ML20207G439

Responds to from Cl Miller,Requesting Assistance of FEMA in Addressing Concerns Received by NRC Involving Offsite Emergency Preparedness at Plant NPP

ML20207G439
Person / Time
Site:	Calvert Cliffs
Issue date:	03/30/1999
From:	Quinn V Federal Emergency Management Agency
To:	Essig T NRC (Affiliation Not Assigned)
Shared Package
ML20207G436	List: ML20207G433 ML20207G439
References
NUDOCS 9906110158
Download: ML20207G439 (10)

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,1 Federal Emergency. Management Agency /

Washington, D.C. 20472

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liar 30 999 Mr. Thomas H. Essig, Chief Emergency Preparedness and Health Physics Section Operator Licensing, Human Factors, and Plant Support Branch Division ofInspection Program Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop OWFN 9 HIS Washington, DC 20555-0001

Dear Mr. Essig:

I am writing in response to the September 29,1998 letter to me from Mr. Charles L.

Miller, formerly Chief, Emergency Preparedness and Radiation Protection Branch, requesting the assistance of the Federal Emergency Management Agency (FEM A) in addressing concerns received by the US Nuclear Regulatory Commission (NRC)

! involving offsite emergency preparedness at the Calvert Clifts Nuclear Power Plant (CCNPP).

i Specifically, Mr. Miller asked FEMA to evaluate and provide the NRC an assessment of

the adequacy of five concerns: (1) the effect of the addition of several thousand new l

employees at the Pautuxent River Naval Air Station on the evacuation routes and evacuation time estimates for Calvert Cliffs;(2) the overall effect of the increased population in the area, the increased traffic loading, and deterioration of evacuation routes; (3) the adequacy of evacuation plans for the Drum Point Peninsula and the concern that evacuation of this area may be limited to only one road, Maryland Route 760;(4) the concern that access to the area by responders would be hindered by existing trafric problems that would be compounded during an incident; and (5) the concern that local first responders and the local hospital staff appear not to be adequately aware, trained, or equipped to assist the population at risk, or to protect themselves from exposure both to ionizing and non-ionizing toxic agents at the plant that might be dispersed in a nuclear incident.

I have enclosed a report, forwarded by FEM A Region III, detailing the results of the evaluation and assessment of evacuation plans related to the CCNPP. As is noted in the report, the results of the evaluation and assessment indicate that offsite emergency preparedness at the CCNPP is adequate and provides reasonable assurance to protect the public health and safety. However, please note that the repon also contains some j recommendations that, for the most part, pertain to the Evacuation Time Estimate and the 9906110158 990607 "

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9 radiological capabilities of emergency workers FEMA will, of course, take notice of any recommendations that penain to offsite radiological emergency preparedness.

If you have any questions, please feel free to contact Ms. Nancy Goldstein at (202) 646-4285, Sincerely, V neYa E ui Acting Chief Radiological Emergency Preparedness Branch Enclosure i

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g 4 Federal Emergency Management Agency Region !!!

bberty Square Building (Second floor) 105 South Se enth Street Philadelphia. PA 19106 e99 PT MEMORANDUM FOR: T. Kevin Koob Regional Assistance Committee Chairperson, FEMA Region III T

FROM: Yvette D./ heI'am,y0 hb&^

TechnoloM' al liazard Program Specialist l

SUBJECT:

U.S. Nuclear Regulatory Commission (NRC) Concerns Regarding the Calvert Cliffs Nuclear Power Plant (CCNPP)

The evaluation and ascessment of the evacuation plans for the areas around CCNPP based on NRC's concerns identified in Vanessa E. Quinn's memorandum, dated October 9, 1998 has been completed.

Overall, the results of the evaluation and assessment indicate the off-site emergency preparedness at the CCNPP is adequate and provides reasonable assurance to protect public health and safety. However, some recommendations have been made and are identified later in this correspondence. A summary of each concern addressed by NRC is listed below. In addition, enclosed for your review are an " Evaluation of Concerns Involving Offsite Emergency Preparedness for the Calvert Cliffs Nuclear Power Station", j an " Analysis of TEMA REP Exercise and MS-1 Drill Issues in l Calvert and St. Mary's Counties, Maryland, 1989-1998", and j a memorandum to Tom Forgotte, Baltimore Gas & Electric, Calvert Cliffs Nuclear Power Plant, from Paul Wible, St.

Mary's County Energency Management Agency, subject:

Evacuation Time Estimates, dated March 12, 1999. These documents contain detailed information en the evaluation and assessment.

The first area of concern was the effect of the addition of several thousand new employees at the Naval Air Station (NASI on the evacuation routes and evacuation time estinates for Calvert Cliffs. In summary, the impact of the increase in employment as the NAS has already been

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accounted for in the Evacuation Time Estimate (ETE) report; thus the report (Revision 5) does not need to be updated to account for current population.

Second, the overall effect of tho increased population in l -

the area, the increased traffic loading, and deterioration i of evacuation routes. In summary, with respect to j population growth, there does not appear to be any special l problems in the EPZ areas that are the subject of this ,

inquiry - those to the south of the Calvert Cliffs Nuclear  !

Power Plant. However, it is recommended that an ETE be prepared and reviewed which assumes a population and vehicle growth of 2% per year to 2005 and makes no changes in the roadway network. This implies a year 2005 population of 16,182, up from 14,3669 (5/1/97) in.the area of concern (EPX Zone 3). It is further recommended that a higher proportion of this growth be assigned to the annular EPZ segment that contains the Cove Point and Lusby Town Center areas.

Third, adequacy of the evacuation plans for Drum Point Peninsula, especially because evacuation is limited to essentially one road from the peninsula to the mainland.

In summary, there is nothing to indicate that the time estimates in the ETE covering the southern portion of the EPZ are based on inadequate or unrepresentative data. It is recommended that Baltimore Gas & Electric (BG&E) review the coded ETE network to determine if more nodes and possibic additional (internal) links for the Chesapeake Ranch Estates and Drum Point area could be included in the analysis. We also recommend that when the runs are conducted, per the recommendation in #2 above (which would assume a higher area population), the results be reviewed to determine if and where additional traffic control points on this peninsula might be needed. Given that there is just one road out of the peninsula, good traffic control measures and planning with the public are essential to facilitate efficient and expeditious movement of the population. Finally, it is recommended that the five minor gates in Chesapeake Ranch Estates be counted on as being available to assist an evacuation.

Fourth, access by responders to the area would be hindered by existing traffic problems that would be compoended during an incident. In summary, while we did not identify any existing traffic " problems" that would hinder responders, existing traffic " conditions" might create a a- . :-

probica for_ responders needing to reach spect!ic locations in southern Calvert County. It is recommended that the current plans to move these responders (i.e., plans perhaps to use the shoulders of Route 2/4, which were not available for review, be carefully reviewed.

Several other items were noted that should be resolved before the ETE is revised, which are as follows:

a) The'ETE node list for south St. Mary's County (p. C-5) indicates nodes at the intersections of (a) Rte. 4 and Town Creek Rd., (b) Patuxent Ecach Road and Baringer Drive, and (c) Patuxent Lane and Town Creek Road. No such intersections exist.

b) Route 235 in the vicinity of Route 4 is coded as having two lanes in each direction. At present, there are three usable lanes in each direction through this area. Similarly, Route 4 (St. Andrews Church Road) west of Route 235 is coded as having two lanes in each direction (Links # 123 and 124).

only bne flow lane is actually availabic in each direction unless evacuation contra-flow (turn lane for either direction) is intended by this coding, in which case see (e) below.

c) Separate nodes (235 and 240) are indicated on p. C-6 for the intersections of Route 235 with, respectively, Patuxent Beach Road and Route 4.

Patuxent Beach Road at that location 2s Route 4.

d) There should be some explanation / justification of duplicate node coding. For example, nodes 332 and 260 are apparently identical, as are 415 and 505, 419 and 509, 421 and 507, and 423 and 522 (there may be others points where this duplication exists).

e) Both lanes of Governor Thomas Johnson Bridge have been coded in the- ETE network as carrying southbound evacuation traffic (ETE Revision 5,

. Appendix D, p. D-4: Link # 22). However, we note j in the coding that immediately after the bridge, '

all outbound vehicles are funneled back into a i single lane (p. D-3, Link # 151). Under these I circumstances congestion will inevitably develop at j this point, even with traffic control personnel )

present. Perhaps the congestien could be i alleviated by maintaining the additional contra- I

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flow . lane outbound all the way to Route 235 (this is a feasible option), which in turn could reduce the ETE for the southbound traffic. We suggest that this option be reviewed and possibly included in a sensitivity-case ETE run that includes the higher populations in the Drum Point peninsula (see #2 above), provided that St. Mary's County EMA agree with this proposal. i f) We cannot tell whether the assumption that both lanes of the Governor Thomas Johnson Bridge will be used to evacuate southbound traffic is consistent with the evacuation traffic flow plans and procedures of Calvert and St. Mary's Counties. If it is consistent, then the coding and reporting of ETE results using the Bridge are acceptable.

However, if the county plans maintain that only one lane of the Johnson Bridge will be used for outbound evacuation traffic, then the base case ETE run should be so coded and results of that case (not the case of two outbound lanes) reported in the next ETE revision.

g) Relating to both (e) and (f) above, one of the major concerns of our analysis focuses on Route 2/4. This is a four-lane road of which, according to ETE coding, two lanes will be used for traveling south from the peninsula onto a single-lane (in each direction) bridge deck (Governor Thomas Johnson Bridge), using one or both lanes for outbound traffic. At the St. Mary's County end of the bridge, all flow is coded to merge into a i single lane on Route 4, which has byt one lanc in each direction from the bridge to the edge of the 1 10'-

mile EPZ. Whenever evacuees are required to go j from two lanes to one, even with proper traffic I control, congestion is bound to occur, resulting in l the traffic being backed up for a considerable distance (in this case, back over the bridge). The  !

congested locations that are seen to develop during l the (simulated) evacuation runs by NETVAC2 may not  !

be appropriately capturing the congestion levels I that will occur. We recommend a sensitivity analysis which assumes a maximum speed of 20 mph less that the free flow speed now assumed for the bridge and Route 2/4 to Route 235. [ Pl ea se note that our suggestions regarding possible re-coding of portions of the eva cua tion network in the

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vicinity of the Governor Thoma s Johnson Bridge assume that, like any real-time evacuation traffic .

model in common use, NETVAC2 adj ust s link flow speeds to account for increases in volume. If this is not the case, the model will need to have this feature added prior to performing any new ETE runs.]

rinally, the last concern delved with the adequacy of the emergency workers and hospital staff with respect to training, abilities, and resources to assist the population, or to protect themselves in the event of an accident / incident at the Calvert Cliffs Nuclear Power Plant. The conclusion of our analysis is presented below:

a. Training

1. Exercise Ob]ectives In the radiological area, the incidence and recurrence of issues could be reduced by focusing training on the proper implementation of SOPS, particularly those concerning (1) exposure limits; (2) dosimetry  ;

issuance, use and documentation; and (3) monitoring, I decontamination, and contamination control. The l training should be directed at RSos and front-line emergency workers in all settings (especially, EOCs, dosimetry distribution points, monitoring and decontamination stations, and medical transport units and facilities).

2. MS-1 Drill Objectives In the Medical Services area, performance could be enhanced (i.e., the incidence and recurrence of issues 1 could be reduced) by focusing training on (1) the overall concept of operations and (2) the proper implementation of radiological SOPS, particularly those concerning the issue and use of dosimetry equipment, emergency worker exposure limits, patient monitoring and decontamination, and documenting all phases of MS-1 activities.

b. Abilities

1. ORO Resources

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1 The most common resource issue found in the study was inadequate staffing. Infractions were found in a variety of settings, including Monitoring and '

Oecentamination Stations, Rumor Control, Access Centrol Points, and Congregate (Mass) Care Centers.

Perhaps noteworthy in this regard is the observation that all of these settings are peripheral to county EOC operations, neither of which was cited for staffing omissions. Moreover, all of the staffing issues occurred in St. Mary's County.

A few issues were cited (also in St. Mary's County) involving tangible asset inadequacies, such as lack of workspace for State Liaison personnel, the unavailability of nursing supplies at a Congregate (Mass) Care Center, inadequate parking space for segregating contaminated and uncontaminated vehicles at a Monitoring / Decontamination Station, and the lack of separate male and female showering facilities for emergency workers.at a Monitoring / Decontamination Station. However, these issues were non-recurring at the same locations.

These findings suggest that greater management oversight may be needed to heighten the awareness of i peripheral ORos concerning staffing shortfalls and l addressing unmet needs. l l

2. Radiological Radiological capabilities is among the two most-cited general capabilities areas. If MS-1 Drill issues were combined with Exercise issues, the radiological capabilities would constitute the most cited area (464 '

of the 128 Issue Components reviewed in this study) .

Yet, there were relatively few recurring issues. Those that were identified involved Monitoring / Decontamination Station vehicle segregation in Calvert County and Field Monitoring Teams (TMT) in both counties. The Calvert County-Monitoring / Decontamination Station currently failed to segregate contaminrted and uncontaminated vehicles.

Calvert County FMTs were recurrently cited for improper use of survey equipment, while St. Mary's County FMTs were recurrently cited for failing to properly complete recording forms and other documentation.

r I I These considerations notwithstanding, a broad array of radiological issues were identified. While at the most specific level Issue Components are largely non-recurring, there is a broad pattern of SOP infractions involving radiological equipment distribution, use, and documentation. These infractions cut across ORos, including FMTs, emergency worker, and evacuee Monitoring / Decontamination Stations. Over a third of the 27 radiological Issue Components (37%) involved failing to follow equipment SOPS, and all but two of  :

these components occurred in Calvert County. Nearly j two-thirds of the issue Components identified under objective 5 were found in Calvert County, while under objective 6 for FMTs, nearly two-thirds of the components were found in St. Mary's County.

These findings suggest that greater management oversight and additional training of radiological )

workers are needed. j

3. Medical Transport I

All of the medical transport capabilities issues '

concerned dosimetry. The Calvert County medical transport personnel were cited recurrently for failing to provide required dosimetry. This trend was found in a context of other non-recurring issues, including failing to issue proper dosimetry, failing to issue proper dosimeter recording forms, lack of knowledge about exposure limits and the dosimeter recording interval, and failing to zero dosimeters prior to use.

These findings suggest that greater management oversight and additional training of medical transport workers are needed.

4. Medical Facilities Almost all of the medical facility capability issues involved radiological concerns, including failing to issue dosimetry equipment; lack of knowledge of emergency worker exposure limits; failing to properly implement monitoring, decontan.ination, contamination control, and radiological documentation SOPS; SOP technical errors; and ambiguity concerning hospital vs. utility roles and responsibilities. In addition,

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the medical facility was cited recurrently for failing i to properly document patient decontamination and other ,

REA activities.

l These findings suggest that greater management oversight and additional training of medical facility workers are needed.

c. Resources

1. Exercise Objectives Although a number of resource issues were identified (mainly personnel inadequacies), the data do not suggest the presence of any critical resource shortages that would significantly impair emergency response efforts. The maintenance of tangible assets is an imperative that appears to be adequately addressed on an ongoing basis by the counties.

The availability of personnel resources requires recruitment and training. The staffing issues identified do not indicate that there is a significant shortage of personnel available to perform vital functions. Training is addressed above.

2. MS-1 Drill objectives i

Too few resource inadequacies were cited in the source l documents under the MS-1 objectives to identify meaningful trends. Consequently, the issues identified ,

do not indicate that there were any significant resource shortfalls for cither the medical transport agents or hospitals.

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