ML20235B469

Applicant Direct Testimony 3 (Personnel Resources).* Testimony Demonstrates Availability of Personnel to Each of 17 Towns/City in Portion of EPZ to Perform Radiological Emergency Response Functions.Related Correspondence

ML20235B469
Person / Time
Site:	Seabrook
Issue date:	09/10/1987
From:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Shared Package
ML20235B348	List: ML20235B346 ML20235B421 ML20235B449 ML20235B469 ML20235B499 ML20235B519 ML20235B566 ML20235B578 ML20235B601 ML20235B621 ML20235B643
References
OL, NUDOCS 8709240115
Download: ML20235B469 (17)

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Dated: September 10, 1987 l

e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the

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ATOMIC SAFETY AND LICENSING BOARD l I

\ ) \

In the Matter of )

PUBLIC SERVICE COMPANY ) Docket Nos. 50-443-OL i OF NEW HAMPSHIRE, EI AL. ) 50-444-OL

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(Seabrook Station, Units 1 ) (Offsite Emergency I and 2) ) Planning Issues)

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APPLICANTS' DIRECT TESTIMONY NO. 3 (Personnel Resources)

Panel Members: John D. Bonds, Assistant Director for Planning, Division of Public Health Services, New Hampshire Department of Health and Human Services.

Anthony M. Callendrello, Manager, Emergency Planning, New Hampshire Yankee Paul R. Frechette, Jr., Senior Emergency Planner, New Hampshire Yankee William F. Renz, Emergency Planning Specialist, Aidikoff Associates Richard H. Strome, Director, New Hampshire Office of Emergency Management William T. Wallace, Jr., M.D., M.P.H.

Director, Division of Public Health Services, New Hampshire Department of Health and Human Services PURPOSE The purpose of this testimony is to demonstrate: (1) 8709240115 070912 PDR ADOCK 05000443 G PDR

..t the availability of personnel to each of the 17 towns / city in

. the New Hampshire portion of'the EPZ to perform the l

radiological emergency response plan functions called for under their respective local plans; (2) the availability of

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personnel to staff and implement state emergency response l functions called for under NHRERP Rev. 2; and (3) the l

l availability of personnel to provide state assistance to local communities in the absence of local emergency response plan implementation.

This testimony addresses issues raised in the following contentions: Seacoast Anti-Pollution League Contention Nos.

8 and 8A, Town of Kensington Contention No. 1, New England Coalition on Nuclear. Pollution Contention No. VI, Town of Hampton Falls Contention No. 2, and Town of South Hampton Contention No. 2. Issues of the availability of volunteer, 1

part-time, seasonal, or out-of-town emergency workers are addressed'in the testimony of the ETE and Human Behavior Panel. Issues regarding letters of agreement for bus driver and towing services are addressed in the testimony of the Letters of Agreement Panel. Issues of staffing traffic control positions and population estimates for the Town of Hampton are addressed in the testimony of the ETE and Human Behavior Panel. Issues raised by.the personnel resources ,

I' contentions Town of South Hampton No. 8 and Seacoast Anti-Pollution League No. 37 are addressed in the testimony of the  ;

Special Needs and Transportation Panel.

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SUMMARY

OF PERSONNEL RESOURCE ASSESSMENT In order to establish that personnel resources are available to fulfill all state and local response functions contemplated in the New Hampshire Radiological Emergency Response Plan (NHRERP), a personnel resources survey was conducted and an ongoing assessment program established. A document entitled Summary of Personnel Resource Assessment for the New Hampshire Radiological Emergency Response Plan (Summary), presented herewith as Exhibit 1, and incorporated by reference herein, catalogues and records the information obtained regarding the number of personnel available to perform State and Local emergency response functions and describes the steps taken to identify personnel requirements and availability to support the implementation of local and State plans and procedures.

LOCAL MUNICIPALITIES A systematic approach to define the types and numbers of personnel required and'available to perform the functions described in the local municipality RERPs was undertaken. A walk-through of the implementing procedures was conducted to identify, by position and functional responsibility, all tasks required to be performed in fulfilling the emergency response functions. This process led to the determination of the specific staffing requirements to implement each plan, and the identification of those positions requiring staffing for 24-hour operations.

The resultant' personnel'needs are displayed in'the form of emergency response organization charts for each of the New Hampshire local municipalities located within the Seabrook Station plume exposure Emergency Planning Zone. An Organization Chart for each local municipality is included within Section 2 of the Summary.

The next step in this process was the identification of available personnel resources to fill the emergency response.

-positions for each municipality identified in the procedural walk-throughs. This was done through the analysis of l background documentation and included specific data sources such'as Town Plan Appendices; Town Annual Reports; the New I

Hampshire Police Standards and Training Commission records, the New Hampshire Fire Standards and Training Commission records, the Bureau of Emergency Medical Service records, and the New Hampshire Firemen's Association records.- In addition, surveys were conducted with persons knowledgeable about the specific communities to verify and adjust the numbers of required and available personnel. Various individuals such as selectmen, Town Managers, Civil Defense Directors, Police Chiefs, Fire Chiefs, and Health officials within the local municipalities were contacted by representatives of the New Hampshire Emergency Management Agency and New Hampshire Yankee.

The actual assignment of personnel to a local emergency response organization is typically made by, or with the l

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concurrence of, municipal officials. For six towns l

(Kensington, Hampton, Hampton Falls, South Hampton, Rye and l

North Hampton), however, no complete assignment of personnel has been adopted. Therefore, for demonstration purposes, Section 2.2 of the Summary contains an Organization Chart depicting personnel needs, a breakdown of personnel availabilities, and a matrix of how the available personnel might be assigned to the corresponding emergency response organizations for each of these towns.

Organization charts, breakdowns of personnel availabilities and matrices depicting the status of local -

personnel assignments as of July, 1987, provided for the remainder of the local municipalities located within the 10-mile EPZ have been reviewed with appropriate local officials.

Explanatory _ comments regarding the breakdown of personnel availability and the assignment of available personnel presented in the matrices are noted in the remarks column of each matrix. .

Section 2 of the Summary includes organization charts for each local emergency response organization. These organization charts define the personnel "need" for implementing the respective local RERP for a protracted emergency response. Section 2 of -the Summary also contains matrices that were developed for each local municipality detailing the personnel available to each local municipality and the assignments that have been made through July, 1987.

It is significant to note two points with regard to these assignments. First, assignments of available personnel made for the local emergency response organizations of the.

Towns of Kensington, Hampton, Hampton Falls, South Hampton, Rye, and North Hampton, as noted earlier, are those which could reasonably be made. Second, and as is demonstrated by each and every matrix included in Section 2 of the Summary, j the overall number of personnel available to the local municipalities to staff the respective emergency response organizations exceeds the number ofLpersonnel required.

For the most part, 11 municipalities have already made assignments of.available personnel to emergency response positions. As of July, 1987, 370 of the 378 local emergency response positions have been filled by the 11 municipalities that have made assignments. Local officials have indicated that they will continue to make assignments using available l

personnel.

The following examples illustrate the practice of reallocation of local personnel resources in assigning emergency response positions.

The assignments of Police Department personnel for each local municipality is displayed on the town matrices included in Section 2 of the Summary. As local police resources are not available for all municipalities in sufficient numbers to fulfill all of the emergency response functions typically assigned to police personnel, support in the form of additional personnel is provided by various means. The specific breakdown of assignments for each local municipality l

.is presented in the matrix provided in Section 2 of the Summary.

In some communities, sufficient police personnel exist to staff all responsibilities assigned in the local RERP. In the City of Portsmouth for instance, there are sufficient numbers of police department members to staff the Police Chief position in the EOC, provide EOC security, provide municipal security, direct the operation of the local Transportation Staging Area, support the contact of persons requiring special needs and special facilities, and perform all traffic control responsibilities within the City.

Summary at Table 2.3-9.

The Town of Newfields on the other hand, as depicted in Table 2.3-7 of the Summary, provides police personnel to staff the Police Chief position in the EOC and perform municipal security functions. The functions of traffic control and EOC security, in this case, are assigned to State police personnel and Town Fire Department personnel.

For any distinct group or organization within the local municipalities, local fire departments, more than any other provide the personnel resources necessary to fill emergency response support functions. The assignment of local fire department personnel is broken down into personnel assigned to " fire department" responsibilities, and those assigned to

positions in supporting roles such as local EOC staff positions, EOC Security,. Traffic Control and local Transportation Staging Area.

The Town of Stratham Fire Department, for' example, has a complement:of 101 and only a need for 15 personnel to serve the Fire Chief position in the local EOC and various other-positions. 'This surplus allowed for the reallocation of personnel to provide' local EOC security.

In determining the required number of local and state highway personnel the following factors were considered. The local RERPs contemplate that a highway department representative will report to the local EOC. There, this person implements his or her designated procedure and notifies, as required, public works personnel and private contractors _to report to a predesignated location.' Depending upon conditions at the time of the emergency, personnel are dispatched to perform emergency maintenance of evacuation routes. Should the need on the local level exceed the capability of local resources, resource assistance of the State can be requested through the Incident Field Office per NHRERP, Vol. 4, Local Liaison procedure.

STATE AGENCIES In order to determine the availability of personnel resources within the various State agencies in New Hampshire, all New Hampshire State agencies and supporting organizations t

l' assigned responsibilities under the New Hampshire RERP, Rev.

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2 have been included in the personnel resource assessment.

In addition, some agencies or organizations designated in New Hampshire RERP, Rev. 2, Volume 2, Appendix G as responsible for'providing assistance to local municipalities have been provided' additional attention. Summary at Section 3. A systematic approach was undertaken to define the types and numbers of personnel required to perform these functions.

The first step in the process was to review the New i

Hampshire RERP, and the procedures contained in New Hampshire RERP, Rev. 2, Volumes 4, 4A, and 4B to ensure that all assigned responsibilities were addressed. On the basis of.

this review, a subsequent step involving a walk-through of each implementing procedure was conducted to identify by agency, position and functional responsibility all the tasks required to be performed in fulfilling emergency response functions. This analysis included both primary and support (secondary) responsibilities.

The next step in the process was the identification of personnel resources available to fill the emergency response positions noted during the procedural walk-throughs. To accomplish this, assessment worksheets were developed specifically for each State agency. The purpose of the worksheets was to elicit pertinent agency-specific data by a review of the agency's assigned responsibilities.

Under the auspices of the New Hampshire Emergency Management Agency, interviews were arranged with the

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principal emergency response personnel in each New Hampshire State agency.with assigned responsibilities under the NHRERP,.

Rev. 2. The assessment worksheets were completed during the interviews, and the number, location, and type of personnel i 1

available to perform emergency response functions were documented. The assessment process is depicted in Figure 3.1-1 of the Summary. This primary data source for State personnel resources has been supplemented by a review of resource appendices to the agency procedures contained in NHRERP, Rev. 2, Volumes 4, 4A, and 4B and by a review of currently available State directories and other public ,

records. The results of the assessment are summarized in Tables 3.1-1 through 3.1-4 of the Summary.

STATE ASSISTANCE TO LOCAL MUNICIPALITIES (1) General Support The following New Hampshire State agencies are directly assigned responsibility for providing assistance as specified to local municipalities.

1. New Hampshire Emergency Management

a. Providing direction and control over State assistance activities.

b. Ensuring activation and mobilization of resources.

c. Providing communications.

d. Notifying special facilities and persons with special needs,

e. Determining special transportation requirements and other special assistance requirements.

-f. Coordinating provision of transportation and~other specialLrequirements.

2. New Hampshire State Police-

a. Providing traffic control assistance.

b. Providing security and law enforcement.

c. Dispatching impediment removal resources.

3. New Hampshire Department of Transportation

a. Providing traffic control equipment.

b. Roadway clearance and impediment removal.

4. Rockingham County Sheriff's Department

a. Staffing of local transportation staging areas. , i l

b. Dispatching transportation resources to special facilities and providing special needs assistance.

5. New Hampshire National Guard Providing personnel to support primary responders, supporting protracted operations, and, if required, support traffic control, security and law enforcement, special needs assistance, transportation, communications, and road clearance.

6. EMS /Public Safety Providing personnel to assist in evacuating special needs individuals from their homes.  ;

Based upon the methodology of assignment of personnel, and as evidenced by the overall listing of the State agencies and support organizations inclusive of required and available personnel resources, it is clear that personnel resources d2 exist to staff the identified emergency response functions of the State's response organization. Summary at Tables 3.1-1  !

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through 3.1-4.

If any position vacancies are identified in the future via the ongoing personnel assessment program, they may be resolved through the reallocation of individuals within the specific State agencies, and from other State agencies as identified in the program surpluses, or through recruitment.

(2) Local Liaisons As defined in the procedures contained in NHRERP Volume 4, Local Liaisons are generally responsible for facilitating the flow of information between local and State emergency response personnel. Should the tasks associated with the emergency response exceed the capabilities of local responders, the Local Liaison is also responsible for securing assistance. This includes determining transportation needs for local municipalities unable to respond, and forwarding those needs to State emergency responders.

A summary of the tasks assigned to Local Liaisons are outlined in the IFO Liaisons Procedure included in Volume 4 of the New Hampshire RERP. There are sufficient numbers of Local Liaisons available to fill the required positions as shown in the Summary at Tables 3.1-3 and 3.1-4. It should also be noted that there need not necessarily be a one to one ratio between a Local Liaison and a community. Personnel assignments are based upon the amount of work needed to be l performed in support of a response effort within that i

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community.

(3) Rockingham' County Sheriff's Department To' determine the required number of sheriff's deputies, Lthe following' functions were analyzed. Rockingham. County

. Sheriff's deputies are primarily concerned with the' activation and operation of Transportation Staging Areas (TSA). There are two State TSAs managed by deputies from the Rockingham County Sheriff's Department. In addition, there are local TSAs in each-municipality managed by local emergency response personnel. For towns that would require full State assistance, local TSAs will be managed by-Rockingham County Sheriff's deputies.

At the two State TSAs, Rockingham County Sheriff's deputies will perform the managerial functions of staging area supervisor, staging area managers, and managers' assistants. Additional sheriff's deputie:s will be dispatched to establish and direct the operation of local TSAs as needed. In addition, personnel 1 who will provide support in the operation of the local TSAs include additional Rockingham County Sheriff's deputies (up to six), Sheriff's deputies from contiguous counties, and other support personnel assigned this responsibility.

Assignments such as the distribution of bus maps, logging in of vehicles, distribution of dosimetry and directing traffic at the staging area will be performed by the support staff. Sufficient numbers of personnel are

available to Rockingham. County Sheriff's Department to implement their assigned emergency response functions at State and local TSAs. Summary at Table 3.1-4.

EMEEGENCY WORKER RADIATION EXPOSURE LIMITS Radiatlon exposure limits for emergency workers are specified in the NHRERP. Volume 1, Section 2.7.4 establishes a radiation exposure limit of SR for local emergency workers.

Section 2.7.4 and Division of Public Health Services procedures (Volume.4A, IFO/RHTA procedures) describe the raechanism for reporting and tracking local emergency worker exposures to ensure that exposure levels are maintained within prescribed limits. This reporting and tracking mechanism allows for the management of emergency worker exposures by providing for reporting and tracking of exposure gradients beginning at 175 mR. NHRERP, Volumes 16-32 (local plans' Section II.H, instructs the local RADEF Officer to initfote actions at specified reporting levels to manage local emergency worker exposure. Management of emergency worker exposure would include rotation of assignments among te local emergency organization or removal from I members of assignments ind replacement of those emergency workers whose individual radiation exposures indicates a trend toward the established limit.

The SR exposure limit prescribed for local emergency workers corresponds to the highest value for whole body dose established by the US EPA PAGs for the general population.

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While the EPA PAGs establish an exposure limit of 25R for emergency workers, the State of New Hampshire has elected to set exposure limits for local emergency workers comparable to the highest levels prescribed for the general public. As expressed in NHRERP, Volume 1, Section 2.6.3, the State of New Hampshire has chosen to base its protective action decisions for the general public on the lowest values recommended by the EPA PAGs, that is, a one rem whole body projected dose'and a five rem thyroid projected dose.

When the protective action recommendation for the general public is shelter, local emergency workers would take the ,

same protective action. When the protective action of evacuation of the general public has been completed, there would be no need for local emergency workers to remain in affected areas. Therefore, local emergency workers would not be expected to exceed the SR exposure limit. Additional emergency tasks such as control of access to exclusion areas, field monitoring, plume tracking, and collection of environmental samples would be performed by state emergency .

I workers whose exposure limits correspond to those established l by the US EPA PAGs for emergency workers.

In sum, the local emergency worker exposure levels fall l

within the range established by the EPA PAG's for the general public. Local emergency workers have no emergency assignments to perform after protective actions for the public have been completed. At that point, local emergency

workers would take the same protective actions. It is the goal of the Division of Public Health Services to limit exposure to emergency workers at the same levels incurred by the general public. There is no intention of allowing local emergency responsibilities to go unmet prior to the completion of protective actions by the public.

i ASSESSMENT RESULTS The resource assessment program delineated the personnel needs in the local towns and at the State level. Assignments of available personnel were made to staff the various emergency. response organizations. This included the practice of reallocation of personnel from resource pools found to have a surplus to resource pools found to have' shortages.

Results of the assessment indicate show:

1. The State of New Hampshire end its supporting organizations have personnel available to staff the State's emergency response organization.

2. Eleven municipalities have assigned personnel to staff their responsive local emergency response organizations.

3. The six towns that have not presently made personnel assignments have personnel to staff their respective local emergency response organizations.

4. The State of New Hampshire has personnel available to provide full or limited state assistance to local l

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communities in need.

Circumstances involving personnel who normally provide support to a given community on a volunteer, part-time or seasonal basis, or who have residences or regular employment locations out of the area, are not unique to radiological emergency response planning. The availability of emergency workers to respond to an emergency does not necessarily depend upon their living or working within the affected community. Notification procedures, emergency response training, and drills and exercises ensure that the capability is maintained to notify emergency workers and that there is

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reasonable assurance they will respond.

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