduk of Corrective Actions: Demonstrate at the next scheduled exercise. d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None l f. PRIOR ARCAs - UNRESOLVED: None 1.3 Emergency Operations Facility (EOF) The Depanment of Environmental Protection Monitoring and Radiation Division (DEPMRD) Liaison personnel kept the State EOC Depanment of Environmental Protection Monitoring and Radiation Division desk informed of critical changes in plant status as they were reponed to the utility's Director of Site Emergency Operations by the utility Technical Suppon Center on an open speaker-phone line. These changes were reponed to the State EOC within 30 seconds of receipt, thus ensuring that the State EOC DEPMRD desk had the latest plant status information at all times. 25 ~,n . y m:, p.a Q.m.~ w.wqn,.x , w g,;, p p. w w. m, ,...,,,.v
a. MET: Objectives 1,2,4, and 7 I b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None I.4 State Field Monitoring Teams I.4.I Field Monitoring Team "A" DEP Field Monitoring Team Alpha showed considerable knowledge of plume dispersion and of emergency worker exposure control. They discussed sky shine, ground shine, the effect of an elevated release, plume width and centerlines, and post plume deposition. They also discussed that the low-level DRD readings correctly provided by the controller could not be read on the 0-5R range DRDs. a. MET: Objectives 4,5,6,8, and 14 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None c. PRIOR ARCAs-RESOLVED: Issue No.: 38-95-08-A-08
== Description:== The technician did not operate the air sampler for 10-15 seconds to purge noble gases from the radioiodine cartridge before counting the cartridge in accordance with Emergency Plan Section 3.4.3.g.6. He also did not use the planchet when counting the particulate filter and improperly placed the filter below the metal spacer instead of above it. (Objective 8) (NUREG-0654. I.7, I.8, I.9). Corrective Action Demonstrated: The RMD member of FMT Alpha operated the air sampler for 15 seconds in a low background area to purge the radiciodine 26 i
cartridge of noble gases. The team member also used an Eberline SH-4 sample holder with a planchet when counting the particulate filter. Issue No.: 29-96-06-A-02 (Haddam Neck)
== Description:== Field Monitoring Team A (FMTA) did not receive a mission briefing either before or during deployment. The team was not briefed on information regarding exposure control, measurement procedures, meteorological conditions, or reponing procedures. (Objective 6) (NUREG-0654, I.7, I.8, I.11) 3 Corrective Action Demonstrated: Before deployment the RMD team leader did - a briefing on exposure control procedures, survey procedures to be followed, the starting point for radiation measurements, procedures for iodine sampling, and communication of radiological data. The FMT coordinator provided additional information by cellular telephone and mobile radio including plant and meteorological conditions, locations for monitoring assignments, and other pertinent data. The FMT Coordinator continued to provide information throughout the mission. Issue No.: 29-96-06-A-03 (Haddam Neck)
== Description:== The Field Team Coordinator failed to utilize the assets of FMTA. He ordered the team to remain at its initial location and to call in when the team's monitors detected the plume. The plume never passed over this location and as a result the team never made a measurement nor took an air sample during the exercise. (Objective 6) (NUREG-0654, I.7, I.8, I.11) Corrective Action Demonstrated: The FMT Coordinator used reported measurements and other information to make effective FMT Alpha monitoring location assignments. Issue No.: 29-96-06-A-04 (Haddam Neck)
== Description:== The monitoring equipment issued by the State did not bear labeling which gave either an expected reading from a check source, calibration curves, or l correction factors. (Objective 6) (NUREG-0654, H.10, I.7, I,8, I.11) F Corrective Action Demonstrated: Expected readings for instruments were posted on the check source holder. 1 Issue No.: 29-96-08-A-05 (Haddam Neck)
== Description:== FMTA failed to purge their air sample of noble gases prior to counting the silver zeolite canridge. (Objective 8) (NUREG-0654, H.10 I.7, I.8, I.11) 27 I \\
Corrective Action Demonstrated: The RMD member of Team Alpha purged the air sample of noble gases prior to counting the silver zeolite canridge. f. PRIOR ARCAs - UNRESOLVED: None I.4.2 Field Monitoring Team "B" Field Team B worked very effectively ar, a team. All assignments were carried out promptly and sample results were reponed to the Field Team Coordinator on a timely basis. Plans and procedures were carefully followed. a. MET: Objectives 4,5,6,8, and 14 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: Issue No.: 38-95-08-A-08
== Description:== The technician did not operate the air sampler for 10-15 seconds to purge noble gases from the radioiodine cartridge before counting the cartridge in accordance with Emergency Plan Section 3.4.3.g.6. He also did not use the planchet when counting the paniculate filter and improperly placed the filter below the metal spacer instead of above it. (Objective 8) (NUREG-0654, I.7, I.8, I.9) Corrective Action Demonstrated: Field Team B purged the noble gases from the radioiodine cartridge before counting the canridge. They also used the SH4 sample holder and the planchet when counting the paniculate filter. Issue No.: 29-96-06-A-03 (Haddam Neck)
== Description:== The Field Team Coordinator failed to utilize the assets of FMTA. He ordered the team to remain at its initial location and to call in when the team's monitors detected the plume. The plume never passed over this location and as a result the team never made a measurement nor took an air sample during the exercise. (Objective 6)(NUREG-0654 I.7,I.8,I.11) Corrective Action Demonstrated: Effective use of all teams to locate and determine the plume size was noted during the 1997 Millstone Exercise. 28 i .I
Issue No.: 29-96-06-A-04 (Haddam Neck)
== Description:== The monitoring equipment issued by the State did not bear labeling which gave either an expected reading from a check source, calibration curves, or correction factors. (Objective 6) (NUREG-0654, H.10,1.7, I.8, I.11) 1 Corrective Action Demonstrated: Check sources were labeled with expected readings for all instmments utilized during the 1997 Millstone Exercise. Issue No.: 29-%-08-A-05 (Haddam Neck)
== Description:== FMTA failed to purge their air sample of noble gases prior to counting the silver zeolite cartridge. (Objective 8) (NUREG-0654, H.10,1.7, I.8, I.11) Corrective Action Demonstrated: Field Team B purged the noble gases from the radioiodine cartridge before counting the cartridge. f. PRIOR ARCAs - UNRESOLVED: None 1.5 State Field Sampling Teams (Ingestion Pathway) During the Ingestion Pathway exercise field sampling teams were mobilized from the four Connecticut State agencies indicated below: Department ofPublic Health The Department of Public Health Water Services Division sampling team demonstrated excellent sample taking and contamination control techniques. Department ofAgriculture The initiative of the Department Agriculture sample collectors to avoid cross contamination was excellent. For example, written procedures were placed on the dashboard of the vehicle. After each step of the sampling procedure, the team member would look through the windshield to be assured all procedures were followed and avoided cross contamination by not handling the procedures themselves. l Consumer Protection Division During the process of collecting the assigned samples, the Consumer Protection sampling team had communication problems with their radio and mobile cellular phone. They overcame this difficulty by using a pay phone to contact the command center and by relaying information through the Agricultural sampling team. 29
Department ofEnvironmental Protection The Depanment of Environmental Protection Field Team demonstrated knowledge of instrument use and procedures. Their performance in the field was very professional and efficient. a. MET: Objectives 4 and 5 b. DEFICIENCY: None i c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs-UNRESOLVED: None 1.6 Joint Media Center The Joint Media Center is a modern technically well-equipped facility located in the State Emergency Operations Center. During the Plume Pathway exercise the Joint Media Center was established in a timely manner after the 9:45 a.m. Alert (ECL) of an incident at Millstone NPS. There was joint cooperation between the Governor's press office, Connecticut Office of Emergency Management, State Police, Department of Public t Health, Department of Environmental Protection and Northeast Utilities. The Connecticut OEM provided an effective presentation to the media at the first press briefing on the . State's compensatory plan for the City of New London. The State of Connecticut Office of Emergency Management demonstrated the implementation of an effective system of disseminating emergency information and instructions to the public in an accurate, comprehensive, and timely manner. A comprehensive list of emergency information topics was addressed through a combination of EAS messages, news releases and media briefings. The process was funher enhanced by references to the Emergency Instructions section of the telephone book yellow pages and the availability of brochures and pamphlets. The State should be commended for the most thorough and comprehensive demonstration of public information activities in an Ingestion Pathway Exercise to date in FEMA Region I. Eight news releases, five press conferences and numerous background media briefings were utilized to convey accurate, timely and comprehensive information to the public. The media briefings included effective presentations by a wide variety of state spokespersons including the Governor's Press Secretary and representatives from the Office of Emergency Management, Depanment of Environmental Protection, Department of Public Health, Depanment of Agriculture and the State Police. The Govemor's Press
- 0
Secretary and the Director of Emergency Management should be especially commended for their effective and consistent leadership in advancing the crucial role of public information in the exercise. a. MET: None b. DEFICIENCY: None AREAS REQUIRING CORRECTIVE ACTION: Objectives 11,12, and 27 c. Issue No.: 38-97-11-A-03 I
== Description:== EAS message #1 (MP-0) stated that "the Govemor has not j recommended any actions by the public" when, in fact, he had ordered the closure of state parks and placing farm animals on stored feed. Moreover, a related news release (#3) added advisory topics, including harvested crops, milk supplies and water cisterns, which had not been included in the Governor's precautionary measures. (Objective 11) (NUREG-0654, E.5,' E.7, J.9, J.11) Recommendation: Steps should be taken to ensure that the content of EAS messages and news releases accurately reflect the decisions of the Govemor or his designee. Schedule of Corrective Actions: Demonstrate at the next scheduled exercise. Issue No.: 38-97-12-A-04
== Description:== The issue of what to leave behind when evacuatmg was not mentioned in media briefings, news releases or printed materials for the public. In briefings the term precautionary action was used, while visual aids used the term protective actions. News release #5 includes inaccurate information, stating that j the Govemor upgraded the situation. During the 1330 news briefing the Millstone NPS presenter did not have visual aids present it was apparent that spokespersons had not coordinated their information prior to the news briefings. (Objective 12) (NUREG-0654, E.7, G.3.a. G.4.a, G.4.b, G.4.c) Recommendation: Clarify the use of terminology, specifically the terms i " precautionary action" versus " protective action". Provide a visual status board with current information about the incident in progress. Have graphic displays readily available or pre-set for presenters. Hold pre-briefings before the actual media briefing to ensure consistency of message by participating organizations and to anticipate media questions. Schedule of Corrective Actions: Demonstrate at the next scheduled exercise. 31
Issue No.: 38-97-27-A-05
== Description:== The brochure containing agriculturalinformation was deemed inappropriate for distribution by state officials and yet was not withdrawn from the Media Center. (Objective 27) (NUREG-0654, J.11) Recommendation: Steps should be taken to ensure that only accurate and appropriate informational materials are available for distribution to the public. Schedule of Corrective Actions: Demonstrate at a future exercise. d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: Issue No.: 38-95-11-A-09
== Description:== The EBS messages did not contain specific instructions for transients, special populations or transportation dependent individuals. (Objective
- 11) (NUREG-0654, E.7, J.10.c, J.10.d)
Corrective Action Demonstrated: Under the provisions of the EAS system, emergency instructions and information may be provided through a combination of EAS messages, news releases and media briefings. Instructions for transients, special populations, and transportation dependent individuals were provided in EAS messages, news releases and media briefings. Issue No.: 38-95-12-A-10
== Description:== In response to a news media questian during a briefing, a State spokesman inaccurately stated the time of the Governor's State of Emergency. (Objective 12) (NUREG-%54, G.3.a. G.4.a, G.4.b) Corrective Action Demonstrated: State spokesperson responses to news media were accurate in media briefings. Issue No.: 38-95-12-A-11
== Description:== There were no comprehensive media briefings on emergency protective measures. (Objective 12) (NUREG-0654, G.3.a G.4.a, G.4.b) Corrective Action Demonstrated: Issue corrected at 8/14/96 Haddam Neck exercise. -r Issue No.: 38-93-12-A-12 32
== Description:== Media briefings, news releases, and the telephone book yellow-page inserts did not provide instmetions for transients without shelter or information transportation-dependent individuals. (Objective 12) (NUREG-0654, G.2, J.10.c, J.10.d) Corrective Action Demonstrated: This issue has been administratively corrected. f. PRIOR ARCAs-UNRESOLVED: None i 1.7 State Department of Health (DHS) Laboratory The use of piotective clothing and the transfer of sample custody was well presented. The briefing on use of dosimetry and KI,its distribution and collection, the explanation of the dosimeters and KI use, and briefings on the associated forms showed good familiarity with the equipment and its purpose. Laboratory operations, including sample storage, prevention of sample spoilage, access control, and staff familiarity with counting equipment and associated procedures provided evidence of excellent preparation for i emergency response. a. MET: None b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: Objective 25 Issue No.: 38-97-25-A-06
== Description:== Procedures used for monitoring for contamination on persons were not adequate to detect levels of contamination in excess of FEMA guidance. The distance from the probe to the surface of about four to six inches was too great, the path width of about six inches was too wide and the probe speed of about two feet /second was too fast for the instrument / detector (CD-V 700) being used. Plans for the radiation laboratory operations do not include monitoring procedures for portable instruments, but procedures are included in Attachment 11 to Section CTAP-4.3 of the State Plan. This document includes specifications for probe distance of one-halfinch and probe speed of six inches per second. (Objective 25) (NUREG-0654, C.3, J.11) Recommendation: The plan for operation of the radiation laboratory should be modified either to be specific about radioactive contamination monitoring procedures for persons, samples, and equipment, or to reference other parts of the plan where these procedures are provided. Laboratory staff responsible for radioactive contamination monitoring should receive training on this topic. 33
~~ Schedule of Corrective Actions: Demonstrate at a future exercise. Issue No.: 38-97-25-A-07
== Description:== Contamination control for surfaces was not apparent for the exercise. However, the spread of contamination to the Chemistry and Industrial Hygiene Laboratory and the Radiation Laboratory could seriously delay the determinatioa of appropriate protective actions. No temporary coverings were provided for the floor at the reception area, tne hot sample storage area, or the wheel-carts at the reception area. No provisions were made to add another plastic bag to " hot" samples or to smear them to determine whether the measured radiation might be coming from contamination on the exterior surfaces. (Objective 25) (NUREG-0654, C.3, J.11) Recommendation: The State Plan should be revised to include contamination control procedures for laboratory operations as discussed in FEMA REP-14, 3 j Section D.25-2. However they are not discussed in the State Plan forlaboratory { operations. Schedule of Corrective Actions: Demonstrate at a future exercise. j d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None ) 1.8 OEM Area IV, Colchester The Office of Emergency Management (OEM) Area IV - Colchester staff were very proactive in maintaining good communications links with all agencies. At one point ) during the exercise when the high band operator was unable to contact Groton Town, the Area IV Coordinator established and inaintained a telephone link with this location for i over one hour. Also, the high band operator performed routine communications checks to all agencies to confirm that the system continued to operate properly. Further, when transmitting messages to local EOCs, the high band operator spoke clearly and slowly so that the receiving operators had sufficient time to copy the messages. a. MET: Objectives 1,2,3,4, and 10 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None 34 i 1
1 l 1 d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: Issue No.: 38-95-03-A-12
== Description:== The Area IV staff wcs not always responsive to the EPZ communities' requests for information. At 1012 hours, New London EOC requested radiation release measurements at the perimeter of Millstone, explaining that these readings were necessary to verify local readings. Area IV advised that the only way New London EOC could obtain the readings was for them to send a person to the State Media Center in Hartford and obtain readings when they are provided to the general public. Also, at 1020 hours, Ledyard EOC requested State media and news releases for information purposes. Area IV acknowledged the radio request, but did not send back any media releases. (Objective 3) (NUREG-0654, A.I.d, A.2.a) Corrective Action Demonstrated: The Area IV staff members receiving requests from EPZ communities were very responsive to requests for services and information. At 1116 hours, the Town of Groton wanted to know what the compensatory plan was and where they could get a copy. Not only were their questions about the plan answered, but a copy of the plan was faxed to them to use/or review in the interim. At 1307 hours, the Town of Ledyard requested an additional 50 dosimeters for shift change. Their request was handled courteously and professionally, forwarding the information to the proper sources. Numerous other requests for information and services flowed through Area IV, all being handled without incident in a courteous manner. f. PRIOR ARCAs - UNRESOLVED: None 1.9 State Police Access Control Pointsffraffic Control Points The State Police and Depanment of Transponation staff had ample resources and knowledge of the mission. a. MET: Otijectives 5 and 17 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None 35 m .....,. ~
f. PRIOR ARCAs - UNRESOLVED: None 1.10 State Compensatory Plan The ability of the State Police Supervisor and Communication Officer to implement the compensatory plan was demonstrated with professionalism and confidence. Although the State Police Mobile Command Post has been used for many other activities, this was the first time it was used for this type situation. A very professionaljob, well done. Both the Shift Supervisor and Communications Officer from the Montville State Police Barracks (Troop E) were very knowledgeable on emergency procedures for all hazards. Although } this was the first demonstration of the Comp ensatory Plan, the Shift Supervisor and i Communications Officer followed their eme rgency plans and procedures with enthusiasm, understanding and a willingness to leam. The Shift Supervisor observed ways that the plan could be demonstrated more smoothly, but also took into consideration that in a real event, more personnel would be made available to handle each task. They l l coordinated with the Department of Transportation for resources and worked extremely l well with one another. ) a. MET: Objectives 3,4,15,16,17 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: Objective 5 Issue No.: 38-97-05-A-08
== Description:== There was no precautionary briefing prepared for any female troopers that may have assisted with emergency worker duties. (Objective 5) (NUREG-0654, K.3.b, K.4) Recommendation: A briefing for women emergency workers must be given to wam of the radiological issues of someone who is pregnant or thinks she might be. Include in the briefing a signature card for the woman to sign that states she has had the briefing and understands its contents. Schedule of Corrective Actions: Demonstrate at a future exercise. Issue No.: 38-97-05-A-09
== Description:== Electrical leakage check dates were not available for any DRD. (Objective 5) (NUREG-0654, H.10, K.3.a) Recommendation: Provide the dates. 36
Schedule of Corrective kctions: Demonstrate at the e.:xt scheduled exercise d. NOT DEMONSTRATED: None e. PRIOR ARCAs -RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 2. RISK JURISDICTIONS 2.I East Lyme EOC The East Lyme First Selectwoman, Emergency Management Director, and staff members of the Emergency Operating Center were knowledgeable, enthusiastic, and professional in performance of their duties during the August 21,1997, REP Exercise. The cooperative spirit was especially noticeable. Members were helping each other in anticipating problem areas and assisting each other in completion of duties. a. MET: Objective 1,2,3,4,5,10,15,16, and 17 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs-RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 2.2 Hamlet of Fishers Island,NY, EOC The Fisher's Island EOC staff demonstrated outstanding flexibility and team-work. When several members were called out to respond to storm-related actual emergencies those remaining took over the responsibilities as well as executing their own. No operational efficiency was lost. Throughout, the staff worked together, helping one another and operating in a business like manner. a. MET: Objectives 1,2,3,4,5,10,15,16, and 17 b. DEFICIENCY: None n
c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 2.3 City of Groton EOC The Mayor, as the CEO, was an asset to the Emergency Management Director. She provided leadership for other municipal agencies in the EOC. The Mayor and EMD worked well together in the command and control of personnel and decision making. Emergency workers in the EOC showed knowledge of the plans and procedures when actions needed to be implemented. They worked well together and understood the responsibilities of other agencies, allowing for good communication and interaction. a. MET: Objectives 1,2,3,4,5,10,15,16, and 17 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None i f. PRIOR ARCAs - UNRESOLVED: None 2.4 Town of Groton EOC Noteworthy was the full exercise panicipation by the Town Manager who, in concert with the Civil Preparedness Director, did an excellentjob of managing emergency operations. Also, the Communications Officer did an excellent job in maint,aining an accurate message log. a. MET: Objectives 1,2,3,4,5,10,16, and 17 b. DEFICIENCY: None AREAS REQUIRING CORRECTIVE ACTION: Objective 15 c. Issue No.: 38-97-15-A-10 38 e
1 Descripti::n: The EOC's Human Service Groap had a list of 33 special needs persons. On exercise day the group was given a bundle of mail-in cards which may reflect additions and deletions to the EOC special needs list. The Human Services Group representative made an estimate that 55 special needs persons actually live in the Groton Town area. The EOC's special needs list will not be accurate until the cards are analyzed and additions or deletions are made on the EOC list. (Objective 15) (NUREG-0654, J.10.c,d,e) Recommendation: It is recommended that the mail in special needs cards be analyzed and appropriate additions or deletions be made on the EOC's special needs list. Schedule of Corrective Actions: Demonstrate at the next scheduled exercise. d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 2.5 Ledyard EOC The major strength demonstrated by the staff at the ledyard Emergency Operations Center was the true interest in emergency management. The emergency workers present during the exercise were both enthusiastic about the work they were doing and dedicated to the effort. The staff demonstrated flexibility and persistence under pressure when a fire alarm and power outage occurred in the building housing the EOC during the exercise. The fire alarm contained a " canned" message to evacuate the building. Fire personnel in the EOC simply responded to the fire alarm while other personnel obtained an emergency generator and the rest of the emergency workers kept the EOC operational until full power was restored. During the exercise, the Ledyard Emergency Management Director (EMD) demonstrated superb direction and control of the EOC operations. The EMD kept the EOC staff apprised of changes in the status of the emergency and coordinated all efforts through the responsible individuals. The emergency workers were able to carry out their responsibilities independently, yet interacted and coordinated with each other without conflicts. a. MET: Objectives 1,2,3,4,5,10,15,16, and 17 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None 39 T. ) l N.@' [1 .)f
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d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 2.6 Lyme EOC Because of the Civil Defense Director's leadership, all Lyme Emergency Operations Center staff were proactive. The Civil Defense Director utilizes the EOC for all other emergencies, and therefore he is equipped with multiple communications redundancies. By utilizing the EOC for all emergencies, the staff has become well trained and constantly seeks better ways to solving problems. The Civil Defense Director utilizes self-made weather detection devices to alert the town of any sudden severe weather; and, he has also made an earthquake detection unit capable of measuring any activity along the fault running through Lyme. These activities exemplify how r.erious emergency management is taken by the Civil Defense Director and consequently his enthusiasm spills over to his staff. During the exercise the EMS Officer was extremely proactive in making sure the Special Needs population was safe by lining up possible needed transportation. Outstanding job perfonned by the Lyme EOC staff. a. MET: Objectiver, 1,2,3,4,5,10,15, and 17 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONST. RATED: None e. PRIOR ARCAs RESOLVED: None f. PRIOR ARCAs UNRESOLVED:None ) 2.7 Montville EOC EOC staff demonstrated a thorough knowledge of the emergency plan and procedures. They also demonstrated a high degree of professionalism and conscientiousness. a. MET: Objectives 1,2,3,4,5,10,15,16, and 17 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None i 40 i )
d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 2.8 City of New London EOC The City of New London did not participate in the August 1997 exercise. Emergency response measures for the City of New London were taken by the State of Connecticut by means ofits compensatory plan. See report Section 1.10. a. MET: None b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: Objectives 1,2,3,4,5,10,15,16, and 17 e. PRIOR ARCAs - RESOLVED: None j f. PRIOR ARCAs - UNRESOLVED: None 2.9 Old Lyme EOC The Old Lyme EOC ran smoothly and without problems due to coordination and cooperation among staff. The Selectman was knowledgeable of State and local operations. The EMD was well-versed in plant operation and radiological monitoring. All EOC staff members were trained in their emergency responsibilities. a. MET: Objectives 1,2,3,4,5,10,15,16, and 17 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 41
2.10 Waterford EOC The professionalism and dedication of the Waterford EOC staff and their ability to work together without any conflicts or problems was demonstrated. The staff took their responsibilities seriously and acted as though this exercise was a real emergency. This EOC staffis to be commended for a job well done. a. MET: Objectives 1,2,3,4,5,10,14,15,16, and 17 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: Issue No.: 38-93-05-A-09
== Description:== The school bus guide instmeted the bus driver on when to read and record DRD values. However, the bus driver may not be accompanied by the bus guide on every route. (Objective 5) (NUREG-0654, K.3.a K.3.b, K.4) Corrective Action Demonstrated: This issue has been administratively corrected. f. PRIOR ARCAs - UNRESOLVED: None 2.11 School / Bus Evacuation 4 2.11.1 Town of East Lyme The Lillie B. Haynes school staff was familiar with their emergency plans and procedures. The bus driver followed the directions to the Host Reception Center, and was knowledgeable with the surrounding area and roads. The amateur radio operator maintained clear and strong communications with tne emergency operations center for the duration of the trip. The school staff, amateur radio operator and the bus driver were enthusiastic, and worked well as a team. a. MET: Objective 16 b. DEFICIENCY: None 42 r
c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 1 2.11.2 Town of Ledyard The school superintendent, Principal, and school staff of the Gales Ferry Elementary School were knowledgeable of the plan requirements for their school. The bus driver was also knowledgeable and experienced in driving. He was familiar with the required route and the surrounding communities. All personnel displayed enthusiasm in accomplishing the tasks at hand. a. MET: Objective 16 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None ) d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 2.11.3 Town of Old Lyme School officials of the Mile Creek School were familiar with the emergency management plans affecting school children. The bus driver was experienced and knowledgeable regarding his responsibilities. The bus driver was able to continually communicate with the dispatcher, a. MET: Objective 16 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None 43
e. PRIOR ARCAs RESOLVED:None f. PRIOR ARCAs - UNRESOLVED: None 2.12 Special Populations Nursing Homes The nursing home staffs were very knowledgeable of their duties, responsibilities, and evacuation plans. They had an excellent relationship with their local EOC representatives. It was evident that they had maintained open communications throughout the year. Both nursing home and EOC personnel were enthusiastic and cooperative and provided requested additional back-up documentation to support the i information provided on the questionnaires. a. MET: Objective 15 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 2.13 Medical Services 2.13.1 Transportation - Town of Waterford Ambulance Company The ambulance crew consisted of two EMTs. Both members demonstrated a spirit of teamwork and professionalism. The EMT assigned to the patient compartment of the ambulance demonstrated excellent patient care and kept the hospital informed of the patient's condition. Upon arrival at the hospital the patient was transferred, and the EMT gave an excellent briefing to the medical staff receiving the patient. a. MET: Objective 20 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None 44
e. PRIOR ARCAs - RESOLVED: Issue No.: 38-95-20 A-13
== Description:== While demonstrating monitoring techniques the plant Health Physics Technician (HPT) placed his instrument on the floor of the ambulance in an area which was later to be found contaminated, thus contaminating his instrument. In addition, he touched the interior of the ambulance on several occasions with his probe. (Objective 20) (NUREG-0654, L.1, L.3, L.4) Corrective Action Demonstrated: At no time did the Health Physics Technician (HPT) set his instrument down on the floor of the ambulance. He did not permit the probe of the survey meter to touch any portion of the interior of the patient compartment at any time. f. PRIOR ARCAs - UNRESOLVED: None 2.I3.2 Facilities - Lawrence and Memorial Hospital, City of New London The Lawrence and Memorial Hospital Emergency Room Staff and Security Team demonstrated superior knowledge and perfortned with confidence throughout the demonstration period. The best performance to date within this' Emergency Planning Zone. a. MET: Objective 21 b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 3. SUPPORT JURISDICTIONS 3.1 Windham EOC j The Emergency Management Director at the Windham EOC displayed outstanding leadership. The staff were knowledgeable and experienced. Communication between all participating entities occurred in a timely fashion and without delay. 43 5 i
a. MET: Objectives 1,2,3,4 b. DEFICIENCY: None l c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None f. PRIOR ARCAs - UNRESOLVED: None 3.2 Windham Reception Center The Reception Center Manager demonstrated excellent management skills throughout the drill by maintaining control and making quick and appropriate decisions. In the male and female decontamination areas, the teams concerned themselves with attention to detail to ensure proper completion. In the vehicle monitoring area, one individual continued to remind fellow team members about reading personnel dosimeters and proper monitoring techniques. These examples of teamwork enaured a successful completion of an emergency situation. a. MET: Objectives 3,5,18 and 22 i b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs RESOLVED:None f. PRIOR ARCAs - UNRESOLVED: None 3.3 Windham Congregate Care Facilities The American Red Cross (ARC) Representative submitted shelter survey forms to the evaluator. These shelter surveys were filled out appropriately and with detail. The ARC Representative was knowledgeable with Congregate Care Centers, the emergency management process and procedures. a. MET: Objective 19 46
b. DEFICIENCY: None c. AREAS REQUIRING CORRECTIVE ACTION: None d. NOT DEMONSTRATED: None e. PRIOR ARCAs - RESOLVED: None l f. PRIOR ARCAs - UNRESOLVED: None l 1 e 47 l'~
APPENDIX 1 ACRONYMS AND ABBREVIATIONS The following is a list of the acronyms and abbreviations which were used in this report. ACP Access Control Point AMA American Medical Association ANI American Nuclear Insurers ARC American Red Cross ARCA Area Requiring Corrective Action CCC Congregate Care Center CD-V Civil Defense - Victoreen CFR Code of Federal Regulations CPM Counts Per Minute DEP Depanment of Environmental Protection DHHS U.S. Department of Health and Human Services DHS/OEMS Department of Health Services / Office of Emergency Medical Services DOC U.S. Depanment of Commerce DOE U.S. Depanment of Energy DOI U.S. Department of the Interior DOT U.S. Depanment of Transponation DRD Direct Reading Dosimeter EAL Emergency Action Level EAS Emergency Alen System EBS Emergency Broadcast System ECL Emergency Classification level EEM Exercise Evaluation Methodology EOC Emergency Operations Center EOF Emergency Operations Facility EPA U.S. Environmental Protection Agency EPZ Emergency Planning Zone ETA Estimated Time of Arrival ETE Evacuation Time Estimate EWMDS Emergency Worker Monitoring and Decontamination Station FAA Federal Aviation Agency FCC Federal Comrnunications Commission FDA U.S. Food and Drug Administration FEMA Federal Emergency Management Agency 48 (.
FR Federal Register FTC Field Team Coordinator ft/ min feet per minute 3 ft / min cubic feet per minute GE General Emergency GM Guidance Memorandum IP Implementing Procedure JMC Joint Media Center JPIC Joint Public Information Center KI Potassium Iodide mR milliroentgen mR/h milliroentgen per hour NOAA National Oceanic and Atmospheric Administration NOUE Notification of Unusual Event NRC U.S. Nuclear Regulatory Commission NUREG-0654 NUREG-0654/ FEMA-REP-1, Rev.1, "Criteriafor Preparation and Evaluation ofRadiological Emergency Response Plans and Preparedness in Support ofNuclear Power Plants," November 1980 NWS National Weather Service OEM Office of Emergency Management i ORO Offsite Response Organization PAD Protective Action Decision PAG Protective Action Guide PAO Public Affairs Official PAR Protective Action Recommendation PIADC Plum Island Animal Disease Center PIO Public Information Officer POR Point Of Review R Roentgen RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Service RC Reception Center REA Radioactive Emergency Area REM Roentgen Equivalent Man REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan 49 ',. , ( id d I "[ 4%* WN ). ,,j., o
R/h Roentgen (s) per hour RO Radiological Officer SAE Site Area Emergency SEOC State Emergency Operations Center TCP Traffic Control Point TDD Telecommunications Device for the Deaf TL Team Leader TLD Thermoluminescent Dosimeter UHF Ultra High Frequency USCG U.S. Coast Guard USDA U.S. Department of Agriculturt VHF Very High Frequency WP Warning Point e
APPENDIX 2 EXERCISE EVALUATORS AND TEAM LEADERS The following is a list of the personnel who evaluated the Millstone Nuclear Power Station Plume Exposure Pathway exercise on August 21,1997, and the Ingestion Exposure Pathway exercise during the week of October 6,1997. Evaluator Team Leaders are indicated by the letters "(TL)" after their names. The organization which each evaluator represents is indicated by the following abbreviations: FEMA Federal Emergency Management Agency FEMA HQ Federal Emergency Mar.agement Agency Headquarters ANL Argonne National Laboratory DOT U.S. Department of Transportation INEEL Idaho National Engineering and Environmental Laboratory KLT K.L.Travis & Associates,Inc. NRC U.S. Nuclear Regulatory Commission USDA U.S. Department of Agriculture EVALUAT ON SITE EVALUATOR ORGANIZATION Plume Exposure Pathway Exercise - August 21,1997 GENERAL OBSERVATIONS S. Stoffel FEMA D. McElhinney FEMA STATE OF CONNECTICUT State Emergency Operations Center D. Bell FEMA B. Swartz FEMA R. Conley USDA R. Neisius ANL B. Rospenda ANL Depanment of Environmental Protection J. Hardin KLT B. Salmonson INEEL Emergency Operations Facility B. Keene ANL State Field Monitoring Teams J.Cox INEEL G.Jacobson ANL Joint Media Center J. Melton FEMA K. Horak FEMA l l 51 1 1 , ;.;.., g y g.g Q,.y, eg.,.. mpy,.. e a . ;;,. /
1 EVALUATION SITE EVALUATOR ORGANIZATION OEM AreaIV,Colchester W. Anderson FEMA S. Bailey ANL State Police Access Control / Traffic Control Points D. Camey FEMA State Police Troop E-Montville (State Compensatory Plan) R. Poole FEMA State Police Mobile Command Post (State Compensatory Plan) D. Camey FEMA OEM AreaIV,Colchester (State Compensatory Plan) W. Anderson FEMA RISK JURISDICTIONS East Lyme H. Harrison ANL Hamlet of Fishers Island, NY D. Petta DOT City of Groton M. Brazel FEMA Town of Groton E. Hakala ANL Ledyard D. Knowles FEMA Lyme M. Gallagher FEMA Montville D. Piso FEMA City of New London R. Poole FEMA Old Lyme J. East FEMA HQ Waterford A. Lookabeugh ANL 32 asy r mw..x irm:pa - .,~...e, :as. .w ....~:.z. . e. c. .x n. ..e...- iu;;.; a,
EVALUATION SITE EVALUATOR ORGANIZATION Ingestion Exposure Pathway Exercise - Week of October 6,1997 GENERAL OBSERVATIONS S. Stoffel FEMA STATE OF CONNECTICUT i State Emergency Operations Center B. Swartz FEMA D. Bell FEMA D. McElhinney FEMA R. Rospenda ANL Department of Environmental Protection B. Salmonson INEEL S. Bailey ANL State Field Monitoring / Sampling Teams R. Conley USDA R ~. Imher NRC J. Cox INEEL R.Poole FEMA Joint Media Center K. Horak FEMA D.Piso FEMA State Department of Health Laboratory J.Logsdon KLT State Police Access Control / J. Gibbons FEMA Traffic Control Points RISK JURISDICTIONS East Lyme School Evacuation D. Carney FEMA Ledyard School Evacuation J. Gibbons FEMA Old Lyme School Evacuation J. Gibbons
- FEMA Special Populations - Nursing Homes R. Poole F.MA r
W. Anderson FEMA Medical Services MS-1 Drill Waterford Ambulance Company W. Anderson FEMA Lawrence and Memorial Hospital R. Poole FEMA 53
EVALUATION SITE EVALUATOR ORGANIZATION SUPPORT JURISDICTIONS Windham EOC D.Piso FEMA Windham Reception Center and EWMDS R. Poole FEMA D. McElhinney FEMA W. Anderson FEMA D.Piso FEMA J.Cox INEEL B. Salmonson INEEL Windham Congregate Care Facilities D. Carney FEMA Special State / Local Activity State /LocalIngestion Pathway Table Top Discussion D. McElhinney FEMA R. Swartz FEMA D. Bell FEMA K. Horak FEMA D.Piso FEMA R. Conley USDA R. Rospenda ANL S. Bailey ANL W $4 l
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APPENDIX 3 EXERCISE OBJECTIVES AND EXTENT-OF-PLAY AGREEMENT This appendix lists the exercise objectives which were scheduled for demonstration in the Millstone Nuclear Power Station Plume Exposure Pathway exercise on August 21,1997, and the Ingestion Exposure Pathway exercise during the week of October 6,1997, and the extent-of-play agreement approved by FEMA Region I on July 31,1997. The exercise objectives, contained in FEMA-REP-14, " Radiological Emergency Preparedness Exercise Manual," September 1991, represent a functional translation of the planning standards and evaluation criteria of NUREG-0654/ FEMA-REP-1, Rev.1, " Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Suppon of Nuclear { Power Plants," November 1980. q Because the exercise objectives are intended for use at all nuclear power plant sites, and because of variations among offsite plans and procedures, an extent-of-play agreement is prepared by the State and approved by FEMA to provide evaluators with guidance on expected actual demonstration of the objectives. A. Exercise Objectives Listed below are the specific radiological emergency preparedness objectives scheduled for demonstration during this exercise. OBJECTIVE I: MOBILIZATION OF EMERGENCY PERSONNEL Demonstrate the capability to alert and fully mobilize personnel for both emergency facilities and field operations. Demonstrate the capability to activate and staff emergency facilities for emergency operations. OBJECTIVE 2: FACILITIES - EQUIPMENT, DISPLAYS, AND WORK ENVIRONMENT Demonstrate the adequacy of facilities, equipment, displays and o,ther materials to suppon emergency operations. OBJECTIVE 3: DIRECTION AND CONTROL Demonstrate the capability to direct and control emergency operations. OBJECTIVE 4: COMMUNICATIONS Demonstrate the capability to communicate with all appropriate emergency personnel at facilities and in the field. 55
OBJECTIVE 5: EMERGENCY WORKER EXPOSURE CONTROL Demonstrate the capability to continuously monitor and control radiation exposure to emergency workers. OBJECTIVE 6: FIELD RADIOLOGICAL MONITORING - AMBIENT RADIATION MONITORING Demonstrate the appropriate use of equipment and procedures for detennining field radiation measurements. OBJECTIVE 7: PLUME DOSE PROJECTION Demonstrate the capability to develop dose projections and protective action recommendations regarding evacuation and sheltering. OBJECTIVE 8: FIELD RADIOLOGICAL MONITORING - AIRBORNE RADIOIODINE AND PARTICULATE ACTIVITY MONITORING Demonstrate the appropriate use of equipment and procedures for the measurement of 7 airborne radiciodine concentrations as low as 10 (0.0000001) microcuries per cubic centimeter in the presence of noble gases and obtain samples of particulate activity in the airborne plume. OBJECTIVE 9: PLUME PROTECTIVE ACTION DECISION MAKING Demonstrate the capability to ma', timely and appropriate protective action decisions. OBJECTIVE 10: ALERT AND NOTIFICATION Demonstrate the capability to promptly alert and notify the public within the 10-mile plume pathway emergency planning zone and disseminate instructional messages to the public on the basis of decisions by appropriate State or local officials. OBJECTIVE II: PUBLIC INSTRUCTIONS AND EMERGENCY INFORMATION Demonstrate the capability to coordinate the formulation and dissemination of accurate information and instructions to the public. OBJECTIVE 12: EMERGENCY INFORMATION - MEDIA Demonstrate the capability to coordinate the development and dissemination of clear, accurate, and timely information to the news media. 56 ,..... :. x s.: + u.. w.. n.... x .,r-,,,- r.. m. ; -,. .n . m yav
p-OBJECTIVE 13: EMERGENCY INFORMATION - RUMOR CONTROL Demonstrate the capability to establish and operate rumor control in a coordinated and timely manner. OBJECTIVE I4: IMPLEMENTATION OF PROTECTIVE ACTIONS - USE OF POTASSIUM IODIDE FOR EMERGENCY WORKERS, j INSTITUTIONALIZED INDIVIDUALS, AND THE GENERAL PUBLIC Demonstrate the capability and resources to implement potassium iodide protective ) actions for emergency workers, institutionalized individuals, and,if the State plan specifies, the general public. OBJECTIVE 15: IMPLEMENTATION OF PROTECTIVE ACTIONS - SPECIAL POPULATIONS Demonstrate the capability and resources necessary to implement appropriate protective actions for special populations. OBJECTIVE I6: IMPLEMENTATION OF PROTECTIVE ACTIONS - SCHOOLS Demonstrate the capability and resources necessary to implement protective actions for school children within the plume pathway emergency planning zone. OBJECTIVE 17: TRAFFIC AND ACCESS CONTROL Demonstrate the organizational capability and resources necessary to control evacuation traffic flow and to control access to evacuated and sheltered areas. OBJECTIVE 18: RECEPTION CENTER -MONITORING, DECONTAMINATION AND REGISTRATION Demonstrate the adequacy of procedures, facilities, equipment, and personnel for the rcdiological monitoring, decontamination and registration of evacuees. OBJECTIVE 19: CONGREGATE CARE Demonstrate the adequacy of facilities, equipment, supplies, personnel, and procedures for congregate care of evacuees. OBJECTIVE 20: MEDICAL SERVICES -TRANSPORTATION Demonstrate the adequacy of vehicles, equipment, procedures, and personnel for transporting contaminated, injured, or exposed individuals. $7 c
OBJECTIVE 21: MEDICAL SERVICES - FACILITIES Demonstrate the adequacy of equipment, procedures, supplies, and personnel of medical facilities responsible for treatment of contaminated, injured, or exposed individuals. OBJECTIVE 22: EMERGENCY WORKERS, EQUIPMENT, AND VEHICLES MONITORING AND DECONTAMINATION Demonstrate the adequacy of procedures for the monitoring and decontamination of emergency workers, equipment, and vehicles. OBJECTIVE 23: SUPPLEMENTARY ASSISTANCE (FEDERAUOTHER) Demonstrate the capability to identify the need for external assistance and to request such assistance from Federal or other suppon organizations. OBJECTIVE 24: POST-EMERGENCY SAMPLING Demonstrate the use of equipment and procedures for the collection and transponation of samples from areas that received deposition from the airborne plume. OBJECTIVE 25: LABORATORY OPERATIONS Demonstrate laboratory operations and procedures for measuring and analyzing samples. OBJECTIVE 26: INGESTION EXPOSURE PATHWAY - DOSE PROJECTION AND PROTECTIVE ACTION DECISION MAKING Demonstrate the capability to project dose to the public for the ingestion exposure pathway and to recommend protective actions. OBJECTIVE 27: INGESTION EXPOSURE PATHWAY - PROTECTIVE l ACTION IMPLEMENTATION l l Demonstrate the capability to implement protective actions for the ingestion exposure pathway. l OBJECTIVE 28: RELOCATION, RE ENTRY, AND R$ TURN - DECISION l MAKING l Demonstrate the capability to develop decisions on relocation, re-entry, and return. l 58
OBJECTIVE 29: RELOCATION, RE ENTRY, AND RETURN - IMPLEMENTATION Demonstrate the capability to implement appropriate measures for relocatien, re-entry, l and return. ) o 59
4 I B. Extent-of Play Agreement 1 l The extent-of-play agreement on the following pages was submitted by the State of Connecticut, and was approved by FEMA Region I on July 31,1997, in preparation for the Millstone Nuclear Power Station Plume Exposure Pathway exercise on August 21,1997, and the Ingestion Exposure Pathway exercise during the week of October 6,1997. The extent-of-play agreement includes any significant modification or change in the level of demonstration of each exercise objective listed in Subsection A of this appendix. I i t d i l l i f ~ .._m___._
Extent ofPlay .uanone stacan m7 pune un upsion pernver eveunec saanse. August 21, Odober 8,9,10,1997 .My 31,1997 Rowsoon l Objective 1. MOnfr rrATION OF EMERGENCY PERSONNEL l Demonstrate the capability to alert and fully mobillie personnel for both emergency fadlities and field operations. Demonstrate the capability to activate and stafremergency facilities for emergency operations. Extent of Flav-General Notification of State, Local and Utility o!!icials will bc initiated through use of the Emergency Noti 5 cation and Response System (ENRS). State and local emergency staff will then moWiize appropriate emergency personnel to notify them of emergency operations center (EOC) activation and direct them to report to theEOC. Activation of State and local emergency planning zone (EPZ) community EOC's will be driven by the exercise scenario Emergency Classitcation Level (ECL). The state radiological emergency response plan (RERP) requires EOC activation at the Site Area Emergency (SAE) classi6 cation, however the decision to activate mqy occur at an earlier ECL. Estent of Play- $necific
- 1. The following locations and agencies will be pre-positioned and demonstrated o61ine from the exercise scenario:
Reception Center: Windham (o5line during the week of October 6,1997) Host Community, Congregate Carc Facihty, Windham (o&line during the week of October 6,1997) State Deparanent of Environmental Protection (DEP) Field Teams (m conjunction with the exercise) School District Demonstrations (o5line dunng the week of October 6,1997) TrafEc and Access Control Polms (off-line during the week of October 6,1997) Medical Services Drill (oEline on October 9,1997) US Coast Guard EOC Liaison (August 21,1997)
- 2. A second shiA roster will be available for evaluator inspection.
O W neersxT,noc 61
cxtent or riay .Mastone Staban 1997 Plume and Ingesbon Pathway Evaluated Exercise-August 21 October 8,9,10,1997 July 31,1997 Revision Objective 2. FACILITIES-EQUIPMENTDISPLAYS AND WORK ENYTRONMENT Demonstrate the adequacy offacilities, equipment, displays, and other materials to support emergency operationa. Ertent of Play -Soccific I This objective will be demonstrated by state and local EOC's and the participating hon community to include; plans, procedures, radiological emergency status board, classification schemes and comrcunications equipment. The facility activation will be appropriate for a one-shift operation. A source of backup power and maintenance logg if available, will be discussed with the evaluator. l l l l 1 I 0 ll l 62 mm i
-M8lstone statkws 1997 Pfane and kestion Pounvey Evolveted Exercee-August 21, October 8, 9,10,1997
- ~ ~
July 31,1997 Revision IObjective 3. DIRECHON AND CONTROL l Demonstrate the capability to direct and control emergency operations. ExtenLef_ Flay _- Genital Direction and Control sedvities will be demonstrated by participating organizations in accordance with the REAP. Artas Reanirine Corrective Action (ARCA) 38-95-03-A 01: Notificadon ofEPZ farmers. Closed 38-95-03-A-02: Range ofR=*a - 38-95-03-A-03: Bus driver dosimetry. In abeyance pending reicase of oscial FEMA policy. 38-95-03-A-04 Range ofReading. 38-95-03-A-12: Area IV not a!mys responsive to municipalities. 29-96-03-A-01: Conflicting instructions in Town ofLyme. 29-96-03-A-04: Conflicting actionsin Town ofLyme. e O wenxTmoc 63 l
Extent of Play -hGfstone Sin 6cn 1997 Pkane and ingeshan Pathway Evaluated Exercise-August 21. October 8. 9.10,1997 July 31,1997 Revision l Objective 4. COMMUNICATIONS l Demonstrate the capability to communicate with all appropriate emergency personnel at facilities and in the 6 eld. Estent of Play-Specifle
- 1. Communications from the state to the EPZ communities will be relayed through the state Office ofEmergency Managesucnt (OEM) Area Coordinator.
- 2. Direct communications bers the state and the udlity will be established between the site emergency operations facility (EOF) and the state EOC. Northeast Utstics dispatches a company officer to act as liaison to the state EOC in Hartford.
Arras Reauirine Ceawee Action (ARCA) 29-96.04-A-01: Faxworks* system unrehable. 29-96-04-A 04: EBS messages not timely faxed from OEM. 0 l l ersmxTmoc 64 g.
Extent of Play -MRstone Stadon 1997 TMume Cnd Ingestion Pethway Evaluated Exercsse. August 21, October 6, 9,10,1997 July 31,1997 Revision lObjective 5. EMERGENCY WORKER EXPOSURE CONTROL l Demonstrate the capability to continuously monitor and control radiation exposure to emergency personnel. Esteni of Play-Specific
- 1. Each community has been provided with emergency worker dosimeny packets. These packets include: a thermoluminescent dosimeter (TLD) and two self-reading dosimeters (SRD) in the 0 roentgen (R) to 5 A and the O R to 200 R ranges.
- 2. One dosimetry packet will be issued to each emergency worker in the plume emergency planning zone who is leaving the EOC. In addition, each EOC will be issued o'ne dosimetry packet to represent those issued to all appropriate personnel. The EOC representative who is issued the packet will demonstrate dosimeuy turn-in and necessary paper work. Evaluators will be shown the stockpile ofTLD's which will represent a sufficient supply for all emergency workers.
- 3. Emergency worker exposure control training, which includes basic knowledge of exposure control procedures (tum-back values, call in values, and periodic monitoring), may be demonstrated thmugh evaluator interviews.
- 4. Range ofreading will be demonstrated.
- 5. During the exercise one emergency worker will demonstrate procedures to be followed in tho event that exposure limits or tum-back values are received. Controller inject will be used rs prompt demonstation of these procedures.
i Areas Reaufrine Corrective Action (ARCA) 38-95-05-A-14: UConn reception center will not be demonstrated this exercise. 38-95-05-A-16: Wethersfield reception center will not be demonstrated this exercise. t 5 O werexrmoc 65 i
I .I -Mmstone station 199T Plume and koestion Pathw:y Evaksated Euernse-Au9ust 21, October 8, 9,10,1997 ~~ July 31,1997 Revision .t Objective 6. FIELD RADIOLOGICAL MONTf0 RING - AMBIENT RADIATION MONITORING Demonstrate the appropriate use ofequipment and procedures for determining field radiation measurements. Extent of Play - General Teams using provided eq'i;=w and procedures will demonstrate 6 eld radsation measurements in accordance with theRERP. Field monitoring teams will be dispatched flrom State Police Troop E (Montville) barracks. Extent of Piav - Soecific
- 1. Demonstration of 6 eld team activities will include inventory, operational checks and verification of calibration in accordance with the Objective #5 extent of play agreement.
- 2. DEP will deploy two two-pemon field teams who will determine plume characteristics. The extent of monitoring team deployment to be demonstrated will depend on accessibility of the areas, equipment, wearher conditions, and projected exposure to survey team IrAs.
I
- 3. The number ofpre-selected reference points demonstrated during the exercise in a given area will be a function of wind speed and direction, distance from the nuclear power facility, topography, population density, and accessibility by road. Each Sold team will be dispatched to at least two sampling points where each team will take at least two radiation measurements.
- 4. DEP field monitoring teams will demonstrate plume monitoring for skin exposures, particulate and iodine per the state RERP. Field teams will be activated and assembled at the Montydle state police barracks to obtain equipment and await instructions.
Areas Reanirine Cornetive Action (ARCA) 29-96-06-A 02: No mission briefing given. 29-96-06-A-03: FMTA assets unused. 29-96-06-A-04: Check sources untabeled. 29-96-06-A-05: Failure to purge noble gases. l l womer.coe 66
-heigatone staban 1997 Mume arnt Ingestion Pathway Evaluated Exeranse. August 21, October 8, 9,10,1997 .luty 31,1997 Reviskm l Objective 7. PLUME DOSE PROJECTION l Demonstrate the capability to develop dose projections and protective action recommendations regarding evacalation and sheltering. Extent of Play - General i Activities associated with plume location and d#..yo. cat of dose projections through the use ot' models, data from the field, data supplied by the utility, and the development of approprimta protective action recornmendations will be demonstrated in accordance with the state RHRP Extent of Pimv - Snecific
- 1. DEP staffwiD perform dose projections at the state EOC with site-specific input flrom Northeast Utilities (NU). 'Ihe NU stafrat the EOF will perform parallel dose calculations for comparison and diamamion with state stafE The DEP dose calculation staffwill also receive frequently updated meteorological and radiological data via the NU radiological stafE
- 2. Dose crloulations will be demonstrated using the atmosphere dose=== ament model (ADAM) computer code.
MPo mTmoc 67
.nt& stone Station 1997 Plume and ingestion Pathway Evalueled Enanssa. August 21, October 8, 9,10,1997 July 31,1997 R3esion Objective 8. FIELD RADIOLOGICAL MONITORING-AIRBORNE RADIOIODINE AND PARTICULATE ACTIVITY MONTIVRING
- 1. Demonstrale the appropriate use ofequipment and procedures for the measurement of airborne radioiodine concentrations as low as 1 x 10"pci/cm' in the presence ofnoble gases
- 2. Demonstrate the apprepi=te use of equipment and procedures for the measurement of airborne radioiodine particles Estent of Play - General Acrivities associated with the monitoring of airborne radionuclide and particulate activity will be demonstrated. The activities involve sampling equipment, procedurcs, vehicles, and transmission of data. Sample collection will be in accordance with procedures Extent of Play - Specific
- 1. DEP field monitoring teams will obtain one or more radioiodine and paniculate samples where the exposure ate of at least 100 mR/hr as indicated by controller inject, represents the plume center line. Transportation of samples to the state laboatory will not be demonstrated for the plume phase.
- 2. Air sample cartridges used during the exercise have been specifically designated for drill or exercise use only. These cartridges may be used mare than once during the exercise. The inventory of air sample cartridges to be used in an actual emergency is located at the DEP in Hartford, each of the nuclear power stat ons, and at the Montville state police barracks i
Evaluators will be shown the actual inventory. Areas Reanirine Corrective Action (ARCA) 38-95-08-A-08: Field team technician used non-standard technique. e p....
MEstone station 1997 Plume and Ingestion Pathway Evolueled Exerdsc. August 21, October 8, 9,10,1997 July 31,1997 Revision [ Objective 9. PLUME PROTECTIVE ACTION DECISION MAKTNG l Demonstrate the ap6Irty to make timely and appropriate protective action decisions (PAD). Extent of May-Sneelfic
- 1. Initial plume protective action dedsions will be based on the exercise scenario emergency classification level and state posture codes as specified in the RERP. The RERP provides recommended actions for state and local officials, which may be used during rapidly j
i developing events. Specific decision making cdteria, including the influence of extenuating factors such as environmental conditions, plant conditions and established radiological thresholds, are provided in the RERP for both state and local of5cials. Input such as utility protective action m+ -w.dations will also be used in decision making.
- 2. When the EOF is activated, its staff will forward utility protective action recommendations to the state EOC.
- 3. The state EOC, as specified in the RERP, will direct and coordinate protective action implementation through state and local agencies I
j 69 wnmmoc
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Extant of Play .htRstone Station 1997 Plume and ingestion Pethway Evaluated Eueraine-Au9ust 21, Odober 8,9,10,1997 July 31,1997 Revialon l Objective 10-ALERT AND NOTIFICATION l Demonstrate the capability to prompdy alert and notify the public within the 10-mile plume pathway emergency planning zone (EPZ) and dissaninate instructional messages to the public on the basis of decisions by appropriate state and local of5cials. Extent of Ptsy-Specinc
- 1. Activation of the public alerting system (sirens) will be sinmistad
- 2. Alert and noti 5 cation activities leading to Emergency Alerting System (EAS) simulation and the release ofEAS messages will be demonstrated, however actual transmission of EAS messages to the public will be simulated. The state RERP does not permit activation ofEAS by local CEOs aAer the governor declares a state of emergency.
- 3. Demonstration ofEAS activities willinclude; selection of the EAS message to be br~hg arranging communications with the appropriate EAS station for message tunsaussion and simulated narration of the selected message.
- 4. The 15-minute clock begins when the governor or his representative approves the protective action decision with his signamre.
- 5. FEMA may conduct out-of-sequence interviews ofEAS radio station staff.
- 6. State OEM Area Coordinators will simulate siren activation arrangements for any EPZ community that is unable to participate.
- 7. By agreement with FEMA, the sum content ornews releases, instructional messages, and press briefings will determine whesher public informadon requirements have been met.
a Areas Reauleine Cowde Action (ARCA) 38-95-10-A-05: Inconsistent EBS instructions. Administratively closed. EBS messages since revised, and are now being replaced with EAS rnessades. l i worstraoc 70 1 l l \\ t r
.NINattme Staden 1997 Plume and kges6an Pa0may Eselveted Exemne. August 21, October 8, 9,10,1997 July 31,1997 Resnaion i Objective 11. FUBLICINSTRUCTIONS AND EMERGENCY COMMUNICATIONS Demonstrate the capability to cow.& nite the formulation and dissemination of accurate information and instructions to the public. Extent of Flav - Generst Acewities associated with the development of cicar, concise public information and instructional messages to implament protective actions will be dam _44ed. These will )e demonstrated in conjtW whh preparation ofin de.a! message releases, and willinclude coordination with all appropriate agencies andjuriM+==- The capability to coordinate message release with appropriate agencias and organizations will be demonstrated. These activities will generally be demonstrated concurrent with each instructional message release. Extent gf Play-Snecirse Protective action implementation will be inhiated and cevif== ad by the state OEM through transmission to its area of5ces and subsequent relaying to the affected local governments. local oflicials would then p=>1a+a activation of their public slerths system (PAS) to procede an instructional message release. Activation of the EAS will occur at state OEM only. The RERP does not authorize local activation ofEAS during a declared state ofemergency. I.ocal goverrmants may choose to develop and simulate release of their own news advisories. By agreement with FEMA, the sum content ofnews releases, instructional messages, and press briefings will determine whether public informadon requirements have been met. Areas Reauirine Co..Jw Action (ARCA) 38-95-11-A-09: Incomplete EBS instructions. Administratively closed. EBS messaacs i since revised, and are now being replaced with EAS messages. 29-%11-A-06: IncompleteEBS instructions. Adminientively closed. EBS messages since revised, and are now being replaced with EAS messages 29-Ell-A-07: Incomplete EBS instructions. Administratively closed. EBS messages since revised, and are now beira replaced with EAS messages. womermoc 71
l -Mmstone Statiors 1997 Plume end Inges60n Pathway Evaluated Exercise-August 21, October 6, 9,10,1997 sluty 31,1997 Revmion I lObjective 12. EM ERGENCY INFORMATION - MEDIA l Demonstrate the capability to coordinate the development and distemination of clear, accurate, and timely information to the news media. Estent of Play - General Activities to establish a primary information facility for coordinating media information will be demonstrated. These activities will include a media briefing and the generation ofpress releases Demonstration ofin-person or telephone interaction with media representatives may be shown by the use of actual media representatives or players simulating their role during the briefings. l Extent of Pluv - Specifle Activation of ajoint media center at the state armory will be demonr: rated. Representatives &om J the governor's press office and the utility public information group will be present This activity will include; distribution of media kits, detailed discussion of protective actions, site rernedial actions, instructional message and press release copy distribution, use of plant equipment graphic displays during bdefings, and internal coordination ofmedia information prior to its release. By agreement with FEMA, the sum content of news rela:ases, instnactional messages, and press briefings will determme whether public information requirernmts have been met. Aress Reautrine Corrective Action (ARCA) 38-95-12-A-10: Inaccurate information given during media briefing. Closed in CY'96 exerdse report. Incomplete information given during media briefing. Closed in CY'96 38-95-12-A-11: exerdse report. 38-93-12-A-12: Not found in CY'96, MP'95, or MP'93 (where this numbering convention was not used). Administratively closed according to FEMA Region I stafE h l bes a rpoo 72 6
Extant ofPby ~~ afilstone Stanon 1997 Plume andInges6on Pamway Evolueled Exenise- \\ August 21, October 8, 9,10,1997 .luty 31,1997 Revision l Objective 13.
- EMERGENCY INFORMiTION-RUMOR CONTROL l
Demonstrate the capability to establish and operate rumor contml activities in a coordinated and timely manner. Extent of Play-Soccirse The state EOC will activate the rumor control desk. A control cell will initiate rumors into the synem at the state and utility level. The control cell will demonstrate this objective by the insertion of at least six rumors per hour to each rumor control staftperson (excluding the rumor control supervisor), beginning after the governor's state of emergency declaration. Demonstrated rumor control acdvities will include securing current information, receiving updates, and relaying infonnation to callers. i Areas Reauirine Cornetive Action (ARCA) 38-95-13-A-03: Found in neither CY'96 or MP'95 exercise report. Cleared according to FEMA RegionI staff. e l I i Naoc 73 i y ------,, ,...,,y,p
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- s
.-Missione Ste6cn 1997 Plume atulInges6on Pathway Evelveted Exerdse. August 21, October 8,9,10,1997 Jury 31,1997 RevMon Objeettve 14.. IMPLEMENTATION OF PROTECTIVE ACTIONS - KI POR EMERGENCY WORKERS,INSTITUTIONAT.f7.F.D 1 INDIVIDUALS, AND THE GENERAL PUBLIC. I Demonstrate the capability and resources to implement potassium iodide (KI) protective actions for emergency workers, institutionalized individuals, and, if the state plan specifies, the general Pubuc. Extent of Play-General The RERP discusses the issue of potassium iodide (KI) policy and implementation in Section 10.3, of the basis document (Volume 1). The state of Conneesicut KI policy provides for the use of KI by emergency workers only. The state policy does an1 provide for issuance ofKI to the general public. EPZ communities m&Y use KI in accordance with their plans and procedures. The only EPZ community which wy_6 and issues KI to its emergency workers is Waterford (Millstone). The use ofKI by people who are institutionalized has not been recommended by the CWcui public health department. State emergency workers with assigned duties inside the plume exposure EPZ take one tablet of KT when respondmg to an incident classdication GENERAL EMERGENCY Posture Code Alpha, unless they are otherwisc ' structed. m Estent of Play-Snecifle Decision making regarding =Waration of KI to identified emergency workers will bc performed in accordance with the RERP. ~ wouxrmac 74
Extent OfPI y .ntinarone staden 1997 Mume and koranon Paemey Evaduated Exercmee-August 21, Odober 9,9,10,1997 .My 31,1997 Rension Objective 15. IMPLEMENTATION OF PROTECTIVE ACrlONS - SPECIAL POPULATIONS Demonstrate the capability and resources necessary to implement appropriate protective actions for special W4 Extent of Play-Cmrt Implementation activities for special populations will be demonstrated by appropriate staff as in an actual emergency ) Extent of Play - SMne
- 1. State OEM will demonstrate contacting the Niantic Correctiona1 Institution. The state pu health department will simulate ea% nursing care facilities vnthin the plume EPZ.
- 2. Communitio will demonstrate this objective by table top discussion to include; identification of special needs populations, transportation requhements and the coordination ofactivities with the state OEM to obtain additional transportation resources as 9- ?y.
- 3. During the week ofOctober 6,1997 FEMA will conduct surveys offive nursing care facilities within the plume EPZ to discuss these facilities' evacuation plans.
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Extent of Play .MEstone Stadon 1997 Pfume and Inges00n Pattnvey Evaluated Exeteise. August 21, Odober 8, 9,10,1997 July 31,1997 Revision IObjective 16. IMPLEMENTATION OF PROTECTIVE ACTIONS-SCTIOOLS l Demonstrate the capability and resources narmaury to implement protective actions for school children within the plume pathway emergency planning zone (EPZ). Extent of Ptav. General The following three selected communities will demonstrate the ability and resources ne*<ury to implement protective actions for school children within the EPZ: Town ofEast Lyme l Town ofLedyard e Town ofOld Lyme Extent of Play-Swh
- 1. Appropriate activities associated with the implementation ofschool protective actions will be l
simulated in those communities affected by the scenario plume on August 21,1997. l
- 2. During the weck of October 6,1997, the towns ofEast Lyme, Ledyard, and Old Lyme will conduct a <ittenuion of their plans with their superintendents of schools and one dcaignated school principal in each district. One vehicle will be demonstrated.
Aruns Reauirine Corrective Action (ARCA) 38-95-16-A-07: Incomplete EBS instructions. #
- 44ively closed. EBS messages since revised, and are now being replaced with EAS messages.
91-25; Incornplete EBS instructions. Administratively closed. EBS messages since revised, and are now being replaced with EAS messages. 82-30: Incomplete EBS instructions. Administratrvely closed. EBS messages since revised, and are now being replaced with EAS messages. womrr. coo 76 ~
l ~ .AtlEstone sta00n 1997 Plume and Ingestion Pathway Evolunted Exetesse. August 21, October 8,9,10,1997 .My 31,1997 Revmon l, l Objective 17. TRAFFIC AND ACCESS CONTROL l i' Demonstrate the organizational capability and resources necessary to control evacuation traffic flow and control access to evacuated and sheltered areas. i Extent of Play - General Decision making activities at the state and local EOC's to establish inirial trofEc access and control points will be drues.uM. Coordination and implementation of Connecticut's traffic management plan is a state police responsibility. The state police liaison to the state EOC will direct implementation of the plan to the state police barracks in the affected area. Each barracks assigns troopers or officers to control points withinitsjurisdiction. Extent of Plav. Sneelfic
- 1. Local EOC staffwill discuss establiemant oftrafBc control points.
- 2. State police and transportation department (DO'I) officials will discuss the process of securing additional resources, such as low trucks, required to remove trafEc impediments
- 3. The Connecticut State Police and state DOT, will demonstrate the provision ofnecessary barriers for traffic and access control points at two designated locations during the week of October 6,1997. State police assigned to traffic and access control will be briefed at the 1
Troop E (Montville)barracka. - Note: Since this is a scenario-driven objective, EPZ municipalities with a full-time paid police force (Groton (city and town), New Iondon, and Waterford) will discuss the establishment of traffic and access control points. All other EPZ municipalities are covend by Connecticut State Police. e w,70ermoc 77 ~~~
1. -neEstone Sta6en 1997 Piume and ingestion Pathway Evaluated Exemise. August 21, October 8, 9,10,1997 Jsdy 31,1997 Rewslan ^ RECEPTION CENTER - MONITORING, DECONTAMTNATION, Objective 18. AND REGISTRATION Demonstrate the adequacy of procedures, facilities, equipment and personnel for the radiological monitoring, decomamination, and registration ofevacuees. Estent or May - General Radiological monitoring, registration and decontamination procedures for evacuated individuals, vehicles, and equipment will be demonstrated at selected facilities. The Windham reception center will be activated and players simulating evacuees will be pr~--=~8 by the facility. Eatent of Play - Specific h Windham reception center will demonstrate activation of personnel and resources during the week of October 6,1997. The following capabilities will be demonstrated by the reception center activated for exercise play: Registration ofincoming evacuees; Personnel radiological nanitoring activities using hand-held equipment or portal monitors as avadable at the facility. A minimum of six persons will be monitored for the demonstration. Hein: Ifpostal monitors are used during the demonstration, at least one staff radiological monitor will demonstrate hand-held instrument monitoring techniques for Personnel. Contamination control measures and decontamination techniques for at least two males and two females will be demonstrated. One vehicle per lane will be extemally monitored and parked in a designated clean or contaminated ama. Inventory of clothing for decontaminated individuals will be show. The town ofWindham will activate its reception center for demonstration of this objective. These activities will take place out of sequence from the exercise scenario with a simulated notificadon thxn the state Office of Emergency Management. Areas Reanirine Currective Action (ARCA) 35-95-Is-A-15: Resolved at 1996 MS-I drill 38-95-18-A-17: Incomplete set of clothing. i I ~ I w a rtmac 73 j
-hGnstone Station 1997 Plume amtInges00n Pamway EvaluatedExetnise. August 21, October 8, 9,10,1997 My 31,1997 Rension l l lObjcetive 19. CCN5tEGATE CARE l Demonstrate the adequacy of facilities, equip.M supplies a'nd personnel and procedures for congregate care ofevacuees. Ezfent of Play-General Demonstration of this objective wi!! be performed out-of-sequence with the bercise scenario by a walk-through of the facility by evaluators. Congregate care facility staffing will be demonstrated by presentation of a current roster to evaluators. Availability of equipment and matcrial for center operation may be demonstrated by the presentation of a list ofresources detailing their location and quantity. Exteni of Plav. Snecific Windham
- 1. All congregate care facilities will be made available for walk-through inspection by evaluators during the week ofOctober 6,1997.
- 2. "Ihe Red Cross will provide shelter survey documentation for evaluators' inspection.
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.MEstone StaDon 1997 Mume and Inges60n Pathway Evaluated Exercise-August 21, Odober 8, 9,10,1997 l Objective 20. MEDICAL SERVICES TRANSPORTATION l Democ5trate the adequacy ofvehicica, equipment, procedures and personnel for transporting contaminated, injured, or exposed *mdividuals. Extent of Ptsy - General Demonstrate control of the spread of contamination from individuals who may be contaminated and injured. Address pdorities of care betwoon control of contamination and the need for prompt transportation to a medical facility for care of an urgent condition. Arrange transportation to a medical facuity equipped to deal with a contaminated ir4jured individual Demonstrate communication between the vehicle crew and medical facihty. Monitor the emergency vehicle and determine the need for decomamination. Demonstate the adequacy ofplans and procedures for the care and transportation of contaminated or exposed individuals. Extent of Play-Specific
- 1. This objective will be demonstrated by licensee, emergency medical, Lawrence and Memorial Hospital and Waterford Ambulance personnel dudng the week of October 6,1997.
- 2. An individual having simulated injuries will be anessed medically and radiologically. Pdorities of care will be determined based on injudes and the magnitude of radioactive contamination.
- 3. "The individual wUI receive appropriate first aid using contamination control measures, be prepared for transport, and transported to a medical facility ibr tmatment.
- 4. A member of the liccasce's health physics staffwill accompany the patient and vehicle to the facthty designated to receive the 'mdividual.
- 5. Communications will be demonstrated by use of the vehic!c dedicated medical radio equipment (Med Radio) as it proceeds to the medical facilhy. This equipment is required in all ambulances in Connecticut and provides two-way radio communication to a0 emer5ency medical facilities.
- 6. Medical procedures will be conducted in accordance with state, local, and hospital protocols.
They will not be demonstrated. 80 unprxrmoc
-Mastone stehan ICT Plume andIngestion PnUnvey Evaluated E.nercine-August 21, October 8, 9,10,1997 July 31,1997 ReWann l Objective 21. MEDICAL SERVICES-FACHJTIES l Danonstrate the adequacy of the equipment, procedures, supplies, and personnel of nwdical facilities responsible for the treatment ofcontaminated, iriured, or exposed individuals. Fur-t of Play - C-ul Dw ste the ability to control the spread of contamination from individdals who may be contaminated and injured. D-wr.e.ie setting priorities between the need to address radioacdve contamination and the p:nmpt diagnosis and treatment ofmedical conditions. Demonstrate the appropriate decontamination ofindividuals Fre==t of Play - Snecifle Lawrence and Memorial Hospital will demonstrate this objective. An area for the diagnosis and treatment ofa contaminated or exposed irjured individual will be established in acccitlance with hospital plans. The radiological esnergency area has been designated and will contain or have immediate access to all equipment necessary for this function which can include the decontamination of patients. Designated hospital pe.wi..e!, assisted by licensee health physicista, will receive and simulate diagnosis, treatment, and decontamination of a patient. Simulated patient treatment activities will be carried out in accordance with existing hospital plans. l wwsxr. coo 81 m - m gw;- - 7 r-m3g7 _ -_.,,-a,3 y yq_ _,,.,_m-* am, e,- +<-%>
- u;8
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n '+*:_' t. J r ._s._ e m -henstorm Staelon 1997 Plume am! bgestion Pathway Evaluated Exercise-August 21, October 9, 9,10,1997 Juf 31,1997 Redslon t Objecdvc 22. EMERGENCY WORKERS-MONITORING AND DECONTAMINATION Demonstrate the adequacy of the facilities, equipment, supplies, procedures, and perwnnel for decontamination of emergency workers, equipment and vehicles and for waste disposal. Extent of Play - Snecific This objective will be demonstrated at the Windham host community during the week of October 6,1997. The demonstration will include turn in of dosimetry by emergency workers. l I e i w waximoc 82
Extent ofPlay - -Moistone Stabon 1997 Plume and Ingestion Pathway Evaluated Exettuse-August 21. Odober8, 9,10,1997 July 3t.1997 %;.;un lobjective 23. SUPPLEMENTARY ASSISTANCE (FEDERAUOTHER)l Demonstrate the capability to identify the need for external assistance and to request s assistance from federal and other support organizations Esteni of Plav -General Once the need for outside organizational support has been established, all activitics a with requests for supplementary assistance will be carried out in accordance.with th deviations are specified below. Extent orPiav-Snecific Once the need for outside organizational support has been established, DEP will initiate'l request for federal agencies' supplementary assistance. ll ) )\\ l 1 I i e + umoarmoc 83 / r - = "- ' ~ " 7 '1
__._m -MEstone Station 1997 Pfume and kages00n Patrway Evaluated Exercise. August 21, October 8, 0,10,1997 July 31,1997 Rewann lObjective 24. POST-EMERGENCY SAMPLING l Demonstrate the use of equipment and procedures for the collection and transportation of samples from areas that roccived deposition from the airborne plume. Demonstradon Criteria:
- 1. Each team demonstrates e-y procedures and the use of equipment to properly collect samples.
- 2. Samples are promptly transported to a central point or an appropriate" laboratory for analyds.
- 3. All activities described in these demonstration criteria are carried out in accordance with the plan unless deviations are provided for in the extent of play.
Extent of Play-General Sampling teams will demonstate sampling collection procedures and cross contamination prevention procedurcs. Particular types of samples to be collected and the areas from which they are collected may be determined in advance. All activities related to sample transportation and storage as well as record maintenance and documentation will be performed as in an actual emergency. In the event the organization collects e! a large number of samples in the field, these activities may be performed for a representative number of samples. All arrangements necessary to accommodate the scope of exercise play and demonstration of these procedures will be made by the responsible parties before the exercise and identifiedin the section below, t Extent of Play-Snecine DEP will direct the state agriculture, health, and consumer protection departments on where field sampling will take place. Each department will provide one two-person sampling team. Each department will demonstrate equipment and supplies used for 5 eld sampling. Field teams will also demonstrate equipment used for measuring background radiation for field personnel, sangle location, and individual samples. Each department will take two samples of a single type from d%=aa'ad sampling locations within the simulated affected area. These samples will be delivered to the state health department laboratory in Hartford for analysis
Extent ofPlay -nenstone Station 1997 Mwne anOlgeselon Pedrway Evolunted Exercise. AUpunt 21, October 6. 9.10.1997 July 31,1997 Mevision lObiective 25. LABORATORY OPERATIONS l Demonstrate laboratory operations and procedures for measuring and analyzing samples.. Demonstration Critaria-
- 1. The laboratory has the capability to process samples as required.
- 2. The laboratory is equipped with analytical instruments suhable for determining radioisotopes and radiation levels in the samples.
- 3. All saivities descnbed in these demonstration criteria are carried out in accordance with the plan unless deviations are provided for in the extent of play.
Extent of Play-Genesal AI! activities associated with the laboratory's capabilities to process samples indadas those that are seasonal in accordance with the exercise scenario--as required will be performed as in an actual emergency. Should the laboratory receive a large number of samples, these activities may be performed for at least two of each sample type received. All arrangements necessary to accommodate the scope of exercise play and demonstration of these procedures will be made by the responsible partica. l Appropriate laboratory activities and equipment will be demonstrated as in an acmal emergency. The laboratory will analyze two samples of each type. In the event the laboratory requires additional assistance with sampic processing, its personnel.will discuss techniques for obtaining such assistance. Since laboratory data are critical to the decision-making process, laboratory ) operations may be demonstrated out ofsequence with the rest of the exercise This is done to accornmodate the compressed time schedule of the caerdse. Entent of Play-Swh The state heshh department laboratory will receive and log incoming ingestion samples for analysis The results of the analysis will be transmitted to the DEP staff at the state EOC. Transportation of one field sample by the state police or its designee will be demonstrated. ) wonotraoc 85 \\
.MWstone Staten 1997 Plume and Ingestion Pathway Evaluated Exercise. ~ August 21, Odober 8, 9,10,1997 My 31,1997 Revision Objective 26. INGESTION EXPOSURE PAu1WAY - DOSE PROJEU110N AND PROTECTIVE ACTION DECISION MAKING Demonstrate the ability to project dosage to the public for ingestion pathway exposure and determme protective measures. Demonstration Criteria:
- 1. Projected dore is calculated for the ingestion exposure pathway.
- 2. Protective action decisions are made for the ingestion exposure pathway.
- 3. All activities described in these demonstration criteria are carried out in accordance w the plan unless deviations are provided for in the extent ofplay.
Estent of Ptsy - General All activities associated with the calculation of dose projection for the ingestion pathway will be completed as in an actual emerEenCY. The dose assessment group will demonstrate the capability to make protective action recommendations (PAR's). PAR's will be based on controller-injected data which will consist of radiation levels found in simulated samples of agricultural pruducts and potabic water. Data will be transmitted over conununication channels used in an actual emergency. Radiological field data will reflect a compressed time schedule. All activities associated with protective action decision making for the ingestion exposure pathway will be completed as in an actual emergency. l l l Erteat of Play - Specifk After DEP reviews data from the state heahh department laboratory and compares food and water radiation levels to guidelines contained in its emergency plans, it will formulate FAR's for the governor to review. Assistance from a control cell simulating the federal radiological monitoring and asacasment center (FRMAC) will provide additional information to DEP for use in making the PAR's. Data will be provided in the form of an ingest-phase data set because time is short. wouxmc 86
.Mastone station 1997 Mume andinges6on Pattway Evaluated Exercise-August 21, October 6, 9,10,1997 .My 31,1997 Revision Objective 27. INGESTION EXPOSURE PATHWAY - DOSE PROJECTION AND PROTECTIVE ACTIONIMPLEMENTATION Demonstrate the capability to implement protective actions for the ingestion exposure pa Demonstration Critaria:
- 1. The off-site response organization (ORO) has adequateinformatie aiutable on food and water supplies as well as milk, food, and agricultural products within the ingesdon exposure pathway EPZ for the implemamatian ofprotective actions.
- 2. Appropdate pre-printed ingestion exposure pathway protective action infonnation and instrucdons are available for rapid reproduction and distribution to designated individuals and businesses.
- 3. Appropriate measures and strategies are developed for implementing protective action decisions for contaminated water and food, milk, and agricultural production.
- 4. All activities described in these demonstration criteria are carried out in acco the plan unless deviadons are provided for in the extent of play.
Entent ofPlay - Generst All activities associated with the development ofinformation regarding water and food supp and food, muk and agricultural production within the ingestion exposure pathway EPZ for implementation ofprotective actions will be completed as in an acmal ernergency. All activities associated with the selection ofpre-pdnted information and instructions on inge - ) exposure pathway protective aedons are available for rapid reproduction and distribution to designated individuals and businesses will be completed as in an actual emergency. All activities associated with the development of appropriate measures and strstegies for implementing protective action decisions for con *aminated water and food, milk, and ag products will be completed as in an actual emergency. Development ofmeasures and st for implementation ofingestion pathway protective actions wiu be demonstrated during e play by formulation ofprotective action messages to the general public and food producers and processors. For example, instructional and educational messages on ingestion pathway measures wiD be developed for broadcast. Although actual broadcast ofmessages is not wn. Demonstration ofthis objective by responsible state agencies will include selection of appropria instructional material to be printed and distributed within the ingestion pathway EPZ at the time ofthe emergency. "NOC 87 7 ,g4 -T ..g; ', r v, Y I ..ur. 9 =T = - *""~'r- ' ' ' * " ~ ' ' ~ ~ * ' .c ,,,..- ~<
Ln-t 2:.u.. a w Extent ofPlay .Minstone Staban 1997 Mume andIngestion Pathway Evaluated Exercise-August 21, October 9, 9,10,1997 .lufy 31,1997 Revision l State agencies will demonstrate the capability to control, restrict, or prevent distnhtion of contaminated food stuffs by administrative orders issued through health or agricultural agencies. Exercise play will include demonstration ofinter-organizational conununications and coordination rvguired to imptoment protective actions. Actual field play ofimplementation activities, such as communications and coordination with a8encies responsible for enforcing food controls within the ingestion pathway EPZ, may be sunulated. While these activities will be demonstrated, communications with food producers and processors may be nimntated. ExterLaflins__$ntttit 1 On Wednesday and Thursday, October 8 und 9, (and Friday October 10 if necessary) 1997, implementation plans will be demonstrated to carry out PAD's. These activities include: Development of emergency information messages to be issued to agencies responsible for ensuring the safety of the affected food stuffs, l press coniss%, distribution of pre-printed information to the public (this will be a tabletop discussion), individual agency orders prepared and issued to staff, and development of maps showing affected locations. i 1 { 1 1 seuxTaoc 88 ~~
-AGEstone Stahon 1997 Plume avutIngeshon Pathway Evolunted Exemine-o o August 21, October 8, 9,10,1997 My 31,1997 Revision lObMd+e28. RELOCATION, RE-ENTRY, AND RETURN DECISION MAKING l Demonstrate the capability to develop decisions on relocation, re entry, and return Demonstration criteria-
- 1. Areas requiring relocation of the public are identi5ed by comparing simulated measurements to decision criteda.
- 2. Decision criteria and strategy are followed in decisions to allow re-entry to the controlled areas
- 3. Return recommendations are developed.
- 4. Decisions are made regarding assistance to individuals affected by the emergency.
- 5. Decisions are coordinated with other organizations.
- 6. All actrvities described in these demonstration criteria are carried out in accordance with the plan unless deviations are provided for in the extent of play.
Estent of May-General All activities associated with the identification of areas requiring relocation by comparing simulated measurements to decision crneda will be completed as in an actual emergency. Controllers will provide simulated data developed as part of the scenado to Geld monitodng teams and laboratories as appropdate. DEP's done assessment group will receive data from the laboratories or the Geld teams and make assessments based on those data. Under the standard approach, field samples ofvegetation a'nd soil will be sent to the laboratory for analysis as demonstrated under Objective 24. The dose assessment group will demonstrate the capability to use simuisted data from the laboratory to calculate the exposure rate conversion factors. The group will also demonstrate the capability to use gamma exposure rate data measurementa from the field after the plume has passed. In addition, a map will be generated 1 abowing areas where population relocation is required. Under the optional approach, the dose assessment group will demonstrate 'the use of data on Geld measurements ofgamma exposure rates aAer plume passage and the pre-determined samma j exposure 1o plot the WA'y of the stea from which the population will be relocated on a map. Development of the decision criteda and strategies that are followed to allow re-entry into controlled areas will be accomplisted in a group settmg with representatives of all major organizations. Decisions will be made regarding the location ofcomrol pointa and policies regarding control will be explained. Pre-primed forms will be presented and explained. k esemermoe 89 [ q g ] [M e Y'- k~' ,--] . k 8 b _,,g-as*w--
E z w dhi s w arn~~f& n J %: a t xx w a, -www a_ .htMstone Station 1997 Plume and Ingeston Pathway Evaluated Exercise-August 21, October 8, 9,10,1997 July 31,1997 Revision DEP will dispatch two two-person relocation Seld teams. Each team will demonstrate sampic and data acquisition at one location. These data will be the basis for relocation decision making. Development of the decision cdteria and strategies that are followed to allow re-entry into controlled areas will be accomplished in a group setting with representatives of all major organizations. Decisions will be made regarding the location of control points and policies regarding control willbe evphinad Responsible agencies will demonstrate the capability to use the standard or optional approach and the simulated environmental measurements provided by the centroller to identify the location of the crea boundades to which retum is permitted. Environmental measuremcat data should be developed as part of the scenado. Demonstration of the decision making regarding assistance to individuals who are affected by the emergency will be accomplished in a group setting by representatives of all major organizations. The conditions facing individuals will be determined by decisions made under the above cdteria. Discussions will be held regarding the actions that will be needed, prioritics, and the processes for implementation. Demonstration of the coordination of decision making will be accomplished in a group setting by repmsentatives of all major organizations. Resources in the plans for a**ietanet concurrence, and information transfer will be identified, and availability of methods for communications of these activities will be confirmed. Extent of Ptsy-Specific Based on fic!d survey infonnation, decision makers will determine the relocation criteria. De corresponding isodose rate line will be drawn on appropriate maps. The area ofinterest will be discussed in regard to the effect on the public and special population groups. Population estimatea, relocation time estimates (which are DEP responsibilities), host community requirements, and traf5c control will be discussed. wortxTooc 90
4 -AQstone Sta00n 1997 Pfume and Ingestion Pathway Evaluated Exerstse-August 21, O@ber 6, 9,10,1997 July 31,1997 Revision Objective 29. RELCCATION, RE EhmY, AND RETURN. IMPLEMENTATION Demonstrate the capability to implement appropriate measures for relocation, re-entry, and return. Extent of Play - General Implementation actions will be demonstrated through internal meetings, briefmas, discussions, and by communications and coordnation with other emergency organizations and support agencies. This demonstration is effectively accomplished in a group setting with representatives of all major organizations working together to review dose projection and relocation issues and implementation proceduret Actions required for implementation of decisions will be demonstrated through di.wussions with EOC personnel. Primary demonstrated exercise activitics would invoke communications and coordination. Messages regarding procedures for=== control to and from the restricted zone will be transnitted from decision makers to the agencies and other organizations involved in implements: ion. It is not weatay to transmit the messages to the public. Communications systems among emergency organh=Hons will be discussed. Field activities related to re-entry need not be demonstrated. All relocation, re-entry, and return implementation actions will be demonstrated through internal meetings, briefings, diseassions, and by communications and coordination with other emergency organizations and support agencies. The demonstration is most effectively accomplished in a group setting with representatives ofall major organizatio,ns working together to review dose projections, relocation and re-emry, and return issues and develop implementation procedures. Extent of Play-Specific implementation plans for establishing a restricted zone will be developed with the coordination of affected local officials. These of5cials, together with state agency heads, will implement these plans through tabletop discussion. wenxt. ooc 91 ) i [ ,,-,,,.-.._m. . _._ _ m m, _, m.m., m. m._
gird" r.A.. g.w,9 r,; i.La4n.s yy. m. ;,..;.aa w..,.. a A* ,,im 'a.d. ~.,..... a-......- r .,g, 6. m -MRdone Station 1997 F4ame andIngestion Pathway Evaluated Exercise-August 21, Odober 6, 9,10,1997 . luff 31,1997 Rewston List of Objectives not demonstrated for this Exercise N hhN-N)h!Nh)hbhNbkN kkkNhb3$5hhk bib 30 Cominuous,24-Hour Suhg 31 Off-Site Support for the Evacuation of On-Site Personnel 32 Unannounced Exercise or DrW 33 Off-Hours Exercise or Drill 34 Licensee Off-site Response Orgamzations l i maxim 92 41#** IE
l DRAFT August 14,1907 Estent ofPlayfor CompensatoryPlan In the event that a community should not be able to panicipated in an exercise or emergency situation, the State would execute the requirements necessar) t,o assure public safety. During the August 21,1997 Millstone exercise, the objectives for completion of the compensatory plan would be accomplished at three locations: the Office ofEmergency Management Area Office; the State Emergency Operations Center (EOC); and the mobile command post. ASSUMPTIONS: Once it becomes obvious that a community is unable to participate, the OEM Area Coordinator would notify the State EOC, where the decision to activate the Compensatory Plan would be made. Three controller injected messages will be used as a tool to show the process of obtaining additional transportation requirements. Mobile Command Post van will be pre-positioned outside of the Montville State Police e Barracks. Since the mobile command post is not a hardened EOC, displays will be limited to 8 1/2" by 11" sizes or information which is faxed from the State EOC as needed. The State Department ofHealth Services will simulate (their normal task of) notifying health facilities and hospitals in the affected zones. If they were informed of a transportation request beyond a facilities' resources - in the non-participating community only - they would notify the Transportation Resources Manager, located in the State EOC directly rather than refer the facility to the local community Emergency Management Director. ACIIONS 1T LOCATIONS. The evaluator should see the following objectives accomplished at these locations: State Emereenev Operations Center:
- 1. Demonstrate the ability to communicate with the Mobile Command Post and Office of Emergency Management Area Coordinator Office.
93 ... A.., c ,4 ..4..
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- 2. In the event of a public protective action the State Police will simulate the procedures necessary to provide personnel resources
- 3. Demonstrate the ability to provide supplemental public information to the non-participating community through news releases and/or Emergency Alert System (EAS) messages, if necessary.
Area Coordinator's Omce;
- 1. Demonstrate communications between State EOC and mobile command post.
- 2. Demonstrate the ability to coordinate the back-up siren procedures.
- 3. The Area Coordinator will direct that additional resources be (simulated) dispatched to the Transportation Staging Area (TSA) at the Rocky Hill Staging Area to be ready to assist the non-participating community.
- 4. The non-participating communities' special needs individuals list will be shown to the evaluator. A few of the special needs individuals on the list will be (simulated) contacted and additional resources that could be used to assist this erTort will be discussed.
- 5. Relay special needs transportation requests / requirements to the State Transportation Resource Manager (State EOC).
- 6. Simulate the contact of community Superintendent of Schools, if school is in session.
- 7. Simulate contacting the designated Host Community of the situation.
Mobile Command Post:
- 1. Demonstrate the ability to communicate with State EOC(State Police liaisons) and Area Coordinator Office.
- 2. The Mobile Direction & Control unit Team Supervisor will simulate the dispatch of State Police Troopers to the non-participating community for traffic control.. (Mobile Route Alerting (PA systems) will be discussed as a back-up system in the event that the public alerting siren systems fail to be activated.
- 3. Show ability to provide a radiological briefing and hand out dosimetry to one trooper.
mpsor.d
94
APPENDIX 4 EXERCISE SCENARIO This appendix contains a summary of the simulated sequence of events - Exercise Scenario - which was used as the basis for invoking emergency response actions by OROs in the Millstone Nuclear Power Station Plume Exposure Pathway exercise on August 21,1997, and the Ingestion Exposure Pathway exercise during the week of October 6,1997. This exercise scenario was submitted by the State of Connecticut and approved by FEMA Region I on July 31,1997. During the exercise, controllers gave " inject messages", containing scenario events and/or relevant data, to those persons or locations who would normally receive notification of such events. These inject messages were the method used for invoking response actions by offsite response organizations. SCENARIO
SUMMARY
1 (Note: The times indicated below are approximate and reflect the times which had been anticipated from the planned scenario. Due to problems with the simulator at the start of the plume exposure pathway exercise, the actual times during the exercise were somewhat later than those indicated below.) Day 1 - Plume Exposure Pathway Exercise: 0800 Exercise commences. 0810 Fire in the emergency diesel generator room disables the generator. 0820 An Alert should be declared. 1020 Bus 14F failure results in the generation of a reactor scram signal. Reactor shutdown is successful. 1035 A Site Area Emercency should be declared. I140 Large break LOCA and subsequent fuel damage occurs. 1215 Bus 12E fails and valve AC-8 opens. Radiological release is initiated. 1225 A General Emercency should be declared. 1300 Emergency repair team closes valve AC-8 and the release is terminated. 95 3.. EJ T.:
- . ;..... + ;.
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f l 1430 Exercise play (plume pathway) is terminated. Day 2 -Ingestion Exposure Pathway Exercise: At this stage in the scenario it is assumed to be 24 hours after the radiological release to the environment has been terminated. It is assumed that radioactive depositions to the 50-mile area and the plume have been completely dispersed. + 1 l l l 96
- #8:cg\\
UNITED STATES p i NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30se6 coM %,,9 M June 4, 1998 Mr. Martin L Bowling, Jr. Recovery ONicer-Technical Services Northeast Nuclear Energy Company clo Ms. Patricia A. Loftus Director-Regulatory ANairs P. O. Box 128 Waterford, CT 08385
SUBJECT:
MILLSTONE NUCLEAR POWER STATION EMERGENCY PLAN, REVISION 24 1 SAFETY EVALUATION ( TAC NOS. MA0838, MA0839, AND MA0840)
Dear Mr. Bowling:
By letter dated December 30,1997, Northeast Nuclear Energy Company submitted Revision 24 to the Millstone Nuclear Power Station Emergency Plan requesting the NRC staffs review and approval to resolve concems raised concoming the Site Emergency Plan as documented in Inspection Report Numbers 50-245/97-81,50-336/97-81, and 50-423/97-81. Subsequently, the initial submittal was updated by letters dated March 24, April 15, and May 13,1998, which included changes 1 and 2, and revised change 2, respectively, to the Site Emergency Plan. The NRC staN has reviewed the requested changes to the Site Emergency Plan and has determined that the Millstone Nuclear Power Station Emergency Plan, Revision 24, provides an adequate planning basis for an acceptable state of onsite emergency preparedness in accordance with the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50 and is, therefore, acceptable. This completes all NRC staff actions related to the referenced TAC numbers. I Sincerely, c/ Phillip F. McKee Deputy Director for Licensing Special Projects ONice Office of Nuclear Reactor Regulation Docket Nos. 50 245,50-336, and 50 423
Enclosure:
Safety Evaluation cc w/ encl: See next page 'M M 3p __ _
Millstone Nucle r Power Station Unit 2 oc-Ullian M. Cuoco, Esquire Mr. F. C. Rothen Senior Nuclear Counsel Vice President - Work Services Northeast Utilities Service Company Northeast Utilities Service Company P. O. Box 270 P. O. Box 128 Hartford, CT 06141-0270 Waterford, CT 06385 Mr. John Buckingham Emest C. Hadley, Esquire Department of Public Utility Control 1040 B Main Street Electric Unit P.O. Box 549 10 Uberty Square West Wareham, MA 02576 New Britain, CT 06051 Mr. John F. Streeter Mr. Kevin T. A. McCarthy, Director Recovery Officer - Nuclear Oversight Monitoring and Radiation Division Northeast Utilities Service Company Department of Environmental Protection P. O. Box 128 79 Elm Street Wate:Tord, CT 06385 Hartford, CT 06106-5127 Mr. David B. Amerine Regional Administrator, Region i Vice President - Human Services U.S. Nuclear Regulatory Commission Northeast Utilities Service Company 475 Allendale Road P. O. Box 128 King of Prussia, PA 19406 Waterford, CT 06385 First Selectmen Mr. Allan Johanson, Assistant Director Town of Waterford Office of Policy and Management Hallof Records Policy Development and Planning 200 Boston Post Road DiviMon Waterford, CT 06385 450 Capitol Avenue - MS# 52ERN P. O. Box 341441 Mr. Wayne D. Lanning Hartford, CT 06134-1441 Deputy Director of Inspections i Special Projects Office Mr. M. H. Brothers 475 Allendale Road Vice President-Operations King of Prussia, PA 19406-1415 Northeast Nuclear Energy Company P.O. Box 128 Charles Brinkman, Manager Waterford, CT 06385 Washington Nuclear Operations ABB Combustion Engineering Mr. J. A. Price 12300 Twinbrook Pkwy, Suite 330 Director-Unit 2 Rockville, MD 20852 Northeast Nuclear Energy Company P.O. Box 128 Senior Resident inspector Waterford, CT 06385 Millstone Nuclear Power Station clo U.S. Nuclear Regulatory Commission P.O. Box 513 Niantic, CT 06357
Millstone Nuclear Power Station Unit 2 oc: Mr. B. D. Kenyon (Acting) Attomey Nicholas J. Scobbo, Jr. Chief Nucler Officer-Millstone Ferriter, Scobbo, Caruso, Rodophele, PC Northeast Nuclear Energy Company 1 Bea. con Street,11th Floor P.O. Box 128 Boston, MA 02108 Waterford, CT 06385 Mr. J. P. McElwain Citizens Regulatory Commission Recovery Officer-Millstone Unit 2 ATTN: Ms. Susan Perry Luxton Northeast Nuclear Energy Company 180 Great Neck Road P. O. Box 128 Waterford, CT 06385 Waterford, Connecticut 08385 Deborah Katz, President j Citizens Awareness Network P. O. Box 83 Shelbume Falls, MA 03170 The Honorable Terry Concannon Co-Chair Nuclear Energy Advisory Council Room 4035 Legislative Office Building Capitol Avenue Hartford, CT 06106 Mr. Evan W. Woollacott Co Chair Nuclear Energy Advisory Council 128 Terry's Plain Road Simsbury, CT 06070 Little Harbor Consultants, Inc. Millstona -ITPOP Project Office P. O. Box 0630 Niantic, CT 06357-0630 Mr. Daniel L Curry Project Director Parsons Power Group inc. 2675 Morgantown Road Reading, PA 19607 Mr. Don Schopfer Verification Team Manager Sargent & Lundy 55 E. Monroe Street Chicago,IL 60603 --em~~4 ,ee.w~*=e "~ ~ " " ' - + " * - ' - - ~ ~ ' - ~ ' ' ~"" "~ '
at: p unirso sTArms g NUCLEAR HEGULATORY COMMISSION WAsNINeToN, D.c. 300064001 1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE MILLSTONE NUCLEAR POWER STATION EMERGENCY PLAN. REVISION 24 MILLSTONE NUCLEAR POWER STATION. UNIT 31. 2. AND 3 DOCKET NOS. 50-245. 50-336. AND 50-423
1.0 INTRODUCTION
By letter dated December 30,1997, the Northeast Nuclear Energy Company (the licensee) submitted Revision 24 to the Millstone Nuclear Power Station (MNPS) Emergency Plan (the Plan) for the NRC's review and approval in the letter, the licensee stated that the revision was in accordance with 10 CFR 50.54(q) and did not decrease the effectiveness of the Plan, and, as revised it continued to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. However, the licensee requested NRC review and approval of Revision 24 to resolve concems raised over the licensee's emergency plans as documented in NRC Inspection Report Numbers 50 245/9741,50-336/97-81, and 50-423/9741. By letters dated March 24, April 15, and May 13,1998, the licenses submitted Change 1, Change 2, and revised Change 2, respectfully, to the Plan. These changes were updates to Revision 24 submitted on December 30,1997.
2.0 BACKGROUND
The licensee implemented Revision 22 of the Plan in June 1997. Revision 22 was issued as a complete revision of the Plan, in August 1997, the licensee implemented Revision 23 of the Plan to correct problems the licensee had subsequently identified in Revision 22. During an inspection conducted in August 1997, as documented in NRC inspection Report Numbers 50-245/9741,50-336/9741, and 50-423/9741, the inspectors reviewed selected portions of Revisions 22 and 23 of the Plan. The inspectors concluded that, with the implementation of Revision 22, the licensee made changes to the Plan, which decreased its effectiveness. The changes were made without Commission approval. In some instances, the MNPS Emergency Plan, as changed, rio longer continued to meet some of the standards of 10 CFR 50.47(b), and some of the requirements of Appendix E to 10 CFR Part 50. The inspectors identified several items that were omitted from Revisions 22 and 23. The licenses stated that Revision 24 provided enhancements to the Plan, and requested NRC's review and approval of j the Plan. The staff evaluated Revision 24 of the Plan against the standards of 10 CFR 50,47(b) and the requirements of Appendix E to 10 CFR Part 50 using the guidance provided by NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, dated November 1980, and the guidance contained in NUMARC/NESP-007, Methodology for Development of Emergency Action i M W 02 % fy,. _ _
s -o 2-Levels," Revision 2, dated Jnuary 1992. The staff also considered in the review process the information contained in NW EG-1031, Supplement No. 4 " Safety Evaluation Report Related to the Operation of Millstone Nuclear Power Station, Unit No. 3," dated November 1985. 3.0 DISCUSSION AND STAFF EVALUATION 3.1 Asslanment of Responsibility (OroanizationalControl) The Plan describes the on-shift and augmented organizations that are intended to be part of the overall response organization in the event of an emergency at the Millstone Nuclear Power Station. The Plan identifies a specific individual by title who is in charge of emergency response and includes 24-hour a day coverage. In support of the normal shift organization, the licensee maintains the capability to provide additional support, including senior personnel, facilities, equipment, and financial resources. Local agency and support services are identified as well as copies of letters of agreement listing support organization responsibilities and arrangements. The staff has reviewed the Plan and concludes that the planning standard regarding responsibilities for emergency response is adequately addressed. 3.2 Onsite Emeroency Oroanization The Plan describes the normal plant omanization and the Station Emergency Responso Organization (SERO). The SERO consists of on-shift staff, on-call staff (30- to 60 minute response), and subject-to call staff (8-hour response with provision for 90 minute response for positions as determined necessary). The licensee has provided a description of the emergency response positions. The Plan identifies the Director of Station Emergency Operations responsibilities, including emergency classification, offsite notifications, command and control, and authorization of onsite protective actions. The planning standard regarding onsite facility licensee responsibilities for emergeng response is adequately addressed in the Plan. 3.3 Emeroency Response Support and Resources The licensee has arrangements with local support agencies for ambulance services, hospital facilities, fire fighting assistance, and radiological laboratories, which are identified in the Plan. Letters of agreement are found in Appendix B of the Plan. The planning standard regarding emergency response support and resources for emergency response is adequately addressed in the Plan. 3.4 Emernency Classification System Appendix I of the Plan provides an emergency classification and emergency action level scheme, including initiating conditions associated with possible events at the Millstone Nuclear Power Station that would result in the declaration of a notification of unusual event Alert, Site Area Emergency or a General Emergency. Specific instruments, parameters, and equipment conditions are detailed in the Station Emergency Assessment procedure Emergency Plan implementing Procedure (EPIP) 4400.
) l The Plan adequately addresses the planning standard for emergency classification and action levels for the Millstone Nuclear Power Station. 3.5 Notir, cation Methods and Pracadmes The Plan specifies methods to notify' State and local govemments officials of emergency events within 15 minutes, and the NRC subsequently, of an emergency classification. Simultaneous notification of State officials and site augmentation personnelis outlined. The content of notification messages is specified, and provisions are made for verification of notifmetions. The Plan adequately addresses the methods and procedures for notification of emergency response personnel, State, local, and Federal organizations. ~ 3.6 Emeroency Communications The Plan specifies that systems are in place for prompt notification of the SERO and.offsite authorities. Backup communications are available using commercial telephone lines. Two-way radios are available in-plant between the control room and irkplant teams. A public address system is also available irkplant to link the Technical Support Center, Operational Support t Center, control room, and in-plant teams. The NRC will be notified via the emergency notification system. Communication with fixed and mobile medical support facilities is described. The planning standard for prompt communications among response organizations is adequately addressed in the Plan. 3.7 Public Eductiion and information i Under the Plan, specific emergency instructions for residents and the transient population are distributed annually through the telephone directory serving effected communities. A media information program is also provided for annually. The planning standard for public education and information is adequately addressed in the Plan. i 3.8 Emeroency Facilities and Eauipment The Plan identifies tne Control Room, Technical Support Center / Operational Support Center (TSC/OSC), and OSC Assembly Area as the onsite emergency response facilities. There is a near-site Emergency Operations Facility (EOF) described. Arrangements have been made to accommodate offsite officists at the EOF. The station has various appropriate monitoring systems as needed for the evaluation of the condition of plant systems, meteorological conditions, seismic activity, and radioactive materials. The provisions for, and the maintenance of, emergency equipment and supplies are established. The planning standard for adequate emergency facilities and equipment to support an emergency response effort is adequately addressed in the Plan. 3.9 Accident Assessment The Plan calls for onsite systems and equipment to allow for radiological accident monitoring and assessment of radiological conditions, and the performance of dose projections. The Plan
4 provides an example of the emergency action levels (EALs) that are based on the methodology outlined in NUMARC/NESP-007. The specific details of parameter values for the EALs are found in Station Emergency Assessment Procedure, EPIP 4400. The planning standard for methods, systems and equipment to be used in accident assessment and radiological monitoring is adequately addressed in the Plan. 3.10 Protective Response The Plan outlines protective actions to be taken to wam personnel of hazard conditions, call for the relocation of onsite staff when necessary, maintain accountability of emergency responders, and limit site access when needed. The Plan has a goal to complete accountability of onsite personnel within 45 minutes. The Plan establishes a mechanism for recommending protective actions to State and local authorities. The planning standard for protective actions is adequately addressed in the Plan. 3.11 Radioloalcal Exposure Control The Plan establishes responsibility for emergency radiological protection activities for plant staff and support personnel. Exposure limits and authorization required for exceeding limits are defined. Contamination control measures and provision for decontamination are established. The planning standard requidng means to control the radiological exposure of emergency workers is adequately addrested in the Plan. 3.12 Medical and First Aid Sunoort First aid and other medical supplies are provided for at the plant. Shift personnel, trained in first aid, are available on a 24-hour per day basis. The Plan contains arrangements for transportation of potentially contaminated injured individuals to offsite medical facilities. Two hospitals are identified in the Plan for the treatment of these individuals. The planning standard for medical services is adequately addreshd in the Plan. 3.13 Recovery and Reentry Plannino The Plan contains genersi criteria for determining when to establish recovery operations. The Plan identifies the appropriate authority by position and title for initiating recovery actions. The planning standard for general plans for recovery and reentry is adequately addressed in the Plan. 3.14 Exercises'and Drills it is specified in the Plan that an annual exercise of the Plan will be conducted. The Plan specifies that annual drills will be conducted in the following areas: medical, radiological monitoring, health physics, and post accident sampling. The Plan calls for the testing of communication links to State and local govemmental authorities, among onsite emergency response facilities, and with the NRC. l
O 4 i 4 The planning standard for periodic exercises is adequately addressed in the Piar.. 3.15 Radioloolcal Ememency Remnse Trainina The Plan identifies a training program to ensure that personnel assigned to the emergency response organizations are trained prior to assuming emergency plan responsibilities and are retrained annually. The program covers basic as well as specialized tra;ning for those emergency response personnel with' specific assignments. Training for participating offsite agency personnel involved in emergency response is made available annually. The standard for radiological response training is adequately addressed in the Plan.. 3.16 MNPS Emeroenev Plan Development and Review The requirement for an annual review of the Plan, procedures, practices, training, equipment, readiness testing, drills and exercises, letters of agreement, and adequacy of interface with offsite officials is specified in the Plan. An annualindependent review of the Plan is also to be conducted. Responsibilities for maintaining the emergency response facilities, plans and procedures, staffing the emergency response organization, and training of responders, are specified in the Plan. The planning standard for plan development and review is adequately addressed in the Plan.
4.0 CONCLUSION
S The NRC staff's review of Revision 24 of the Millstone Nuclear Power Station Emergency Plan found that the Plan adequately addressed each of the planning standards identified in 10 CFR 50.47(b). The requirements of Appendix E to 10 CFR Part 50 are sufficiently encompassed in the Plan as it has been revised. The items identified as having been omitted from the previous revision have been included in Revision 24 where appropriate. The criteria of NUREG-0654 i have been adhered to as described in Appendix G of the MNPS Emergency Plan. The emergency action levels are consistent with the methodology outlined in NUMARC/NESP-007. On the basis of its review of Revision 24 of the Millstone Nuclear Power Station Emergency Plan, the staff concludes that the Plan provides an adequate planning basis for an acceptable state of 1 onsite emergency preparedness in accordance with the requirements of 10 CFR 50.47(b), and Appendix E to 10 CFR Part 50 and is, therefore, acceptable. Principal Contributor: Daniel M. Barss Date: June 4,1998
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1 Che as 26 NRC 383 (1987) CLi4712 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMM:SSION COMMIS$10NERS: a Lando W. Zech, Jr., Chairman Thomas M. Roberts Frederick M. Bernthat Kenneth M. Carr Kenneth C. Rogere Docket No. 54322 OL 3 in the Matter of (Emergency Planning) LONG ISLAND 1JOHTING COMPANY ($horeham Nuclear Power Station, November 5,1987 ]' Unh 1) E WY V The Commission reverses ALAB-832, 23 NRC 135 (1986). insofar as it F 't - allowed the admission of two contentions for evidentiary hearing on whether the Shoreham Plume Exposure Pathway Emergency Planning Zone should be expanded by a few miles to: (1) provide an adequate base for the expansion 1 of emergency response effons beyond the EPZ in very severe accidents; and (2) minimize the occunence and effects of spontaneous evacuation from outside the EPZ. De Commission affums the ALAB 832 remand to the Licensing Board for further consideration of evacuation plans for hospita!s in the Shoreham EPZ. l EMERGENCY PLAN: EMERGENCY PLANNING ZONES (SIZE) De NRC/ EPA task force report (NUREG.0396), which formed the basis for the "EPZ" concept in NRC's emergency planning regulations, indicates clearly that the margins of safety provided by the recommended 10 mile radius were not calculated in any precise fashion but were qualitatively found adequate as a maner of judgment. EPZ shape and size can be somewhat different than the 10 mile circular radius implies without compromising emergency plarming goals, s j m f asemas L \\ S?lllls44 2s;v1
.~ j as evidenced by the following statement in the report " judgment... will be used in deu.rmining the precise size and shape of the EPZs considering local conditions such as demography, lopograph, and land use charactentics, access routes, localjurisdictional boundan arrangements with the nuclear facW ttiberator for noti 6casson and response assistance."f3cc 10 C.F.R. 6 50.47(c)(2) (1987). i EMERGENCY PLAN: EMERGENCY PLANNING ZONES (SIZE) e Nothing in NUREO 0396 or in any part of the emergency planning rulemak-ing record compels a 6nding that EPZ adequacy is especially sensitive to where exactly the boundary falls, and any such conclusion would seem to be at odds with the overall thrust of the report. In particular, the NUREG 0396 analysis indicates that adequate protective measures"in the context of emergency plan-ning is not a precisely de6ned concept. I EMERGENCY PLAN: CONTENT (PROTECTIVE MEASURES) NRC emergency planning requirements do not require that an adequate plan achieve a preset minimum radiation dose saving or a minimum evacuation time 1. for the plume exposure pathway emergency planning zone in the event of a [ I. serious accident. Rather, those requirements are designed to achieve reasonable 2 L~ - - a $ and feasible dose reduction under the circumstances; what may be reasonable pu.i or feasible for one plant site may not be for another. Long Island ughting Co. (Shoreham Nuclear Power Station, Unit 1), CLl4613, 24 NRC 22, 30 (1986). e EMERGENCY PLAN: EMERGENCY PLANNING ZONES (SIZE) Implicit in the concept of " adequate protective measures" is the fact that crnergency planning will not eliminate, in every conceivable accident, the possibility of serious harm to the public. Emergency planning can, however, be expected to reduce any public harm in the event of a serious but highly unlikely accident. Given these circumstances, it is entirely reasonable and appropnate for the Commission to hold that the rule precludes adjustments on safety grounds to the size of an EPZ that is "about 10 miles in radius." In the Commission's view, the proper interpretation of the rule would call for adjustmeru to the exact size of the EPZ on the basis of such straightforward administrative consideratioru as avoiding EPZ boundanes that run through the middle of schools or hospitals, or that arbitrarily carve out small portions of governmental jurisdictions. Tbe goal { \\ a k l
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is merely planning simplicity and avoidance of ambiguity as to the locadon of the boundaries. EMERGENCY PLANNING: EVACUATION TIME ESTIMATES Even though sheltering will quite likely be the preferred protective action for EPZ hospitals in the event of a serious accident at Shoreham, evacuation should not be prejudiced by the failure to plan in advance. Appendix E to 10 C.F.R. Pan 50 requires evacuation time estimates for the EPZ without exceptions for special facilities such as hospitals. Moreover, hospitals, as a kind of special facility, are speci6cally mer.tioned in the principal guidance document in this 6 eld, NUREG 0654, and there is no suggestion in this guidance that hospitals are to be treated specially as exempt from the evacuation planning requirement that applies to other segments of the population within the EPZ. EMERGENCY PLAN: CONTENT (PROTECTIVE MEASURES) A Commission conclusion that NRC regulations require Applicant to ful611 the same emergency planning obligations for Shoreham with regard to hospital evacuadon as those imposed by the Licensing Board in connection with other like segments of the EPZ, such as nursing / adult homes, does not necessarily mean that the applicant's emergency plan is inadequate with respect to hospitals. Under 10 C.F.R.150.47(c)(1), the Licensing Board could still approve the utility plan &..+.p =-=:u .4 if it found that the de6ciencies related to the hospitals were not signi6 cant for % w,,. Sho h MEMORANDUM AND ORDER In ALAB.832,23 NRC 135 (1986), the Shoreham Appeal Board reversed and remanded three issues, among others, to the Licensing Board: the Licensing Board's refusal to permit an evidentiary heartng on whether the Shoreham Plume Exposure Pathway Emergency Planning Zone (EPZ) should be expanded by a few miles to provide an adequate base for ad hoc emergency response efforts beyond the EPZ in very severe accidents (Contention 22.B); the Board's refutal to permit an evidentiary hearing on whether the EPZ should be expanded by a few miles to minimize the occurrence and effects of spontaneous evacuation from outside the EPZ (Contention 22.C); and the Board's approval of the applicant's provisions for hospital evacuation In an Order dated September 19,1986 (unpublished), the Commission took review of these three issues and requested briefs from the panies. ( MS P 1 M a
y On review, Long Island Lighting Company (LILCO) and the Staff suppon the Licensing Board's decisions on these issues and oppose the Appeal Board's decision. The Intervenors take the opposi. view. We conclude on the EPZ issws that while the decision of the Appeal Board is a reasonable one in light of the available, but limited, adjudicatory precedent, additional Commission guidance is needed. After careful review of the history of our regulations, me conclude that Contentions 22.B and 22.C consutute challenges to these reguladons. Since Intervenors have declined to cast their contendons in the alternadve as challenges to the rettulations under Iha 10 C.F.R. 5 2.753, litigation of these issues must be disallowed. As for hospital evacuation. *c agree with the Appeal Board that LILCO's plans do not fully satisfy NRC's emergency planning regulations. I. EPZ SIZE A.
Background
Section 50.47(c)(2) of 10 C.F.R. provides that, generally, the EPZ for power reactors shall be "about 10 miles" in radius, with the exact boundanes to be determined "in reladon to local ernergency respoiue needs and capsbilities as they are affected by such conditions as demography, lopography, land characteristics, access routes, and jurisdicuonal boundaries." LILCO's plume EPZ is about 10 miles in radius. In Contendon 22 a four-pan, ten-page (double-spaced) contention, Inter. e venors argued that the proposed LILCO plume EPZ was not large enough, for .[ Qom_1. i several reasons.' In subpart B, it was argued that a myriad of local condidons % Me-mandated a larger plume EPZ because, in a severe accident, LILCO mould not be able to adequately extend emergency response efforts outside the 10-mile area on an ad hoc basis. In subpan C, Intervenors argued that lo:a! conditions demanded an EPZ larger than 10 miles, most imponantly because massive spontaneous evacuation by those outside the EPZ would have two disastrous effects: Arst, residents of j the eastern end of Long Island would spontaneously eva:uate through the EPZ t to avoid being trapped, either passing through contaminated areas or impeding ~ evacuation from inside the EPZ; and second, spontaneous evacuation from west of the EPZ would impede evacuation of the EPZ. The Licensirig Board denied admission of these contentions on the ground that they chall:nged the Commission's generic determination of EPZ size, as 8 m==i er c na e e as see. em Appsik (sus piMWier) = som bus,een mid ones i l L
manifested in 10 C.F.R. I50.47(cX2).8 in dismissing Contention 22.B. the Li-censing Board noted the Commission's explanation of the 1980 amendments to the emergency planning rules, where the Commission stated that "[t]hese dis-tances are considered large enough to provide a response base that would support activity outside the planning zone should this ever be needed " Special Prehear-ing Conference Order Aug. 19,1983, at 10, guoting 45 Fed. Reg. 55,409, col. 2 (Aug.19,1980). The Board also explained that, contrary to the Commission's generic determination, Contention 22.B m assens. (in essensel. that advance plarwiing, as apposed so aaf Aac plannmg. is required beyimd she 10eile EPZ because or the sashi allsged *desunguishes chsrecurisues." To the enunt that this contenuon asseru that ad Aac ornergency susponse would be irnpossible. it snust be rejected as a challenge to { $0 47(c)(2). To the emient that it chauenges the IJtf0 plan in specinc matters, wir transiers populauan,inadequae voeds, adverse esather, etc.. ihese concerns have already been assened en other ocsuennans which we have admitted Order Ruling on Objections to Special Preheming Conference Order, Sept. 30, 1983, at 4. The Licensing Board rejected Contention 22.C for much the same reasons. In ALAB.832, the Appeal Board reversed she Board's disallowance of these contentions, reasoning that "these contentions do not appear to seek anything more than that to which section 50A7(c)(2) entitles intervenors: a determination of the ' exact size and configuration' of the EPZ based upon, p/ tafer alia, local conditions."8 On the ground that one set of facts might support more than one contention, the Appeal Board also rejected the Licensing Board's [,,
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T.'-f ' ' -* " * ? reasoning that because Intervenors were being permined to challenge the overall kw. adequacy of the plan to deal with spontaneous evacuation, the disallowance of ? Contention 22.B had no effect on Intervenors' ability to litigate the safety matters 9 at issue. /4.,23 NRC at 148. in taking review of the rulings on Comention 22.B. the Commission asked: (1) whether... the admission of Carmenian 22.B senpemissibly chatlenges the genene rulernakeg Andmg that a 10eDe EPZ will provide an adequase basis for asusfactory ad Aos emergency response beyond to rails should this be requared (ses d5 Fast Reg $5.406 col 2)(Augua 19,1930),8 and. i 8 spena! Prahanns Confeenas order. Aug 19.1983 6aryuhlashedk orde Eulans an otisseuens is spenal Prehmanns Centaranas order. sept 30.1983 (equhlashed) 823 NRC st 148 He= cur. ihe Appe! assed ressned traarvenari erynnes that um erJy les:umeis brrais en she mas of shs EFZ are thans brans enessend by lasal eundaueis bemanst, seed the Appel acord, the regulauens permat senaderuhen en); ef "maner at inesh as a snik er sus)...,* M at la9 m l. C7 aat et tal a n.77.
- Camnenmas order deind sept 19.1986 as 1. As send ebens, sha Cawtuamen maand an the stad Fedreef l
seg raar sauas eksi"these dananaus era enmdeed large annah as peerade a rumpanas hans that eeund euypet eauvity smaade the p1sanang sans should dus ese ha amaded
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1 P (2) e the easiest of Comenuon 22 C: (e) lwhetheil ehere is a logical conneaean between pawne EPZ sier and she abibty to seeolve problems associnand with possible spomaneous ewmananen, and (b)[whosherl the segutoGons somemplete that the possibibty of sponsaneous evemianon is s
- local amubuon" whieb shmand result m adjustments to en El'Z, ni i B.
Parties' Arguments Before tbt Comniission 1. Intervenor Arguments Imervenors assert that the contentions, far from challenging me regulations, merely seek to enforce them. Thus, Intervenors argue, the Appeal Board correctly acknowledged the importance of the generic considerations that led to the choice of the 10 mile guideline,s but most importantly recognized that "[nlotwithstanding these generic considerations,.., section 50A7(c)(2) goes on to direct that the ' exact size and configuration' of the plume EPZ 'shall be determined in relation to local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries.'"* Imervenors offer two main arguments on the interpretation of this regulation. First they argue that while spontaneous evacuation and lack of local government cooperation aren't listed it, the regulations as local conditions, the conditions listed are exernplary rather than exclusive. Second,Intervenors emphasize that j .,_ T ~ r 9 r" *: w.a ~ "the determination of the exact size and con 6guration of the EPZ must be made 'in relation to local emergency response needs and capabilities as they are affected by...'" local conditions. Brief at 13 (emphasis in Brier). The / concept of " local emergency response needs and capabilities," they continue, encompasses 1.!1.CO's alleged failwe to plan for spontaneous evacuation, an evacuation that will result directly from listed conditions such as the land characteristics of J.ang Island.' 7 hums genant emedesume an that "o) pnsamed damm fium mest asedoes emJd ass asemal Faden3 8 tPAoj does Ismis tsynd that shsianse foun the dealair ed Q) demand pienses wuhan 10 mais smald pouvide ,v a mehsaru.a1 hans fe espannen of suspanns asans nf thss basame emmsmmary
- ALAa e32,25 MitC et 143, meng EMo 0596 and WMG404
'S Nac et 145 In shmar asply ansf. Innsnenen shasse that 1Aco and en aien ene arpsamms is em commmam en are nu e i inne.sy addies g==ues she sem ene. out m. C==mmesi anums i. suvise. aarly anaf at 3 baarveers clasm that thsy don't susped to thans superusly eSend argummes, and thei che Commaman shundd as ammmear lhen Houses, emy senasesi. W eha Canmmmen unmes to emade shes snquesper arpaneses.the a shmJd eMe Isme=wnset e appensusy as suspend. In fan,housser.lananmose eswuns amady tuo page af sunt fesrunn-page suspaans is tems IACo4eaff espansues See amply ansf at 67. 'busneers add est ths lapsesasey of Causasen 21C a sensamed by su ammus !.asessg need's maassess shei s suiJd ammeer the eneri af lusal seedsume en aP2 esesL The asmuus sened sisted dist whahes or as l enemises euss embautai em ths m m. s emJd swumagens whaber." bases af the pueysphy of Lag laland, yM esseusase plansmg sisten en aspuessmans 14*enne aP2 sney em be adapais bennuss er es empnas of passes mands and to the ama af the aFZ eheemsg to ovemmets and hovas to de a by annues sungh das aP2." ) s SAP 8219. Is lac 401. 6t619 (19s2) IAco einsms that eus mass was bingatad a the inre et Consesse l 3,D (eineunum o en estem s gewissu.e eensa hamnus LJiro ham 6 t annadeed Ihs entus af epsesnams GCesemad) p 388 M R i i
p Rejecung charges that they challenge the regulations by seeking a 20 mile EPZ, or one that is " dramatically enlarged," Intervenors assert that what they acek is only what the regulations demand, i.e., an EPZ based on local conditions, whatever the size.s The Licensing Board had agreed with the Staff and LILCO that litigadon b of Contention 22.B required Intervenors to obtain a (2.758 caception to the rule prohibiting challenges to the regula'.jons, something Intervenors never sought. But, say Intervenors, Commission precedent includes cases requiring no exception for challenges to the 10 mile EPZ, cases relied on by the Appeal Board as well as Imervenors.' Even if LILCO, the Staff, and the Licensing Board are correct that only minor adjustments are permitted, Intervenors add, they were precluded from litigating for these adjustments. Reply Brief at 6. Finally, while claiming that the Commission did not take review of the Appeal Board holding in ALAB.832 that a utility only emergency response is a " local condition" to be considered in determining EPZ size, Intervenors assert in response to a L!1CO argument that the Appeal Board correctly decided this qu;stion. 2. Staff and ULCO Arguments L The Staff and LILCO oppose the admission of Conie'uions 22.B and C mainly , a y, p.ef,:;.:.u m = y on the ground that the contentions challenge the generic 6ndings underlying a ~ the Commission's determination that a 10-mile EPZ for power reactors is adequate to protect the public. The Staff and LILCO contest the Appeal Board's f conclusion that Contention 22.B was aimed at determining the exact size and i shape of the EPZ based on local conditions. Rather, they claim, it is a direct swaausuen thei est emew) and 23}f (utto has re6 led is psonds for bleshade is preves sparuansens eveemes from emmna esmaminaiad asure of sha 774 ene pansra, ally harmnig dism and ergedang awnsusum from she i Erz) Reply sner ei 9 'ne Laseweg Beard read ist utro en hash er thans,,seners l 8acah ULCO ed bearwenes one a _. _ dammen a ase Oms /v en aspport shar puenens sannanu e' ~~ j Cel(eam.s Kd.es Ce (san omote Niedser Omnevang sume. thes 2 and 3) C3.J 8310.17 NRC s28 I' s33 09:3) bue mes paus is she comtrasserfe deneng.en same er sw evangery plamans seguleuena a Nuumarus far **sure p&annes eis mamaru plamms Assibilary se develse a ressanshir ed Asc sempanas is theme eury sensis )se probsMlary sendous shmi enund ares the seesl pwhbc ** aarly anst ei s A21 ihey see. asy bearwuners, w e shanse to emplers ehrskar the ' sere plannag" propesad by U140 as e fas 'sufness' t ad has suffienou 'Saaatabry' to perms shs 'dswelarlseen er] e sensenaWs ed ase sumpanss** Ad 'The essi mind are Dade Pe==re Ce (Cainwte Nerlear Besuen. thuis I and 2). LAP 6637,30 NRC 933. ??9 89 090d). afd. A1Aa 113,23 NPC 39 0953), and PMadevins Essesw Ce osame omersung suman, thuu I and 2). lap-8s Id. 21 NRC 1219.1254 09451 agr"4 as setrieur pays. ALAa4% 23 Nhc 479. 492 s00 Ceamsmo se rewia abr6=sd. Andy at.1984 In mar were, thans esas prends only snesma! ouppen fe baanoven is seiden esas ses eks peeprisy of ehmaag ths seusnumw shalaeged hafere em Appen! Seasd hemuswer. the pension surmonuen an saaneenck ses f i emashed a tie thernasse., essenang shaiis persons seneueu enside and adjsses to su E.PZ bussedsry fuen knpe&ng owemuause frown enshes pas EP2. s ons mesusaary ashre to empend the E72 er as ponds addoenal warns een,et anade es ar2. In searea. ceaseems 21s ed 22C assa sei se aJy *ey *= ensnply ei* ens NRc"s sepavemens a to espond eis EP2. Time,saamrence esas mai eresiJr mypen naisroense' panamen. 349 E :: 2 L
J nr challenge to the Commission's determination that a 10 mile EPZ in all cases would provide a substantial base for ad hoc expansion of any emergency response. Staff Brief at 12; LILCO Brief at 3 4. As to Contention 22.C. the Staff and LILCO make three main points: first, that the contention challenges bi the generic determinations in 5 50.47; second, that the local conditions cited by Intervenors are not the type contemplated by the regulation; and third, that Intervenors' concerns were litigated before the Licensing Board in the context of other contentions.88 "Ihe Staff and LilfO contend that the rules contemplate clearly drawn EPZs, with minor deviations from the 10-mile radius where dictated by geographic fac-tors. To suppon these propositions, the Staff funhet argues that the Commission decided in its 1980 rulem4fng that: Pr Ace.insi protectin.uions are needed far EPZs,... it is those within this sanc for whom predetermined protective ecuans are needed in order to prevent esposure to airborne radionuttides, sud pesdeterrruned saions are not needed for those outside this acne.88 Funher, LILCO notes the conclusion of the NUREG 0396 task force relied upon h by the Commission in the rulemaking: ~ { n.,......... 'i -s , e- = ' 24 gem :4
- [Tli was the consatsus of the Task Form that emergency plans could be based upon g _. 1 1 a genene distance out of which predesermined saions oculd provide dose savings for F
any sud accideras Beyond this senenc distance it was concluded that actions sould be taken on an ad Aoc basis using the same coraidersuans that went anno the initial action p determsnations. [Thuil. the size of the EPZa need not be siis specific, las] emergency n, f planning needs seen to be best served by edgtirig uruform EPZ4 for initial ptanning studies for all bght eazer sanctors.-12 4 i Thus, LILCO argues, while obviously there are both generic and site specific j components to i 50.47(c)(2), the site specific component is merely a fine tuning l-mechanism such that "it makes sense to depan from a perfect circle in order to l' run the boundary down a prominent highway so that people will know clearly where the boundary is, and... to avoid bisecting a discrete population." LILCO Reply Brief at 2. To bolster the position that only geographical conditions were to be consid-ered, and then lead to minor adjustments, if any, LIlfO cites the NRC Staff's presentation to the Commission in 1980, where the Staff explained that the h factors to be considered were "' narrowed to a relatively small range,'" e.g., a E A-a -.~.- _ e.s. soview* ths Appeal saard nahng aaply aner at ll. s 88 sentf aner at is, a.ang es Fed sas ss.406 IAmt 19.1980). and NaC Pabry semismus e *?namnus amis far aaspese to N,sdans pues Aamdmas? ad Fed ass 61.1D tout 3.1979) 881JL.CD anar at 12 Is a.lf, geeneg NUnaoets at 16. E 7 s. 390 L
'r { l i "' major population center
- crossing the 10 mile boundary and ' abnormal topo-graphical situations, a very peculiar river valley.'" LILCO Brief at 5 n.6. Even t
4 in these " abnormal" sits.abons, Staff's intent was to adjust EPZ boundanes "'by .*yi[4 small amounts.'" 14. The Staff adds that "the cure forany EPZ related problem arising kom events 5 e taking place ouuide the EPZ is not to expand the zone, but to factor those mat-ters into the planning for the protective actions to be taken for those within the f 10 mile zone." 14. LILCO agrees, stating tha' the record shows that providing i accurate, consistent information to the public will minimize spontaneous evacu-ation, and that this is the remedy contemplated by the regulations. LILCO Brief at 10, citing rac(fic Gas and Electric Co. (Diablo Canyon Nuclear Power Plant. Uniu I and 2), LBP 82 70,16 NRC 756,779 (1982). 1%rther. even if spontaneous evacuauon is to be considered a local condition, they submit, it isn't the type of local condition that can cause adjustments in EPZ size, because the conditions contemplated in the regulation are those unique conditions existing around each plant, as opposed to those that might arise at it. the time of an accident at any plant Staff Brief at 1516; LILCO Brief at 12. ~ i. Condnuing, they argue that Contention 22.C challenges the regulations in ,.1 4 _ f m. WC- *
- two ways. First, it posiu nongcographic conditions, e.g., spontaneous evacuadon
{ and the utility only nature of the response organization. Staff Brief, n.8; LILCO 1 Brief at 4 5,14. Second, the contention argues for more than minor adjustmenu l to EPZ size based on these " conditions." Thus LILCO contrasts the 10-mile generic &nding (in NUREG 0396 and in the Commission's 1980 preamble to the rule) with Contention 22.C's implicit call for a dramatic EPZ expansion, i.e., an expansion "to the west to encompass those persons who may be involved in protective actions" and to the east to include ** East End residents"(which could include those 50 miles from the plant) who may have "the perceptiony w they would be trapped if the wind blew to the east." For such a chauenge to the rules, Intervenors aDegedly should have sought permission under $ 2.758 to litigate the coruenuon, something that was suggested to intervenors early in the proceeding. The Staff and LILCO also deny that there is any logical connocuan between plume EPZ size and the ability to deal with spontaneous evacumuon LILCO argues that "no maner where the boundary is drawn, there will always be people ouuide k who then become part of a new hypothesised ' shadow,'" a problem earlier recognized by a TM/ Licensing Board. LILCO Brief at 10, guoting Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), LBP-8159,14 NRC 1211,1553 (1981). Thus, says LILCO, with the use of 391 L
P Intervenors' theories to determine EPZ boundaries,"the EPZ spreads out like oil on water till it runs out of people." 14.28 Finally, LILCO and the Staff note that the Licensing Board specifically considered potential problems associated with spontaneous evacuation by those ni outside the EPZ, rejecting several Intervenor assertions: that spontaneous evacu6an woodd prevent the evoeusnan of those inside the EPZ e e (Camentions 23.A.C))* that spanianeous ewecusion of those suuide the EPZ would signincaraly and adveruly e affect evacuanon tiens from enhin the EPZ (Canaenuons 65.23.D and 23.H).'8 shst spornaneous evacuees from outside the EPZ might harm themselves by entering e contaminsed areas. and might impede evacmanon from within the EPZ (Contenuon 23.H))' and that 1ACO had dream the EPZ bowtdary knproperly sud that h biseciad disercie e populanons and junsdisions (Corunuon 22.D). LILCO Brief at 14 11
- 2 2._..,,,,, g ;
C. Commission Decision (,., Resolution of this issue requires that we examine carefully the history of l8' "d-the EPZ concept. The EPZ concept in NRC's emergen:y planning regula-tions derives from the repon of an NRC/ EPA lask force on emergency plan-nings NUREG4396," Planning Basis for the Development of State and 1.ocal Government Radiological Emergency Response Plans in Suppon of Light Water Nuclear Power Plants," December 1978 ("Repon"). The Repon's conclusions on EPZ size were based on analyses of both design basis and serious Class 9 " Amda f,e,i as i k d e suas om s mys taro, be. men psarmas h. sw. em, ene um defens Fink is saiald fees taro to nas leniisd pianung seneoems to pumpis whs puently my nas emed thes sesend, at snake anpasabns the task of the plasviar trytag to donde en EFZ haandanas Fww. iha Innsrveen almen ihst the emesenty place sanas psudast how seach spomansmus evenusuen $hst is, how mariy peopts ad how far away) thess will be an e enerymcy of mknown asse nemmens in the fuent has task is arnpassibts Gnier ears wedd ins publae opinaan pe1&s far thas pwpass. Ins shs samord shows that opinaan pelle same predest osmaal emergery behswwr ),. Even assummg the planner em prod.a the eatsu d speonanssa sweeuauen, ha the has to have o ennenen for where to drew the has (Opinam paus, for namnpns, will show fewer speaaneens evemassens as thmenes tem eks plan insseness, si weisi paus en ihis desansats honousa dans mis and shs EPZ?) Thee is en ensh essenen a NRC suodamme er pedamse... 1Aro Snef et i1. s' Ase 1220 Asawar et H.mang PID 1,21 PSC a tea. 80HD ("1200 has even sesammobis emmedsmuen to she pensihis empmas of shadow evensstaan ei summasum untns ennes assa sehm shs EFZ.""eamous ewemassaan as haans to swenauen d a9 er pen of the EPZ'1 pSanff Snef at 14,amans 21 NRC s 80100 Cy LJtro Bnst m 12 tasse '-- 66) r 7hs seest feed thei ihen who = ennessmaaily hemmes of fear af sedasuen undd eine have aseng 88 a se e MD,21 maavouen as to esmer shs EPZ? and thei LEro's plans fas E7Z penmes amusst mess pSC at 004. 392 unummuumus L
4' pe accident consequences using analytical techniques and information available at that time." For design-basis / loss of coolant accidents (DBA/LOCA), the Repon con-cluded, among other things, that for most plants the 25 rem (thyroid) and 5 rem (whole-body) EPA protective action guides would not be exceeded beyond 10 h miles from the plant, even using conservative assumptions and analyses. Re-port, Appendix ! at 4 6. As for serious Class 9 accidents involving core melt and containment failure, the Report concluded that these protective action guides o generally would not be exceeded beyond 10 miles unless the containment failed catastrophically and there was a very large release of radioactive material. The Report further concluded that even for very large releases, emergency actions such as sheltering or evacumuon within 10 miles would result in significant re. ductions in deaths and early injuries. ld. at 6 7. From a probability standpoint, the Repon concluded that the probability oflarge doses frorn core melt accidents drops off substantially at about 10 miles from the reactor. ld. at 37. Based on these considerations, the Report concluded that: lE)mergmey response plans should be useful for sosponding to army aseides shat would pro & ace offsite doses e eassse of the PAGs This would siclude the more sevm design j hasis accideau and the socidens speanen analysed is she ILS$. Aher sowiewing the passnual ' f 8 consequences assoested wish these sypes of asedenu, it was the sensensw (ssel of the [ ..J.. Task Force that amersecy plans sound he kneed ogson a gemene dammes out to whis g%,,, -- a M 66 predeseranined saions would provide does savings for any ass accideas. Beyond this generic J.. ~ ~ disiance it was concluded that asions emuld be taken an an ad hoc basis using the same c.ansideranons shas went inno the ininal asion determum p The Task Faroe judsmars en the saners of the Emergency Planing Zone is derived (som the "^ aharacserisnes of design basis and Qass 9 accidet annaequeness. Based an the aformanon i provided in Appendia I ed the apphoble PAG: a sedim of about 10 miles was aslemed for the plume esposure penhway and a sedim of abess 50 milu was selecend for she usesnan saposure pathway, as shoom hi table I. Ahhough the red,w for the EPZ imphes a circular area, the oceant shape would deped upon the earacterisne af a particular sme. The circular er other esfined area would be for piamag whereas ininal suspcase would likely bevolve aly a poruon af the tasal ases. Report at 16. st A Cass 9 mondes as an assades amnsidend to be se les is puehuhiluy a est to sequus apenAs addasensi perwinem a the emme af s senmar famisy Seash senderes sound unete esquetam af - , fenheen mass amers than thess penwlsind far the pierums of ameblambst du dump hans far pseasuve eyesins and aganmund ~ safary femmuus (Qaas 9 e=us engispism samhans ehems imodsag to asub! ese mak and enungisme dayedsuen of the asuasumes basienry and ihmus landsg to assus Assi aled faihsus er pome! andt wuh endaymides fanless of ens ammassess beandary). #dVREo496 as la 88ppassuit esmas padas an amins of adasuem dune ohnt. F propanaf so bs summoud br as admena!.weeld enness psuissess asuen Ane afassuf a(boamrow Ars's onds endhoasrow Ateearfor Nuriser Ansudsaw sh s3hrt.7s e01 (serismhs lffs). MS
I P A reading of the Repon indicates clearly that the margins of safety provided by the recommended 10 mile radius were not calculated in any precise fashion but were qualita.tively found adequate as a maner of judgment. Given the uncer-tainties in estimations of Class 9 accident probabilities and consequences, there was no other feacible choice in this regard.The EPZ's shape could be somewhat different than the 10 mile circular radius implies, without compromising emer-h gency planning goals. Indeed, the Report is explicit that " judgment... will be used in determining the precise sin and shape of the EPZs considering local conditions such as demography, topography, and land use characteristics, access routes, local jurisdictional boundaries and arrangements with the nuclear facil-ity operator for notification and response assistance." These are, of course, the considerations later cited in 150.47 tf)(2) with regard to determining the " exact sin and configuration"of the EPZ. Nothing in the Report or in any other matenal in the emergency planning rulemaking record compels a $nding that EPZ adequacy is especially sensitive to where exactly the boundary falls, and any such conclusion would seem to be at odds with the overall thrust of the Report. In particular, the task force's analysis indicates that " adequate protective measures"in the context of emergency planning is not a precisely de6ned concept. Earlier in this proceeding 'q' we explained the concept of " adequate protective measures" in our emergency planning regulations in CL18613,24 NRC 22,30 (1986), as follows: { \\ isle ' ~ = a E 4 : et This roos quesuan caman be anseeved widwnst ocme diamssksi of what is maars by f.* d-- ~ ~~
- adequaic pressaive meamares." Our amargency planning seguladens are en impous part ef uw esgulsiory framework for prosecung the pub'ac bankh and enfery. Bei they &ffer in l
sharacter from most of our sinns and engineering design seguiremrzas whid are dosaed l' at acturving or maintaining a minimum level of public safety pressaiors See, ed.,10 C.F.R I 100.11. Our emergency planning seguiremenu do not require that an adequme plan acturve a preset vrurumwn radianon done saving or a minimum evacuation time for the plume esposure paihuay emergency plarming sane in the ewn'. of a satious accident Rather,they euampi to actueve seasonable and feasible dose reducuan inder the circumstances, wbst may l be reasonable or feasible for one plant siis may nas be for anosher. It is implicit in this concept of " adequate pmtective measures" that a de-termination that a particular EPZ slu will provide " adequate protective mea-sures" does not in fact mean that emergency planning will eliminate, in ev-cry conceivable accident, the possibility of serious harm to the public. If this were actor.lly the criterion, it would be dif6 cult if not impossible to set any a priori limits to the sin of the EPZ or to the scope of required emergency planning. Emergency planning can, however, be expected to reduce any public harm in the event of a serious but highly unlikely accident. W But the rule clearly was intended to set such limits. Even under the Appeal Ems Board's analysis, the rule amounts to a Commission inding that adequate 394 I
P protection can be provided by an EFZ of limited size,10 miles in radius, give or take a few miles, but certainly much less than 20. Given these circumstances, we think it is entirely reasonable and appropriate for the Commission to hold that arguments for " adjusting" a 10 mile EPZ 10 improve safety, especiaUy arguments that entail complex analysis and lengthy litigation, are an impermissible challenge to the rule. The Appeal Board has g in effect also treated the rule as imposing a cutoff, which the Appeal Board places at somewhere more than 10 miles but certainly less than 20. The Appeal Board's approach is not much different from simply reading 50A7(b)(2) as requiring an EPZ "about 20 miles in radius" and then taking the position we adopt, i.e., refusing to accept contentions that would enlarge an EPZ that meets the criterion. But the rule says 10, not 20. The " outward creep" the Appeal Board would allow seems in the end to have no logical limits, as LILCO and I the Staff argue. Accordingly, we think the better interpretation is that the rule precludes adjustments on safety grounds to the size of an EPZ that is "about 10 miles in radius" and that Contentions 22.B and 22.C should on this ground be deemed { impermissibic challenges to the rule. In our view, the proper interpretation of the rule would call for adjustment to the exact site of the EPZ only on the basis of such straightforward administrative considerations as avoiding EPZ boundaries h ~' that run through the middle of schools or hospitals, or that arbitrarily carve out small portions of govemmental jurisdictions. The goal is merely planning LJ ~d I ~. ? simplicity and avoidance of ambiguity as to the location of the boundaries. With f W ac - such clanty, plans can be implemented with an understanding as to who is being directed to take particular protective actions." w D. HOSPITAL EVACUATION A.
Background
Two hospitals, and perh.tps a third as well, are located within the Shoreham l 10 mile EPZ. The LILCO plan lists several hospitals outside the EPZ 10 which - - - =,. .seimzs.s, - ee-, a .a. le cu izm o e.t s,., u r.he .e-,- sunenabng lenarveen, who ese fully renaar wah enar sulas sa thss separd, hsee shaman nos se esa Wher esmeiseu e the abensuvs as suna shaumga meer i2,7s4 over 4 yease have es+ elapsed emas ihs suhemanan er energery planrung isswas te bugauen, ed a seneseg er Causesans 21a and 21C es suis shausmgm waad he aussmaly a the samount Pisverdalass, wtmOtus thee ass % f_' 7__ _ as W dtal wWe en WYris'Whed b $1s sulentkutg 1 a and that 'amund ens &s e snapproprisw is apply the IC'.eals EPZ nas to Shersham een esill be annadered as pen er k NRC suff's seris, er umsesmanad imuss To be noe that se se, argas ears, ismas has been sewtenhed in shis essa, we segnem NRC Smir is sors, ens innas and to empen is the Canumane en k psier to esy hemiang oh n p ar. l I 395
l s I p hospital evacuees might be sent. But the Licensing Board found that LILCO had not obained letters of agreement with hospitals outside the EPZ concerning transler of padents, had not provided for transportation for evacuation of EPZ hospital patients undl individuals in other special faciliues"(e.g., nursing homes and nursery schools) were evacuated, had not calculated evacuation times for is two of the three EPZ hospitals, and had not predetermined the circumstances under which EPZ hospital patients would be evacuated. Nevertheless, the Licensing Board concluded that the LILCO plan was
- adequate, in the Board's view, arrangements for the relocation of patients to hospitals outside the EPZ could be made while the emergency was in progress. His was considered adequate because the hospitals are close to the outer edge of the EPZ, where the likelihood of receiving doses requiring evacuation is small, sheliering is the preferred emergency response in any event because of the risks attendant upon the movement of patients, and the EPZ hospiuls were constructed so as to be particularly suitable for sheltering, ne Appeal Board reversed. It characterized the LILCO arrangernents as ad hoc, and found that contrary to the reguladons' requirement for EPZ evacuation time estimates, LILCO had not provided time estimates for each EPZ hospital.
he Appeal Board also noted the Licensing Board's contrasung treatment of hospiuls and nursing homes. While the Licensing Board ftund no de5ciency in LILCO's failure to obtain agreements with hospitals for relocation of hospital.~ -J ' '.'; Q -- .:.c:, patients, it found deficient LILCO's failure to suf6ciendy identify and to include c _ g -- leuers of agreement with facilities outside the EPZ for accommodating EPZ nursing home residents. De Appeal Board was puzaled by the Licensing Board's contrasting treatment of these two areas, in taking review, the Commission asked whether the regulations, including 5 50A7(c)(1), " require evacuation plans for hospim!s in the EPZ even though sheltering would be the preferred option in most circumstances " B. Partles' Arguments Before the Commission 1. LULO sad Ssqff Arguments LILCO argaes before the Commission that NRC's emergency planning regulations do not require evacuation plans for hospitals. LILCO argues that the ha!! mark of the Commission's emergency planning requirements is Sexibility, recognizing the appropnateness of different approaches at different sites and for different potential accident acquences. De key regulation, says LILCO, b 10 C.F.R. 5 50A7(b)(10), which requires "[a] range of protective actions... for { the plume exposure pathway EPZ...." This range of protective actions, LILCO continues, in practice includes sheltering and evacuation n M k
o While conceding that its plan doesn't have all of the detail contemplat:d by NUREG-0654, LILCO argues that the standards of NUREG 0654 do not constitute requirements, but rather are suggestions. LII.CO then lists some of those NUREG-0654 "suggesdons." e.g., that plans "sha!! include.., means for protecting [ hospital patienu),... means of relocation,... time estimates for evacuation,... an estimate of the [ hospital] population... [which] 'shall usually be done on an institution-by.insutution basis, [and] the means as of transportation... [for the hospital population).'" Brief at 19 20. LILCO concludes from these passages that "none of these provisions requires every licensee to maintain a detailed plan for both shchering and evacuation of every facility and population group in the EPZ." LILCO 6nds support for its position in the EPA Marnal of Protective Action Guides, which " expressly acknowledges the need in cerain circumstances to apply different criteria in establishing appropriate protective action for special populations such as hospital patients."
- 14. at 20. Thus, LILCO concludes. "the regulations and guidance ' explicitly' allow different treatment for different groups such as hospital patients."
LILCO's next argument on the hospital evacuation issue, and the only argument offered by the Staff on this issue, is that even if the regulations generally require evacuation plans, the Shoreham plan is not significantly de6cient in this regard, and thus, under $ 50.47(c)(1), the Commission is not compelled to deny the issuance of a license. Both LILCO and the Staff support l i this argument by pointing to the Licensing Board's indings on the distance of j .,. '.. ~ i..m, ; the hospitals from the plant (over 9 miles), on the heavy masonry construction E of the hospital buildings leading to 0.2 shielding factors (i.e., the dose inside f-,%-- the buildings would be 20% of the dose outside), on the danger of evacuation for patients, on the low probability of accidems that would require evacuation for those more than 9 miles from the plant, and on the existing arrangements p for eventual evacuation of the hospitals. Finally, L!l.CO argues, it has developed reasonable evacuation plans for the hospitals. Evacuadon vehicles 6rst would complete their nursingadult home runs, and then report to hospitals on an "as needed" basis, as determined by hospital administrators upon balancing information including that on weather, projected doses, and the risk of transporting patients. Moreover, LILCO argues, the Appeal Board was mistaken that LILCO had not adequately calculated evacuation times for hospitals, since the Licensing Board speci$cally found that the hospitals could be evacuated within 9 hours.8
- The teammas Sensd feed ihst:
lA>nbubses wedd nas auseinal, emmasu es saefsa Casey snarmary usmD sarns 8 hows. $0 mamass sAs the suusi nedssuma.. The onesusman er bespiuk camW==# ash, mm.br esses,mr s/ ase et leem wuh segud is erstedesses... [ Web sogard to estulsassL she bespeals us e e sandar poseen he tu safen Commy inErmary, for weseh mudsulsas ensusman sul aska 4 hamn.40 sewassa). LSP s5-12. si NaC a 8ds 46 (esiphans added) 397 .tk E
} I 2, intervenor Arguments Intervenors argue that "LILCO's failure to plan for evacuation of hospital { patients is total," with vehicle arfangements " expressly acknowledge [d)" in the plan as ad hoc, and provisions for evacuation only *if vehicles become f ~ available." Brief at 15.These aspects of the plan allegedly violate the regulations I and NUREG-0654 by failing, for example,10 identify relocation centers for hospitals (an alleged violation of NUREG-0654 IlII.A.3, J.10.d and J.10.h), by failing to provide evacuadon time estimates for each facility (an alleged violation of Appendix E to 10 C.F.R. Part 50), and by failing to plan routes or procedures for hospital evacuadon (an alleged violanon of both 6 50.47(b)(10) and EPA Protective Action Guidelines). Intervenors support the Appeal Board's view that the improbability of ever needing to use any given protective aedon is irrelevant under the NRC's emergency planning rules because those rules are based on an assumpdon that a serious accident might well occur. Brief at 19 20, citing Philadelphia Electric Co. (Limerick Generating Station, Units I and 2), ALAB 819,22 NRC 681,713 l 3 (1985), review declined. CLI 86 5, 23 NRC 125 (1986). Moreover, Intervenors 2. assert that LILCO's allegedly " complete failure" to plan for hospitals can never HMYN be viewed, using 5 50.47(c)(1), as insignificant.ri p-C. Commission Decision We agree with the Appeal Board's reasoning on this issue. Even though sheliering will quite likely be the preferred protective action for EPZ hospitals in the event of a serious accident, evacuation should not be prejudiced by the failure to plan in advance. Appendix E to 10 C.F.R. Part 50 requires evacuation time esumates for the EPZ without exceptions for special facilides such as hospitals. Clearly, evacuation plans for hospitals must at least be developed in sufficient detail to provide a basis for these estimates. Moreover, hospitals, as a kind of "special facility," are speci5cally mentioned in the principal guidance document in this 6 eld, NUREG-0654, and there is no suggesnon in this gui'Jance that hospitals are to be treated specially as exempt from the evacuation planning requirement that applies to other segments of the populanon within the EPZ. We therefore conclude, in agreement with the Appeal Board, that the regula-3 tions require the Applicant to ful611 the same planning obligations with sogard .to hospital evacuation as the Licensing Board imposed in connection with other like segments of the EPZ, sudi as nursing / adult homes. This conclusion does not % p
- i. utzxr. an r. s si em e. c n
e., eenweremc .shwa e rertaro. om.nps t. show thea omse e adagasu pla.ums and peup nei s r. h.m p.===l o 8.. utro r pual suesusum 398
,e a s P necessarily end the inquiry as to whether LILCO's Emergency Plan is adequate with respect to these hospitals. Under $ 50.47(cXI), the Licensing Board could still approve the LILCO plan if it found that the defeiencies related to the hospi. tais were not signi6 cant for Shoreham. In fact, the Licensing Board did identify factors that may have relevance to this question, such as distance from the plant b i and construction characteristics of the hospitals. However, it is not clear to us that this was a matter adequately presented to or considered by the Licensing Board, since the Licensing Board did not speci6cally discuss 6 50.47(cXI). On remand, LII.CO and Staff are free to raise the issue for appropnate resolution. III.
SUMMARY
In surnmary, we take two actions. First, we reverse the Appeal Board's decision in ALAB 832 insofar as it admits Contentions 22.B and 22.C for hearing. However, the NRC Staff is to advise us prior to issuance of any license for operation above 5% power whether there are special circumstances at Shoreham that were not envisioned in the emergency planning rulemaldng, and that would make it inappropnate to apply to Shoreham the generic decision that y an EPZ of about 10 miles is adequate for emergency planning purposes. Syon,.d. l. .o. ,0..._.. we uphold the Appeal Board's decision in ALAB 832 that the proceeding must ' "~ r-e rm s.asu. --4 be remanded to the Licensing Board for further consideration of the evacuation . ~ "~" ~ ~ plans for hospitals in the EPZ. It is so ORDERED. g For the Commission
- SAMUEL J. CHILK Secretary of the Commission Dated at Washington, D.C.,
this 5th day of November 1987. [7he appenda has been omiued from this publication but can be found in the Public Document Room,1717 H Street, NW, Washington, DC 20555.] ~ E MMMMMMM b M h Ib M. I% W M M % seuW how appened E 399 M . -}}