ML20235E976
| ML20235E976 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/14/1987 |
| From: | Baranski J, Czech L, Papile J NEW YORK, STATE OF |
| To: | |
| References | |
| OL-3-I-NYS-001, OL-3-I-NYS-1, NUDOCS 8709280359 | |
| Download: ML20235E976 (45) | |
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st x - syITED STATES OF AMERICA
..l' UI NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station,
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Unit 1)
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DIRECT TESTIMONY OF JAMES D.
- PAPILE, JAMES C.
BARANSKI AND LAWRENCE B.
CZECH ON BEHALF OF THE STATE OF NEW ZORK REGARDING LILCO'S RECEPTION CENTERS i
April 13, 1987
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Aoril 13, 1987_
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j
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Defore the Atomic Safety and Licensi-Roard I
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In the Matter of
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l LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
('Shoreham Nuclear Power Station,
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Unit 1)
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l DIRECT TESTIMONY OF JAMES D.
- PAPILE, l
JAMES C.
BARANSKI AND LAWRENCE B.
CZECH ON BEHALF OF THE STATE OF NSW YORK REGARDING LILCO'S RECEPTION CENTERS i
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In t rodtict ion O.
Please state your names, occupations, and experience.
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i A.
[Papile] My name is James D.
Papile.
I am currently the Director of the State of New York's Radiological Emergency j
Preparedness Group ("REPG"), a position which I have held for a little over a year.
Prior to that and since 1980, I was one of three Associate Planners for REPG.
In my seven years with REPG I have helped write and/or retiew numerous radiological emergency response plans.
As part of these efforts, I have become familiar l
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with the factors which must be addressed when evaluating the suitability of reception centers and the adequacy of monitoring and decontaminating procedures.
A copy of my resume is attached to this testimony as Exhibit 1.
[Baranski) My ndme is James C.
Baranski.
I am a nuclear facility specialist with REPG and currently hold the additional position of Exercise Director.
I have been Exercise Director since January, 1985, and have been an emergency planning nuclear facility specialist since 1981.
I have had' extensive experience with' nuclear power operations, including eight years in the U.
S.
Navy Nuclear Power Program and six years as a Senior Reactor Operator at Indian Point Unit 3.
As a result of my duties with REPG, I have become familiar with the factors and standards to be considered in assessing whether reception centers are suitable for monitoring and decon-taminating evacuees and whether those factors and standards have i
been met.
A copy of my. resume is attached hbreto as E'xhibit 2.
[ Czech] My name is Lawrence B.
Czech.
My current position is Chief of Nuclear Protection Planning with REPG.
In that posi-tion, I am responsible for the preparation, maintenance, revi-sion, and oversight of the State portien of the New York State Emergency. Response Plan.
I am trained in health physics and have worked in the area of radiological health and radiation protec-tion for approximately 25 years.
Through my experience and training, I have become familiar with the evaluation of the-adequacy of monitoring and decon-tamination procedures in a radiological emergency plan, as well as the adequacy of the facilities and staff dedicated to those activities.
A copy of my resume is attached hereto as Exhibit 3.
L O.
What is the purpose of your testimony?
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A.
The purpose
- our testimony is to address the suit-l ability of the three facilities which LILCO designated in Revi-1 sion 8 of its Plan to serve as " reception centers."
The three facilities are LILCO-owned operati'ons centers located approxi-mately 40 miles west of the Shoreham plant in Bellmore, Roslyn 1
and Hicksville (all of which are in Nassau County).
See Plan, at 3.6-7.1 Under the LILCO Plan, in the event of an accident at the Shoreham plant involving a release of radioactive materials, residents of the EPZ may be advised to proceed to the reception centers for radiological monitoring and, if necessary, decontami-nation.
Id.; OPIP 3.6.1, at 2.
Specifically, our testimony will 1
address the adequacy of the LILCO's monitoring and decontamina-tion procedures described in Revision 8 of the LILCO Plan.
Where 1
All references to the LILCO Plan are to Revision 8, unless otherwise noted. - -
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possible, we will also discuss certain subsequent " draft" revi-sions of those procedures, contained in certain documen.ts, dated i
February 20, 1987, which were provided during discovery.
They are Attachment P to LILCO's testimony and will be cited as the
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" Draft Materials."
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We focus on the following matters pertaining to LILCO's monitoring and decontamination procedures.
First, we testify-regarding.the new planning basis underlying LILCOs monitoring
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and decontamination procedures.
Second, we address the. adequacy of the methods used by LILCO to monitor evacuees arriving at'the three reception centers.
In conjunction with this testimony, we address the amount of time necessary to monitor arriving evacuees and their vehicles.
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L Third, we discuss the adequacy of LILCO's decontamination procedures.
Finally, we discuss whether LILCO has adequate staffing to provide necessary monitoring and decontamination
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services to evacuees arriving at its reception centers.
1 Out testimony is offered to assist the Board in resolving the following issues which have been admitted by the Board:
1.
Whether LILCO's new monitoring procedures are adequate; I
2.
Staff. requirements given LILCO's new reception center scheme; and l -
3.
Whether the proposal to send evacuees to LILCO parking lots could or would ever be implemented in a way to protect the public health and safety.
See Memorandum and Order (Rulings on LILCO Motion to Reopen Record and Remand of Coliseum Issue) (December 11, 1986), at 17, i
1 18-19.2
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For reasons explained more fully below, we conclude that f
i LILCO's Plan and procedures, as they pertain to the reception centers, are inadequate.
II. LILCO's Plannino Basis Q.
What does the term " planning basis" mean in the context of LILCO's reception centers and monitoring procedures?
I A.
In the context of this proceeding, the term " planning basis" means the estimated number of people who may arrive at I
LILCO's reception centers for monitoring and, if necessary, decon-tamination.
Assuming that such an estimate is sound and based on prudent emergency planning principles, the emergency planner can l
2 Our testimony regarding the actual tiae required to monitor evacuees is also relevant to the issues regarding traffic con-gestion in and around the reception centers, which are presently before the Board.
Id.,
at 7, 18-19.
As explained by the State's expert witnesses from the Department of Transportation, the abil-ity of the reception centers to function effectively is strongly affected by the rate at which LILCO can monitor arriving evacr-'n and their vehicles.
Direct Testimony of David T. Hartgen and Robert C.
Millspaugh on Behalf of the State of New York-Regarding LILCO's Reception Centers (April 13, 1987).
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l determine the number of personnel and the amount of equipment which must be provided at the reception centers for monitoring and decontamination purposes.
In addition, the emergency planner can determine whether the facilities provided as reception centers are i
physically capable of serving as reception centers.
This Board has previously found that LILCO's failure to provide an appropriate planning basis made it impossible for the Board to determine whether LILCO's earlier-designated reception center (the Nassau Coliseum)'was suitable.
Concluding Partial Initial Decision.On Emergency Planning, LBP-85-31, 22 NRC 410, 417 (1985).
Q.
What planning basis has LILCO chosen in developing the i
reception center-related portions of the most recent versions of
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its Plan?
i A.
In the only " official" version of the Plan presently before the Board, which is Revision 8 of the LILCO Plan, LILCO has provided no planning basis regarding its reception centers.
Therefore, Revision 8 of the LILCO Plan suffers from the very same 1
deficiency noted by the Board with respect to earlier versions of I
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the LILCO Plan.
Judging from LILCO's testimony, however, LILCO appears to have adopted a 20-30% planning basis.
See also Draft Materials, Plan at 3.9-5.
Given the 1985 estimated summer population of the I
EPZ as 160,000 people, this means that LILCO claims to be provid-1
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ing planning and resources to monitor 32,000-48,000 people at its reception centers.
If more than that number of evacuees arrived for monitoring, LILCO would be required to rely on "ad hoc I
measures" to monitor any higher percentage of the population.
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Draft Materials, Plan at 3.9-5.
Q.
Is LILCO's apparent 20-30% planning basis appropriate?
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1 A.
No.
In our opinion, an emergency plan and associated i
j procedures should provide planning and identify resources j
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(personnel, and equipment) to monitor 100% of the EPZ population
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-- in this case, 160,000 persons -- within about a 12-hour period.
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Q.
Please explain the reasons for your opinion.
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l A.
NUREG 0654 Section II.J.12 states:
l Each organization shall describe the means for registering and monitoring of evacuees at l
relocation centers in host areas.
The per-l sonnel and equipment available should be capa-ble of monitoring within about a 12-hour l
period all residents and transients in the l
plume exposure EPZ arriving at relocation centers.
(Emphasis added).
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3 A common-sense reading of Section J.12 means to us, as emergency planners, that there must be planning for monitoring 100% of the EPZ population.3 NUREG 654 requires planning for a spectrum of accidents, not just accidents affecting only 20 or 30% of the population.
Planning for monitoring 100% of the EPZ population,
is required to deal with the spectrum of accidents which are the basis for NUREG 0654.
This interpretat?.on is consistent with comments we have received from FEMA personnel in the past to the effect that compliance with Section J.12 requires planning and resources for monitoring 100% of the EPZ population.
i Nothing in Section J.12 suggests that a plan need only pro-vide personnel and equipment for 20%, 30%, or some other fraction of the EPZ population.
In addition, neither the LILCO Plan nor j
LILCO's testimony provides a reasoned basis for adopting a plan-ning basis as low as that'found in the LILCO Plan.
In our opinion, no basis exists.
An accident at the Shoreham plant could require monitoring of a much larger fraction of the popula-l tion than the 20-30% LILCO assumes; severe accident conditions might even require monitoring the entire EPZ population.
In fact, in the exercise of the LILCO Plan held on February 13, l
1986, LILCO instructed (simulated, of course) over 95,000 people l
to report to its reception center (at that time the Nassau l
Coliseum) for radiological monitoring.
This scenario, which was l
3 Note that while Section J.12 mentions " relocation centers,"
registration, monitoring and decontamination in New York State is I
typically done at " reception centers" with shelter provided at
" congregate care centers."
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part of LILCO's own exercise, demonstrates that it is reasonable r
for planning purposes to assume that a much larger number of people than merely 20-30% of the EPZ population will require or seek monitoring.
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.1 In addition, we believe that it is probable that some people will seek monitoring even though not advised to do so.
This is because radiation is perceived as a unique type of hazard.
People cannot determine whether they have come into contact with it without the use of special instruments.
People are also generally more fearful of radiation than other types of hazards.
This perception, coupled with the properties of radiation, make it likely that members of the public may travel to LILCO's reception centers to be monitored even though they have not been advised to do so, and even though they may not have an appropri-ate technological or scientific basis to believe that they have been contaminated.
This was demonstrated during the 1979 l
accident at TMI when some people appeared at the Albany Medical 1
1 Center and requested to be monitored, even though they were 200 1
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miles or more from TMI.
Furthermore, neither Revision 8 of the LILCO Plan nor the Draft Materials describe (nor could LILCO probably implement).any means to distinguish between evacuees from areas advised to seek monitoring and those from other areas.
Those people seeking monitoring, but who do not really require it, will therefore be.
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d placing additional demands on the monitoring resources provided by LILCO under its Plan.
This means it will take longer to:
complete the monitoring of those who actually require monitoring i
and to identify those who need decontamination.
In short, we believe that at a minimum, LILCO must plan and identify resources for monitoring all EPZ residents within the approximately 12-hour time frame specified by NUREG 0654.
We consider this to be a prudent approach for emergency planners to take.
Anything less would mean that under certain accident situ-ations, LILCO would not have the resources or-personnel to pro-vide monitoring in a timely manner to those members of the public who need it.
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l Q.
What are the implications of LILCO's intention to J
provide planning and resources for monitoring less than 100% of the EPZ population at its reception centers?
A.
LILCO's low planning basis means that in many accident scenarios, LILCO will be unable to meet the NUPEG 0654 require-I ment that al'1 EPZ residents and transients arriving at LILCO's reception centers be monitored within approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Delays in monitoring the public beyond the time frame set forth in NUREG 0"54 will mean that those members of the public requir-ing decontamination will not be identified in a timely manner.
Delays in decontamination could lead to unnecessary exposure to - _ _ - - - - _ _ _
s t
ionizing radiation.
One of the principal tenets of_ radiation protection is keeping exposures as low as reasonably achievable.
By failing to meet the guidance specified in NUREG 0654, the potential for unnecessary exposure is increased.
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f O.
What does LILCO rely upon to support the 20-30%
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planning basis set forth in the Draft Materials?
A.
LILCO's apparent basis is a December 24, 1985, memo-randum authored by Richard W.
Krimm, Assistant Associate Director for State and Local Programs and Support, Federal Emergency Management Agency.
The Krimm Memorandum, which is Attachment L to LILCO's testimony, states that Section J.12 of NUREG 0654 is met where planning and resources are provided for 20% of the EPZ population.
If more than 20% of the EPZ population arrives at an applicants' reception centers, unspecified "ad hoc" measures are l
to be developed and implemented during an accident.
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Q.
Do you agree with the Krimm Memorandum and the 20%
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planning basis it suggests?
1 A.
No.
First, for the reasons explained abcVe, the Krimm Memorandum is in conflict with the plain language of Section J.12 l
and the guidance which we have previously received from FEMA l
personnel interpreting this provision.
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Second, the basis for the Krimm Memorandum is not clear.
The Memorandum notes in the second paragraph that while." previous experiences" in unspecified natural and technological. emergencies are "not conclusive," "research" shows that "anywhere from 3 to j
20% of the evacuees arrived at relocation centers or shelters."
LILCO Attachment L at 1.
It appears, however, that this range of percentages is derived from the number of people who have sought shelter, not monitoring, in previous emergencies.
The Krimm Memorandum then concludes that because people will want to allay l
their concerns about radiation, the upper bound of the 3 to 20%
shelter-seekina range is appropriate for determining the number of people who will go to reception centers for monitorina.
The Krimm Memorandum confuses two separate functions --
1 seeking shelter on the one hand and seeking monitorina on the other hand.
Using data pertaining to shelter-seeking to support l
estimates of those in need of monitoring, as the Krimm Memorandum does, is contrary to this Board's and the Appeal Board's l
conclusions that the former provide no support for the latter.
ALAB 855, 24 NRC (Dec. 12, 1986) slip op. at 9, 16-17 l
("ALAB-855"); LBP-85-31, 22 NRC 410, 417 (1985).
In rejecting LILCO's previous attempts to confuse the two distinct functions, the Appeal Board stated in ALAB 855 that:
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1 LILCO's planning estimate simply failed to take into account that radiological accidents produce a-category of individuals who require monitoring and decontamination, even if they do not require sheltering.
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ALAB 8 5 5, slip. op. at 9.
The Appeal Board went on to state that:
Surely, the need of evacuees for raonitoring and decontamination services does not hinge to any extent upon whether they have been able to make their own sheltering arrangements.
It seems highly probable that many individuals who manifestly should be monitored as a matter I
of caution will both wish and be able to obtain sheltering at other than a facility supplied by LILCO or another participant in the emergency response plan.
Id., slip op. at 16, 17 and n. 31.4 Finally, the Appeal Board Stated that in this reopened pro-ceeding, LILCO's 20% planning basis could be reasserted before the Licensing Board, but that LILCO's claim that this figure was adequate " appears to us to be of dubious validity."
Id. at 18.
4 See also this Doard's Concluding Partial Initial Decision on Emergency Planning, LBP-85-31, 22 NRC 410, 417 (1985) in which this Board found that the number of persons expected to seek shelter in the event of a disaster is not necer,sarily the same a' the number of persons who might seek monitoring in the event of a radiological accident.
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Likewise, the Krimm Memorandum must be considered to be of
" dubious validity."
For the same reasons articulated by this Board and the Appeal Board in rejecting LILCO's attempt to link a l
shelterina planning basis with a monitorino planning basis, the.
Krimm Memorandum must be rejected.
The Krimm Memorandum is also inapplicable because it does not address the circumstances which would apply to an emergency response under the LILCO Plan.
If a release of radioactive mate-rials occurs during an accident at Shoreham "with the potential to contaminate evacuees," those evacuees will be instructed by EBS messages to proceed to LILCO's reception centers for monitoring.
1 Plan, OPIP 3.6.1, at 2.
The Krimm Memorandum does not appear to a
take into account what will occur when evacuees are instructed to go to a specific site Ior monitorina or analogous reasons.
Under I
certain conditions, far more than 20% of the population may be told to do so.
FEMA has no basis for suggesting that at most only 20% of EPZ residents would comply with this instruction, or that it is permissible under NUREG 0654 Section J.12 to rely upon ad hoc measures for evacuees in excess of a particular fraction of the EPZ population.
We should also note that the Krimm Memorandum was never brought to our attention by FEMA, and we were only made aware of it at the commencement of the most recent reception center litigation by our counsel.
This is contrary to FEMA's normal
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f procedure of providing us with applicable guidance.
If FEMA' i
seriously intended the Krimm Memorandum to be implemented as general guidance, uc believe FEMA would have circulated the Krimm Memorandum (or the substance of it) to us and to others.
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l In short, based upon our experiences in conducting federally-evaluated exercises and our experience in the FEMA plan review process, the State's interpretation of NUREG 0654 Section J.12.is that there must be planning and identification of resources for l
l monitoring 100% of the population of the EPZ within about 12 l
l hours.
We thus conclude that LILCO's 20% planning basis is inade-quate for proper emergency planning, and that the Krimm Memorandum provides no support for that planning basis.
III. Monitorina Methodo 1.
Backcround l
l Q.
What is your understanding of how LILCO intends to moni-tor evacuees?
A.
Different procedures are described in Revision 8 and the Draft Materials.
In both cases, however, the pertinent informa-tion is contained mostly in OPIPs 3.9.2 and 4.2.3.
Under Revision 8 of the LILCO Plan, evacuees arriving in private vehicles enter the parking lots of the three reception centers and proceed to l l
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monitoring stations, each of which is manned by two LILCO monitors.
There are 14 stations at Bellmore, 10 stations at Roslyn and 24 stations at Hick'sville.
One LILCO monitor scans the hands and feet of the driver of the vehicle.
Vehicle passengers are not monitored at all.
The monitoring of the driver is done while he remains seated in the car.
The other monitor takes a
" swipe" of the top of the hood and a " swipe" from the wheel well.
Both swipes are then monitored for contamination.
OPIP 3.9.2, at 9-9a; OPIP 4.2.3, at 5-6, 15.
If the vehicle and the driver are determined to be " clean,"
any passengers are also assumed to be clean and the vehicle is directed out of the parking lot.
If levels of contamination are discovered above acceptable levels, then the vehicle and its occupants are directed to a decontamination trailer located within the LILCO parking lots.
OPIP 3.9.2, at 49a; OPIP 4.2.3, at 5-8.
LILCO estimates that monitoring a vehicle and its driver will take appro::imately 35 seconds per vehicle.
OPIP 4.2.3, at 6.
In contrast to the procedure used for persons arriving by private vehicles, people arriving by buses (i.e.,.those without their own means of transportation) are taken to the Hicksville reception center where they receive a full body scan, including a thyroid scan.
OPIP 3.9.2, at 6-8.
LILCO estimates that this procedure will take about 90 seconds, not including the thyroid i
scan which would take an additional five seconds for an adult and j
an additional 30 seconds for a child.
OPIP 3.9.2, at 7-8.
Under the Draft Materials, it appears that LILCO now intends l
to monitor all persons, passengers included, in an arriving
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private vehicle.
The areas of the body to be monitored have also been expanded to the head, shoulders, feet and hands.
The vehicles themselves are to be monitored by taking a swipe of about i
one-quarter of the front of the hood and one wheel well.
LILCO
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estimates that this process will take approximately 100 seconds l
per vehicle.
Draft Materials at 3.9-5, OPIP 3.9.2, at 9-9A.
i LILCO also estimates in the Draft Materials that it has sufficient l
resources and personnel.to monitor about 30 percent of the EPZ l
population within the time constraints of NUREG 0654 using this I
procedure.
Draft Materials, Plan at 3.9-5 through 3.9-6.
If (by a procedur'e not specified by LILCO) it is determined that a greater number of evacuees will require monitoring, LILCO will ask l
the Institute of Nuclear Power Operations ("INPO") for additional monitors to staff additional monitoring stations.
If (again under unspecified criteria or procedures) it is determined that timely i
INPO assistance is not forthcoming, or will not be adequate, LILCO's monitoring procedures will revert to the procedures set 1
forth in Revision 8 -- that is, only the driver of an arriving vehicle will be monitored.
Draft Materials, Plan at 3.9-5A.
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Bus evacuees appear to be treated the same way under,the Draft Materials as under Revision 8, except that under the Draft Materials, the monitoring will be done on the bus.
Monitoring is still estimated to take 90 seconds for each bus evacuee.
Draft Materials,'OPIP 3.9.2 at 9b.
2.
Concerns About Monitorino Technioues Q.
In your opinion, are.LILCO's monitoring procedures ade-quate to protect the public health and safety in the event of an accident at Shoreham?
A.
No.
Let us first address the procedure set forth in the only official version of this Plan before this Board, which is Revision 8 of the LILCO Plan.
LILCO's Revision 8 monitoring procedure calls for monitoring an arriving vehicle and its driver 1
only.
That procedure is contrary to NUREG 0654 which calls for monitoring all arriving evacuees, not just drivers.
In addition to being contrary to NUREG 0654, LILCO's proposal to monitor only arriving drivers is fundamentally unsound.
The apparent basis for this procedure is tha.t if the drivet is not contaminated, the passengers of the vehicle may be assumed to be uncontaminated as well.
This LILCO assumption,.however, does not logically follow.
For instance, the driver of a vehicle may have come from a different point within the EPZ than his passengers; or _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - _ - -
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he may have been indoors during the passage of the plume while passengers were outdoors.
In short, it is improper for LILCO to j
i assume that a passenger in a car is " clean" if the driver?is
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" clean."
Indeed, the Regional Assistance Committee ("RAC") found Revision 8 to be~ inadequate for, among other things, precisely this reason.
A copy of the pertinent portion of the RAC's findings, dated December 15, 1986, is attached hereto as Exhibit 4.
We agree with the RAC on this point.
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Second, monitoring the hands and feet only of any individual l
is not adequate.
This procedure could cause a monitor to miss other parts of the body that may be contaminated.
In our opinion, the best procedure is to give each arriving evacuee a whole-body scan as was done in previous versions of the LILCO Plan and as is done for bus evacuees.
This procedure takes longer, but it pro-vides greater protection for the public.
There is no supportable reason for evacuees arriving by private vehicle to be afforded less protection than evacuces arriving by bus.
j Third, we believe that LILCO's procedure for monitoring j
vehicles is also inadequate.
Vehicle monitoring is limited to a
" swipe" of the front hood and of a wheel well.
This is not enough.
In our opinion, the outside surface of the entire vehicle should be monitored.
Anything less means that possible " hot 1
spots" might be missed.
This in turn could lead to the eventual contamination of other things or people coming into contact with
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those vehicle areas that LILCO's procedures ignore.
In addition, we believe that the trunk of a vehicle should also be monitored if y
there are indications of contamination in other parts of the car.
It is possible that contaminated items taken from the EPZ may have been placed in the vehicle trunk.
To our knowledge,.the LILCO Plan has no provision for monitoring the trunkn of cars.
The Draft Materials, which are meant to be an improvement on Revision 8, also contain several deficiencies.
First, it should be noted that the monitoring of arriving vehicles is to be done in the same basic way as under Revision 8.
This is still inadequate for the reasons stated above.
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i Second, while the scope of evacuee monitoring has been increased somewhat, several problems still remain.
For instance, f
while the Draft Materials now call for passengers to be monitored, as well as drivers (at least until the equivalent of 30% of the EPZ residents arrive), it should be noted that the monitoring-of i
all vehicle occupants is to be done inside the vehicle.
We are not necessarily opposed to this procedure, but it has drawbacks.
j Monitoring passengers inside an automobile is, to say the least, i
awkward.
Monitors are going to have to reach into arriving vehicles with their probes.and, in some cases, even crawl into the automobiles.
Monitoring people in the back seats of two-door vehicles will be especially difficult.
Our concern with this procedure is that LILCO has apparently devised it as a means of !
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f monitoring large numbers of people quickly.
-Indeed,-LILCO seems to believe that a vehicle and all of ite occupants.can be sc[nned in only 100 seconds.
Draft Materials, Plan at 3.9-5.
Asjdis-:
cussed below, we dispute this time estimath. fHoQever, nci matter
.\\ f what the circumstances, monitoringLmust be done'caref,dlly.
Monitoring. passengers while they-are seated in lol:ati]ons yhich are t
accessible only'with difficulty may cause improper sca.nning.;and f
inaccurate results.
Inaccurate monitoring results j<;an lead to undetected' contamination which could, in turn, lead to adverse health consequences.
Third, we also note that while additional areas of the body are being monitored, LILCO is still not.providing a whole-body survey.
Thus, areas of possible contamination may be missed, especially on the back of the shoulders.
We find this to be unacceptable.
Fourth, we do not agree with LILCO's intention to provide monitoring for all arriving evacuees only until it appears that more than 30% of the EPZ population will arriv,e at the reception centers, at which time LILCO intends to revert to the Revision 8 procedure that was previously found to be inadequate by the RAC (i.e. - driver's hands and feet only are monitored).
For the same reasons that the procedure in Revision 8 is inadequate, the " fall- - - _ _ _ - - - _ _ -
1 back" procedure set forth in the Draft Materials is also inadequate.
As stated above, in our opinion LILCO must provi6e I
monitoring for all evacuees arriving at the reception centers.
1 We are also skeptical about INPO's ability to provide personnel and resources in time to assist LILCO in meeting Section J.12's 12-hour time limit.
Our skepticism is supported by' events at LILCO's February 13, 1986, exercise during which INPO was contacted for the purpose of providing additional monitoring personnel.
INPO reported that the arrival times of additional personnel ranged from six to seven hours up to 15 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.
This highlights the need for LILCO to provide more of its own
]
resources and personnel sufficient for it to monitor the entire EPZ populat'an.
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Record Keepino Q.
Do yo ave any other concerns about LILCO'e onitoring procedures?
l A.
Yes.
We have an addit' concern about inadequate record keeping.
Under the D t Mate 'als, the Traffic Guide assigned to each moni ing station is ins
'cted to record the license plc.te o# each vehicle monitored at his s ' tion and the number o eople in each car.
This is not sufficient.
In our ogi lon, it is important to record the names of all people ho
- 22
'have been monitored, whether they are contaminated or not, and, l
s\\
/,H to record their intended destination.
We hav Cound in possible,3. N j
our experience'with other emergencies that it is-dmportant to j
'*5s record the identitied'o.f all people goi g' hrough reception D's
{
s l
centers for purposes of reunitf g ramilies, providing data for i
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medical follow-ups, and,other suc r asons.
It is also useful to determine evacuee 6 destinations so that LILCO can respond appro-4
/'
priately t6 inquiries from anxious relatives or'others regarding l
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,e.t h's hereabouts of particular evacuees.
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4.
Time Recuired to Monitor j
Q.
You stated earlier that LILCO estimates that under the j
monitoring procedures established in Revision 8, a vehicle and l
driver can be monitored in approximately 35 seconds and that under l
the procedures established in the Draft Materials, a vehicle and its occupants can be monitored in approximately 100 seconds.
Do 1
you agree with LILCO's estimates?
1 i
A.
No.
Preliminarily, we wish to stress that monitoring must be done carefully.
The movement of the monitoring probe over the body cannot be too swift, otherwise an inaccurate reading will result.
Likewise, ignoring areas of the body.or of a vehicle means that contaminated areas may be missed.
For this reason, we generally estimate that it takes two to three minutes to monitor a person and two to five minutes to monitor a vehicle.
23 -
A
]
Regarding the procedures used in Revision 8 (the' driver-only l
procedure), 35 seconds may well te the amount of time, required to-q 1
complete them.
However, for the reasons we discussed above, those l
procedures are so inadequate that the 35-second time frame j
l 1
established by LILCO is meaningless.
A poor procedure is not made better by the fact that it can be done quickly.
With respect to the February 20 draft revision, LILCO's 100-l second estimate is based on two time trials conducted on January 5
)
i and February 10, 1987.
See LILCO Testimony at 42.
However, the l
data from those time trials are suspect for a number of reasons and do not support.LILCO's 100-second estimate.
First, the vehicles were monitored using the methods w'J oh we have already testified could leave much contamination undiscovered.
Monitoring
]
'I a vehicle properly takes more time -- between two and five
]
1 minutes.
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l Second, the 100-second estimate fails to account.for activi-ties other than scanning arriving evacuees and their vehicles.
For instance, the time trials did not adequately measure the time necessary for cars to pull up to the monitoring stations and then l
drive away after the monitoring process is complete.
This factor is especially important because cars will be entering most of the monitoring stations in lines of from.two to four cars.
See Plan, OPIP 4.2.3 at 17, 21, 25; Draft Materials, OPIP 4.2.3 at 17-17a,21-21a, 25-25a.
Using this method, a second line of cars cannot 9
l be pulled in to the monitoring stations until the last car of the I
previous series has been monitored and all cars are moved out.
The trials did not adequately test the scope of delays inherent in i
moving cars in and out of the monitoring stations in series.
In addition, the time trials did not take into account the time l
necessary to respond to questions posed by drivers or.the vehicle occupants, which could cause additional delays.
Third, the time trials were done in a controlled atmosphere and not at the reception center sites.
In particular, the January time trial was conducted only by LILCO monitoring instructors, not t
LILCO monitors themselves.
The time trials were also held in favorable conditions.
The darkness of night, or bad weather, l
might' delay the monitoring even further.
Moreover, because only a limited number of trials were conducted, such factors as fatigue or stress were not taken into account.
Fatigue or stress would slow monitoring times to well below the swift pace set by LILCO.
o Fourth, the 100-second time estimate does not take into 1
account possible equipment breakdowns, vehicle breakdowns, or other such " glitches".
Finally, it must be remambered that monitors are going to have to reach into or climb into the vehicles arriving at the monitoring stat 3ons.
If this is the way LILCO intends to monitor people, then extra care must be taken to j
assure that the aonitoring is conducted properly.
This means taking more time than the 100 seconds which LILCO assumes.
In short, we find LILCO's 100-second time estimate i
unrealistic.
Even conceding that some time may be saved by using LILCO's procedures, we estimate that it'would'actually take at 1
1 i
least three to five minutes to monitor cach arriving' car and its passengers.
O.
What are the consequences of your more realistic esti-mates of the time required to conduct proper monitoring of evac-1 uees in vehicles?
A.
Using more realistic estimates means that LILCO has provided planning, personnel, and resources-for even less of the population than the 30% it assumes in its Draft Mater.ials.
Given the three to five-minute estimate set forth above, we calculate that LILCO actually has the resources to monitor only from 10 to 17% of the EPZ population in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
S.
Staffino j
l 0.
Based on your testimony so far, what are your opinions regarding the number of personnel provided by LILCO for monitoring
~
r evacuees at the reception centers?
A.
Staffing levels are'not adequate.
Under Revision 8 of the Plan, only 40 monitoring stations (14 at Bellmore,'24 at i
Hicksville, and 10 at Roslyn) aie provided.
OPIP 4.2.3, page 15 I l
l i
i of 29.
Under the Draft Materials, only 10 more stations have l
1 purportedly been added, even though all arriving evacuees are to l
be monitored (until arrivals exceed 30% of.the EPZ population).
According to its testimony, LILCO intends to add 3 more stations.
I 1
l This addition of only 13 more monitoring stations is not sufficient.
As we demonstrated above, LILCO has provided only l
enough monitoring stations and staff to monitor from 10 to 17% of the EPZ population.
This is inadequate, even under LILCO's own i
planning basis.
Again, however, we emphasize that in our opinion j
Section J.12 requires that for planning purposes, LILCO must l
prouide monitoring personnel and resources sufficient to monitor all EPZ residents.
IV.
Decontamination Procedures Q.~
How is decontamination of evacuees to be conducted under the LILCO Plan?
A.
Under both Revision 8 and the Draft Materials, decon-tamination of evacuees who require it is to be conducted in trailers equipped with sinks and showers.
There will be two trailers located at Hicksville, but only one trailer each at Bellmore and Roslyn.
Each trailer has nine sinks and 20 shower heads.
See Draft Materials at 3.9-5A.
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J At the trailers,' contaminated individuals are remonitored, l
and instructed to remove contaminated clothing.
Then the skin l
l underneath the contaminated clothing is monitored.
If the skin is contaminated, the individual is' instructed to wash himself using a
)
four-step process, with the contaminated area monitored between
)
each step.
OPIP 3.9.2, at 10.
If successfully decontaminated, the person is given paper clothing.
See LILCO Testimony at 55.
However, it is not clear where a decontaminated person goes'after receiving the paper clothing (which is of some concern if that person's vehicle is still contaminated and he cannot therefore drive himself to shelter).
If the person cannot be decontami-nated, he is expected to dri've himself to an unspecified hospital for further treatment.
OPIP 4.2.3, at 7.
1 People awaiting decontamination are to be kept in the.
" transportation buildings" at Hicksville and Bellmore and the
" warehouse in Roslyn."
Draft Materials, OPIP 4.2.3, at 8.
O.
What concerns do you nave about the adequacy of these j
procedures?
i i
A.
Initially, we are concerned about whether the number of trailers, with only one trailer each at Bellmore and Roslyn, is enough.
As demonstrated by the testimony of the New York State Department of Transportation witnesses (Direct Testimony of David T.
Hartgen and Robert Millnpaugh on Behalf of the State of New
c York Regarding LILCO's Reception Centers), in a serious accident people may have to wait a long time for decontamination because of the lack of adequate showering and washing facilities.
Unfortu-nately, LILCO has not yet obtained the trailers, so that we have been unable to inspect them.
However, it must be questioned whether the trailers will be big ~enough to accommodate sufficient LILCO monitors and evacuees.
The Plan also does not indicate how I
long it will take to set up the trailers for their intended purposes.
If people do have to wait to be decontaminated, LILCO has provided inadequate facilities for sheltering such people.
The
" transportation buildings" at Hicksville and Bellmore are garages which are inappropriate for personnel and provide little space to sit, except on the floor.
The heavy equipment found throughout those buildings also presents a dangerous environment for evacuees.
The Roslyn warehouse is also unsuitable for keeping 1
people avalting decontamination.
Its floor space is filled with shelves containing various electrical equipment.
Thus there is very little space to put people, i
We also have concerns about LILCO's issuance of paper clothing.
While the use of such clothing is in most instances appropriate, it may nct be appropriate under the LILCO Plan i
because LILCO is providing virtually no shelter for people arriv-ing at the reception centers.
This is especially true at Dallmore and Roslyn where there is very little suitable sheltered space.
Thus, people may be' exposed to adverse weather conditions in nothing more that. paper clothing.
We note that LILCO attempts to address this point in its testimony by stating that it may be able to obtain blankets from " local suppliers" (LILCO Testimony at 55);
however, this proposed ad hoc response does not assure that appropriate clothing or other materials will in fact be available.
Finally, in our opinion it is absolutely wrong for-LILCO to expect a contaminated person who cannot be decontaminated at the reception centers to drive himself to a hospital.
A person told 1
that he has contamination which cannot be removed by normal means is likely to be distraught and scared.
Evacuees in that condition should not be left alone and certainly should not be sent back onto the road to drive in what will already be a stressful and l
l congested environment.
1 V.
Conclusions Q.
Please state your conclusions.
A.
LILCO's Plan and procedures for monitoring and decon-taminating evacuees are inadequate.
The planning basis adopted by LILCO, in our opinion, is not in accordance with NUREG 0654 Section J.12.
The Krimm Memorandum does not provide a basis for LILCO's inappropriately low planning basis. _
1
.In addition, the methods to be used by LILCO for_ monitoring i
evacuees, both under Revision 8 and the Draft Material, are inade-J I
quate and could lead to unnecessary exposure to radiation.
LILCO I
has also underestimated the time required to monitor evacuees and their vehicles.
This, of course, means that LILCO will actually 1
be able to provide monitoring to less than 30% of the population j
s within the approximately 12-hour time ~ limit of NUREG 0654 Section J.12.
With respect to staffing, LILCO has not provided sufficient l
staff to monitor 100% of the EPZ population.
In fact, given its underestimation of the time required to monitor evacuees and their I
l l
automobiles, LILCO appears to have provided sufficient staff to monitor only 10-17% of the EPZ population.
l Finally, we are concerned that LILCO may have insufficient capacity in its proposed trailers to decontaminate those requiring decontamination in a timely. manner.
In addition, LILCO's decon-tamination procedures have not provided adequate space for people requiring decontamination.
Q.
Does this conclude your testimony?
A.
Yes, it does.
(~ 1
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EXHIBIT 1 1
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4 James D. Papile G Capital Avenue Delmar, New York 12054 i
I OBJECTIVE _
To obtain a management position which will allow me to use executive management and anclytical experience.
SUBMRY OF OUALIFICAT!0?ts Extensive experience in planning, prograrning, budgeting and management for large procurement and maintenance program.
Advanced degree in management to include systems analysis.
Advance education in field of business l
education.
Completed over 30 years regular Army Service as a Colonel.
)
i CIVILIAi! RELATED MAttAGEliEllT 1986 - Present:
Director, Radiological Emergency Preparedness-Group for the State of ficw York.
1980 - 1985:
Associate Planner with the flew York State Radiological Emergency Preparedness Group involved with writing and addressing County, 1
Utilities and State plans for handling emergencies at Nuclear Power Plants.
1979 - 1980: Deputy Commander, Task Force Lake Placid for State of flew York during the 1980 Winter Olympics.
This Task Force provided logistic and administration support to the US Olympic Committee prior, during and after the 1980 Winter Olympics.
1976 - 1979_:
Supervised an organization of 29 personnel in 14 locations I
throughout State of New York.
Advisor to the Chief of Staff to the l
Governor of tiew York as well as to members of his office.
Acted as President of various boards in the handling of personnel and logistics matters.
1975 - 1976:
Deputy Program Manager for weapons procurement program which include the modernization of equipment to save the government millions of dollars.
The program included procurement of components, parts and l
equipment as well as providing the facility to have the job done.
lionitored government procurement procedures from writing of Referral for Bids through award and. production.
1973 - 10"5:
Chief of Maintenance, Rebuild and Overhaul Program which included aT1. types of equipment.
This world wide program was budgeted fdr approximately One Billion Dollars per year.
As Chief, was required to plan programs and budget over a five year period and then defend the program before Budget Analyst and Congressional Staffers.
The management of.the program required knowledge of systems analysis, computer oriented programs and a thorough knowledge of the Budget System.
EDUCATIOt Industrial College of Armed Forces 1973 - Master of Science, Logistics Management Air Force Institute of Technology 1967 - Graduate School of Education, Boston University 1950 - Bachelor of Science in Business Administration, fjortheastern University 1949 - Majored in Accounting.
Awarded permanent Teaching Certificate for Business Education, State of New York.
T W
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I EXHIBIT 2 s
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XHIBIT 2-RESUME l
JA:iES C. BARANSKI 1
Business Address:
Radiological Emergency Preparedness Group State Campus, Public Security Building Albany, flew York 12226-5000 Education:
Formal Training for Senior Reactor Operator Obtained SRO License #2102 i
May 1972 - April 1974 l
Westchesta Community College, Valhalla, New York i
A.A.S. in Business Administration September 1973 - August 1976 Iona College, New Rochelle, flew York l
B.S. in Business Administration August 1976 - December 1977 1
Experience:
January 1985 to present:
Exercise Director, Radiological Emergency Preparedness Group (REPG).
Lead responsibility for scenario writing, offsite exercise planning l
and development of offsite objectives.
Coordinates development of onsite/offsite scenario among Federal, State, counties and nuclear utilities te meet necessary objectives.
Responsible for ensuring that drills and exercise activities are
{
performed to maximize training requirements and meet definsd l
objectives.
December 1981 - January 1985:
Emergency Flaanina Nuclear Facility I
Specialist, Radiological Emergency Preparedness Group.
Provide ir. mediate concise technical evaluations to Senior State decision-makers during actual emergencies (Ginna), drills and fella l
eraluated exercises.
Provide technical support and interface with the nuclear facilities, NRC and FEftA in preparation of drill scenarios.
Develop, implement and conduct technicci training for State Commissioner, County Executive Officers and Health Officers, county dose assessment I
staff, public information staff and other REPG staff.
October 1978 - December 1981:
Nuclear Facility Specialist, New York State Energy Office, Nuclear Operations.
Perform reviews, analyze and prepara recommendations on safety related components, syster43, technical specifications, and operating, maintenance and testing procedures for nuclear power plants proposed and operating-in New York State.
liaintain an awareness of safety related problems, reportable occurrences, at nuclear plants throughout the State and United States, and determine the safety significance for each of the nuclear plants operating within State.
JAMES C. CAPAftSKI Indian Point Unit #3 Senior Reactor Operator _,
May 1972 - October 1976:
Consolidated Edison of New York, Inc., New York,tiew York.
l Responsible for the safe rnd efficient plant operation in_ accordance Supervise l
with all Federal, State and local and company regulations.
and coordinate all.-testing activities associated with the operationC and operability of plant equipment.
room operation and three plant operators.
Indian Point Unit #3 Test Supervisor.
i During construction phase of I.P. #3 coordinated and directed plant Responsibilities activities associated with the start-up program.
included writing 1.P. #3 operating and emergency procedures, completing start-up procedures and instituting changes to procedures when applicable j
f Mechanical Plant Operator, Connecticut Yankee January 1971 - May 1972:
Power, Haddam Neck, Connecticut.
Worked on all reactor plant, steam plant and auxiliary systems including During refueling temporarily 1
new fuel, spent fuel handling and movement.
l assigned as a Health Physics Technician working'primarily on steam gen 1
tube plugging project.
f United States Navy (Nuclear Power Program).
j September 1962 - December 1970:
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R E S U 11 E LAURENCE B. CZECH Business Address:
Radiological Emergency Preparedness Group State Campus, Public Security Building Albe 1y, NY 12226-5000 Education:
B.S. Physics - State University of New York at Albany January 1960 M.S. Physics - State University of New York at Albany June 1961 Experience:
January 1981 to present:
Chief, Nuclear Protection Plannino, Radiological Emergency Preparedness Group (REPG).
Duties include providing radiological (health physics) input for the State's emergency preparedness efforts for operating nuclear power reactors; assisting local officials in preparation of federally required local (county) plans and implementing procedures; participate in exercises and drills; coordinating the State's emergency plans and procedures with responsible officials in the States of Vermont, Massachusetts, Connecticut, and the Province on Ontario, Canada; coordinating the State's planning activities with the operating licensee's staff; and assisting in training for response to radiological l
emergencies.
Currently responsible for maintaining and l
updating the State portion of the Radiological Emergency Preparedness j
Plan and acting as a REPG liaison to Orange County.
May 1972 to January 1931:
Principal Radiological Health Specialist, Emergency Plans and Special Projects Unit, Bureau of Radiological Health, New York State Department of Health, i
Duties included developing and maintaining the general New York State i
radiation emergency plan for fixed nuclear facilities, assisting local disaster coordination agencies in developing local procedures to i
implement protective actions, and developing procedures for response to radiation accidents and incidents; i.e., spills, lost sources, overexposure and transportation incidents.
September 1970 to May 1972:
Senior Personnel Examiner, New York State Department of Civil Service.
Duties included development of written engineering and technical examinations for State and local merit system appointment 1 1
l February 1966 to September 1970:
Senior Civil Defense Radiological l
Representative, New York State livil Defense Ccmmission.
Duties included civil defense radiological training and planning activities.
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LAURENCE D.. CZECH
' 4 September 1965 to February 1966:
Science Teacher, l!. H. Lynch High School, Amsterdam, New York.
Duties involved teaching of high schoci physics and chemistry.
June 1961 to September 1965:
Senior Biophys'cist, Radiological Sciences Laboratory, Division of Laboratories and Research, New York State Departrent of Health.
Established and operated a calibration facility for radiation survey instruments used by State and local health regulatory personnel.
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~ - - - - - - - - -. _. - _. _., _ _ _.
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.6-am____am_m
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i LILCO hnn ltion P!nn for ChorchS.m - Rc),Jalen !!
j l'cy to Consolidated RAC Revle'd j
Dated Dae:rab:: 15,1003 q
i j
Tno Rc;lonci /e !stanco Corum!ttoo (RAC) r:v!:n et the LILCO Tran:ltion Plan fc fahorcina (Attachment I) b te.:d upon planning criteria ep:elfbd in NUR2G-0334, F E T.l A-R2P-1, Rev. 1; Criterla _ fer Procuration and Evaluatica of Radlole rical
_Emercerev Re:coan F1 tr.1 end Proca.redneca la cuenort of th!clor.r Ponce Planta Hoverab27,1000. Tin pkn hu bacn ove.luated cya!mt cach plan:,In3 ol2mont cpeciflod in MUllEG-03Sa cpplhabla to Stato and/e? Localjurledictlon. Thaco ovaluatleas cro hoy0d i
to tha foUouln; ratin; cyatco:
)
ADEQUAT3.%Y.I!G
=
4 (Ad:quata)
A* (Adequato - cencarna g rtaln!c3 to LERO'a 1:3c1 authority lentifhd 2.cing thia ravhn) l 7h'i GIOT20Gt I3 OdOQU3t:ly OCC.*0;J0d !3 Th3 clori10nt la Od2QUOtOl7 add 200Fd U 1
l
, t*u pbc.
Recoraconhtion3 fc?
th: pba provida; cen2:rna part31n:r.:l I
Inp;voc:. t chowa la ed:2 C70 LGt 13 L32OD h 31 Cuth:?D7 070 r300lV0f+
l 3
m:nhte:3 tut th $ con:!thrat' a Tha 1:x:3 c? h Ja1 tutht?itJ off001-l wotdd iteth w 1:: :y!: tha L230 pha, fr.; th:co clancata tra 02:::1501 b Th2a r:coram:nuat!:n Ino!u6 Attxh:aont 0 to ti:2 RAC rovian ci rovb!:n ta t'.u HU3F,G-0033 c:c:3-3;vbica'0.
raicro 20, c.20 oth a!.:
lin; ?GVo r3 2n t?.'
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LlLCO Transition Plan for Shoreham - Revision 8 Consolidated RAC Review Dated December 15,1983 Pace 11 of 15 NUREC-0654 Elem nt Revieu Cocment(s)
R:st i ng J.10.h In responso to an exercise lscue, the plan has been j
(Cont'd) revised to add a trtffic engineer to the sjaff at the TOC to evaluate any poss!bic impedimefits to evac-a !on and to make recommendation e on necessary n;es to evacuation routes in response to poten-c p
tial Impediments.
Procedures or fleid workers, us drivers, traffic guldp)s, to make pro etc., have been l.e.,
to include instrue on modif notiften ons through their communication network of any p tential Impedin nt. Provisions have been made to \\que an EDE messago in tne event that l
changes to c incuatlo routes are necessary.
Internal comt.wmentions within the LERO EOC regard!n; ass
,,n eut of an response to evacuation Impediment 1as ban, adequately cddrecsed through
\\
to the procedures (esp. OPIP 3.0.3, modificatj! <
Trrlfic pontrol). The 7vacuation Route coordinates q
la resp 6ralb!c for obtagtn; periodle updates from tha *vacunt'on Route Spot'ers, and for immediately repbtin; road impediments cr oth r problems to Coordinator (See OPl? 3.6.3, h>nd Road Logistics he Traffic Control Coordinat - t ction 5.0.7) Lead Traffic Gu!d s (at the sta;ln; arch ara to report any incident.
.J.10.1 See review of Revision 5.
A J.10.tr Sec revlaw of Revision 5.
A J 1 Sec ravlew of Revision 5.
A 7
J.12 See review.of Revision 5. In additlen, the fcliewing I
comments ric now tppilcable.
The LERO Reception Center previously designated at the Nassau County Veterans Memoritl Coliseum has been changed to three (3) LILCO facilitics located in E211more, Hicksville and Roslyn. The adcouncy of these facilities es reception centers must be cvd 'ad at a future excrelse.
^
LlLCO Transition Plan for Shorehem - Revision 8 Consolidated RAC Review Dated December 15,1980 Page 12 of 15 1:UREC-0654 Element Revieu Co=cnt(s)
,Rgtinq J.13 In cddition to the chaxJ of Reception Center (s)
I (Cont'd) locction, the plon specifle (rec page 3.fe' 5 of Reyblon 0) that a screening process will be Leed to ched evacuceo for contamination.
Inecming vehicles nUI be directed to monitoring stations where the vehicle and driver util be checked for contamination.
According to thb sercening
]
procedure, pcssenger; cf the vehicle nlll cico b:
i assumed to be uncontaminated and a clean tag will be !=uod to them if the driver b belon contaminc-tion limite. Thb cereening procedura is inndequate cinea the r_ppliccble guldanca require: tha capabult'r of monitoring within about a 12 hout parled all residents cnd transients in th: plumo EPZ arrivin; et th'c Reception Centers.
LERO is responsible for monItcrin; c.11 cvecucca j
i crriv*ac ct r:ccption centers. It is not cdcquate to plan for th's monitodr.; with cartonn:1 cud l
equipment when availabla.
It b not pecibic to evah' ate tin numb:r of par ennel required for i
monitorin; nt tha sp:clal population reception l
l eenters Lince the plan chona in precedtuo OPl?
3.0.5 pages 21-37, "to be arranged" for ocat of tha l
l crec! 1 population reception center:.
s E.
Rcdloloxicel Eposure Control H.3.2 Se eview of Revision 5. Se
- Issues involving I
I emer cy worker knowled nd use of dosimetry were ld SQfled at the ruary 13,1986 exercise.
ha
- n rated inadequate because I
Th!s clemet.+br s ing were not provided to the Bus dosimetry cn Drivers used oIsh. of evacuation.
j i
I (1)
, s Drivers used fo. school evacuation should be trained in the use o t' simeters.
(2)
Adequcic supplies cf dosimut; should be provided for Boa Drivers used h(school evccuation.
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k.