ML20235M834
| ML20235M834 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/21/1989 |
| From: | Sikich G LAVENTHOL & HOWATH, MASSACHUSETTS, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20235K640 | List: |
| References | |
| OL, NUDOCS 8902280448 | |
| Download: ML20235M834 (38) | |
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UNITED. STATES OF AMERICA-
' NUCLEAR REGULATORY-COMMISSION ATOMIC. SAFETY AND LICENSING BOARD
. ~Before the Administrative Judges:
Ivan W. Smith,' Chairman Dr. Richard F. Cole Kenneth'A. McCollom
)
In the Matter.of: ) Docket Nos. 50-443-OL
) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP).
OF NEW HAMPSHIRE, EI AL. -)
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(Seabrook Station, Units 1 and 2) ) February 21, 1989
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TESTIMONY OF GEARY W. SIKICH ON BEHALF OF THE COMMONWEALTH OF MASSACHUSETTS REGARDING THE ADEQUACY OF SECOND-SHIFT STAFFING FOR CERTAIN EVACUATION SPECIFIC POSITINS (JI-ll AND JI-12)
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a l e I- I.
SUMMARY
OF TES.TIMDEX Together, JI-11 and JI-12 raise the important issue whether.
the SpMC contains adequate planning to' ensure that New Hampshire-Yankee's Offsite Response Organization ("NHY-ORO")
can maintain and sustain a continuous (24-hour) emergency ressponse for a protracted period for certain " evacuation-specific" positions. These positions fall in two. broad i categories: (1) the NHY-ORO's own evacuation-specific positions, and (2) drivers of vehicles from contracted companies. The NHY-ORO positions in question are the following:
- Traffic Guides
- Monitoring / Decontamination personnel
- Reception Center Staff
- Dosimetry Record Keepers
- Route Guides The drivers at issue include those for all the manned-vehicles needed for emergency response services in an evacuation. These vehicles, all of which come from private companies, include buses, vans, wheelchair vans, ambulances, and tow vehicles.
The chief concern identified in this testimony is that for all these evacuation-specific positions, the SpMC does not provide reasonable assurance that there will be adequate, continuous (24-hour) staffing in the not-unlikely event that an evacuation, if ordered, is not completed before the first-shift personnel in these positions need to be relieved. In addition, there is no reasonable assurance of adequate first-shift staffing of the Monitoring / Decontamination personnel.
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l For.the ORO's own evacuation-specific positions, the SPMC provides less than enough personnel to fully staff two.fu11'(12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />): shif ts. Instead, to fully staff these positions, the SpMC relies on personnel from the Yankee Atomic Electric Company received through the Yankee Emergency Mutual Assistance Agreement. This'is an inadequate staffing mechanism because these workers.have not received ORO's pre-emergency training, and there is no assurance that they will be able to perform'in evacuation-specific positions adequately after receiving only a short briefing during the emergency from the first-shift workers they are replacing.
For the contracted drivers, the SpMC makes no provision ,
whatsoever to ensure that a full second shift of drivers can be mobilized in the event that the first-shift needs to be relieved before an evacuation has been completed.
II. QUALIFICATIONS Of_IllE_NI.TNESSES Q. State your name and current occupation.
I A. My name is Geary W. Sikich, and I am currently the Managing Director of Emergency and Environmental Advisory Services for Laventhal & Horwath.
Q. Is a summary of your background and gunlifications in the field of radiological emergency plann,ng contained in your pre-filed testimony on the topic of
- Inadequacies of the SpMC as it Pertains to Special populations"?
A. Yes.
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l I1I. HELCQRTERTJ_QN S_AHQ_ FJJ%' a_fD.S LT10_H Q:' What are the key issues raised by contentions JI-11 and JI-12 which you wish to address?
A: Content' ions JI-ll and JI-12 assert that the SpMC does.
not provide for adequate, continuous (24-hour) staffing for certain key positions that are active only during an evacuation. These positions are referred to in the SPMC and the contentions as
" evacuation-specific" positions. JI-11/ Basis A asserts that the "SPMC does not provide for the capability of continuous operations for a protracted period of time," because, inter alia , it " fails to identify adequate mechanisms for providing second shifts and backup personnel" and " fails to provide assurance of continuity of personnel from the contracted companies." Basis B and D of JI-11 and all of JI-12 focus the concern about ORO's staffing (apart from the contracted companies) on the SPMC's evacuation-specific positions: Traffic Guides, Reception Center Monitoring / Decontamination Personnel, Reception Center Staff, Route Guides, and Dosimetry Record-Keepers.
According to the SPMC, for all other ORO positions, " positions will be staffed using two alternate shifts, with a third shift available as a backup." SPMC, S2.1.1. But the above-mentioned
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.,; w evacuation-specific positions are-not staffed in this manner with a full second shift and'a' full third (backup). shift. The SpMC indicates that enough ORO workers are available for only one full shift. While the SPMC does indicate that' some extra workers will'be available for these positions as backup (i.e., to fill in for those first-shift workers who cannot be mobilized), there are not'enough of'these additional workers to constitute a full second shift. The SPMC offers this explanation:
If an evacuation is required, the . ,
[ evacuation-specific] functions will be performed' over a relatively short period of time as opposed to the entire. emergency situation which may last for a protracted period. Therefore, these evacuation-specific positions will have one compliment only with additional. personnel, at least 20 percent, available as backup as noted in Figure 2.1-1. For the positions of Monitoring /
Decontamination Personnel, Reception Center Staff, and Traffic Guide, additional manpower s'pport u will be requested from Yankee Atomic Electric Company through the Yankee Atomic Mutual Assistance Plan. This will ensure a second shift for these positions.
SpMC, S2.2.1, p. 2.1-1.
Thus, while the SpMC expects that the need for the services performed by workers in these evacution-specific positions will normally end before the first shift needs to be relieved, it does admit the possibility that this need could continue for a longer period. To address that event (at least for
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three of these positions), the SPMC relies upon additional manpower from the Yankee Atomic Electric Company through a mutual assistance plan.
As to the manned vehicles, the SPMC directs that all the bus and van drivers be mobilized upon the declaration of a Site Area Emergency ("SAE"), agg SPMC, IP 1
2.10, S5.1.4( ), while all the ambulance drivers are mobilized 1
at the Alert level, Special Ambulance Service Procedures at 6.
There appears to be no provision in the plans for second shift of drivers in the event the first shift has not completed, or perhaps has not even begun, an evacuation before the first shift needs to be relieved.
Of course, the ultimate issue here is whether this staffing scheme provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency which necessitates an evacuation. That question, however, encompasses a number of subsidiary questions: i
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- 1. Is it prudent to presume for planning purposes that, after these evacuation-specific workers are mobilized, an evacuation PAR will issue and the functions these workers will perform will be completed before these workers need to be relieved? As I will explain below, in my opinion the answer to this question is no; this is not a sensible or prudent j planning basis.
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- 2. Is it adequate to rely on the Yankee Atomic Mutual' Assistance Plan for the ORO's' additional-
.second-shift evacuation-specific workers? As I-will'
.also explain-below, in my opinion this is not currently a viable or' adequate mechanism.
- 3. .Are the staffing plans adequate witht respect to the drivers of the buses, vans, ambulancesLand other manned vehicles, or is some additional second-shift capability required? Again, in my opinion, the SPMC's staffing plans for these drivers is inadequate without adding a second-shift capability.
Q: What position has FEMA taken with respect to the adequacy of the staffing for these evacuation specific positions?
A: In FEMA's Review and Evaluation of the SPMC (Dec.
1988), FEMA evaluates the SPMC with respect to criterion A.4 of NUREG-0654. That criterion states as follows:
The offsite respose organization shall be capable of continuous (24-hour) operations for a protracted period. The individual in the offsite response organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title.
In assessing whether the SPMC met this criterion, FEMA noted that the plan designates two shifts of persor.nel "for most positions." FEMA's SPMC Report at 13 (Dec.
1988). The Report then sunnarizes what the SPMC does with the remaining positions:
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The Plan states (Section 2.1.1) that certain evacuation related positions, as identified in Figure 2.1-l', only require one shift. In addition, the Plan provides a 20% staffing cushion for the single-shift positions to account for those who might be unavailable at any particular time.
FEMA's SPMC Report at 13.
FEMA's evaluation of whether this one-shift staffing meets criterion A.4 is one word: " Adequate." Id. No reasoning is given. It appears, therefore, that FEMA has accepted without reservation the notion that these evacuation related positions require only one shift.
In my opinion, this is a very risky assumption.
FEMA's evaluation of criterion A.4 is silent regarding the drivers of the manned vehicles.
V. ANALYSIS Q: Is the SPMC adequate to meet the A.4 criterion, in your opinion?
A: No, it is not, and allow me to explain why.
Q: Please, go ahead?
A: Preliminarily, I would like to explain the problem with the assumption that evacuation-specific positions will require only one shift. Then I will break my analysis into two parts: First I will discuss the nor driver evacuation-specific positions of Traffic Guide, Monitoring /Decon Personnel, Reception Center Staff, Dosimetry Recordkeepers, and Route Guides.
Then I will briefly discuss the driver positions.
i Q: What is wrong with the assumptin that certain evacuation-specific positions require only one shift?
A: It appears that the planners have relied on the evacuation time estimates in planning the staff needed for.these evacuation-specific positions. Thus,.
assuming that the lengthiest ETEs were in the range of 7-1/2 hours1# the planners have simply concluded that only one 12-hour shift of evacuation-specific werkers will be needed. The evacuation will be over before their shift ends. This assumes, of course, that the evacuation order is given to the public within about 4-1/2 hours of when these workers report for duty, i.e., at the SAE level. There is no assurancce, however, that such will be the case.
Indeed, the Planning Basis in NUREG-0654 suggests that planners assume that the time from the initiating i event to the start of an atmospheric release is from "o.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to one day." NUREG-0654, Table 2, p. 17.
Thus, it is entirely conceivable that an SAE could be dec]ared, evacuation-specific workers could be mobilized, and then many hours could pass before a General Emergency with an accompanying evacuation PAR is declared. This means that Traffic Guides, Monitoring / Decontamination 1/ This is an assumption based on the Board's NHRERP decision. I understand that the ETEs are still a matter of dispute between the parties.
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-Personnel, Reception Center Staff, Dosimetry
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-Recordkeepers, and Route. Guides could be on' duty, but waiting to spring into action,'foril2 or more hours
' before an evacuation PAR is issued and they'have'to begin:to perform their' duties. For many oflthese workers their assignments required-substantial alertness, attentiveness-to detail,-and at least for Traffic Guides and Monitoring / Decontamination Personnel, substantial physical energy. These attributes'.all deteriorate as'a person.gets tired.
Since we cannot' presume that these workers have been.
mobilized just after they woke up after a' full night's.
sleep but may have in fact already worked a full. day on their regular: jobs,.it is. simply.not prudent to assume that these workers can'be counted on to perform adequately for longer than.12-hours after they are mobilized. This means that prudent planners should plan on having a. trained second-shift to relieve'all these evacuation-specific workers (in'cluding drivers) in case no evacuation PAR is issued during the first 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or if it is issued but at a point well into the first shift.
Q: In the event that a second shift is needed, the SPMC proposes to obtain manpower to staff a second shift for three of the non-driver evacuation-specific positions from the Yankee Atomic Electric Company.
through the Yankee Atomic Mutual Assistance Plan.
What problems, if any, do you foresee with this staffing mechanism?
e l'-hf A: ~Let'me start with the Traffic Guides. The problems with'this; staffing mechanism are numerous. -According' to the SPMC,n95 traffic and' access control personnel are.needed to fully staff all the Access control Points and~ Traffic Control Points. In'the' event of an evacuation these Traffic Guides are to go out onto-busy-r'oadways'and, using.only their own hand signals andfsome traffic' cones which they have placed in locations specified'in the SPMC's intersection'n diagrams, facilitate and/or discourage'certain traffic movements.. Some of these' locations are on busy interstate highways'. Others are at critical intersections in the 6 EPZ communities, intersections which will be receiving an extremely heavy flow of evacuation traffic for many hours in the event of an evacuation.
The Applicants have indicated in their responses to discovery requests (Interrogatory No. 51 of the Mass AG's First Set) that they have recruited approximately 143 individuals to be Traffic Guides for the NHY-ORO. (See Attachment A hereto.) This means that in addition to fielding a first shift of Traffic Guides, they have 48 back-up Guides. It would be prudent to assume that some of the back-ups will be needed to fill-in for first shift Traffic Guides who l-
. l are ill, away on vacation,:or otherwise unavailable to respond. So'more than 50 individuals will-have to be' obtained from Yankee Atomic in the event.that a second j, shift is necessary.
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According to the SPMC,-all the individuals from L +
l Yankee Atomic who are recruited for Traffic Guide duty are sent first to the ORO Staging Area where they' ate to receive a briefing from the Staging Area Leader on the. Traffic Guide procedures and response actions.
- SPMC, IP 3.2, S5.1.9. After this briefing, Staging Area Administrative' Staff are "to train, supervise,
' support, supply, and dispatch mutual aid traffic guides." ' Id., S5.1.10. The Yankee Atomic workers are then disp 6tched into the field to their assigned intersections where they are to meet the first shift workers they are replacing and receive what essentially is on-the-job training ("OJT") from this worker. Ege SPMC, Appendix J, Traffic Guide procedures for TCPs/ACPs, J-1 to J-7.
It is this brief, haphazard on-the-job training process that is at the center of my grave concern about this second shift staffing mechanism for all of the ORO's evacuation-specific workers. In my opinion there is simply no assurance that this kind of training, if it can be called training, will produce i
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second shift Traffic Guides who are capable of l
adequately carrying out the crucial tasks required of l those in this position.
Keep in mind that ORO's first-shift Traffic Guides have received some formal pre-emergency training for performing this position. One of the
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NilY-ORO training modules, Module 11, is entitled
" Traffic and Access Control." See SPMC, S6. This module is given in a classroom format and lasts two hours. It is apparently presented to all of the ORO's first-shift Traffic Guides. While I have some very serious questions about that training module, at least the first-shift Traffic Guides have received some training regarding their procedures. It appears, however, that the Yankee Atomic mutual aid responders will not have received this formal training.
The Traffic Guide has a difficult and multi-faceted job to perform, one which is not intuitive, and one which in my opinion requires substantial training and understanding to carry out.
For example, the distinction between " discouraging" certain traffic movements and prohibiting those movements is not clear from the written procedures and needs to be addressed carefully in the Traffic Guide training. Also, the procedures for both ACps and TCPs
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-instruct guides'to implement." access control" by l l
discouraging inbound drivers from passing that point b "exceot for" federal, state and local emergency
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response personnel, emergency' response vehicles,
" employees of-the utilities responding to the plant who have appropriate identification," and " commuters returning to the EPZ to gather household members for evacuation." Id., J-2.and J-5.- They are also to-
.. "[a]dvise persons that they may be subject to L-radiation exposure if.they proceed beyond the ACP."
But.they are also not to " allow lines to. form at the
.ACP entering the EPZ." Id. If the inbound traffic flow is heavy, as it will be for a number of hours after the. declaration of an emergency, how one goes about, on the one hand, identifying discouraging inappropriate people from. entering the area and advising persons that they may be subject to radiation if they do and, on the other hand, avoiding the formation of long traffic lines is not at all clear.
One goal may actually conflict with the other, especially if traffic is heavy. But which is more
- important, preventing lines from forming or discouraging entry? The procedures do not answer this question.
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. Traffic GuidesLof' course are to' direct'and attempt to~ facilitate.trafficEflow, no easy task when one is not-in' unit...m, has.little'or no prior experience in directing traffic, and the traffic flow is extremely heavy and. congested. Training in this regard is crucial; otherwise the guide may create serious traffic flow problems or, worse yet,.cause accidents in which people may be injured, including-the guides themselves, or which block traffic flow.
Traffic' Guides must also report traffic blockages using an ORO radio or, if the radio should break down, 1
a commercial telephone. This means,-first, that the Traffic. Guides will need to know proper ORO communication procedures and how to use the radio.
Explanation also needs to be provided on what should be done if a commercial telephone is not nearby, in the event the radio does break down. Should a guide leave a post unattended to go hunt for a telephone?
The procedures do not answer this question either.
It is very doubtful that the Staging Area Leader will be able to engage in more than a generalized briefing when he meets with the Yankee Atomic workers.
The Staging Area Leader has presumably been on duty for a full shift by this point and may be quite fatigued. His procedures merely state as follows:
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personnel provided through-the activation of the Yankee Mutual Aid Plan, .after being' relieved of your. duties, provide a briefing and discussion on NHY offsite response traffic management, traffic guide procedure, status'of, emergency condition and response actions to the replacement traffic p guides.
IP.3.2, S5.1.9. This is simply a briefing, not in-a depth training. Next the mutual aid responders are turned over to four Staging Area Administrative Staff, who are "to train, supervise, support, supply and dispatch mutual aid traffic guides." Id., S5.1.10.
This too cannot result in any kind of adequate training. According to the SPMC's training plan, Een !
SPMC, S6, ORO staff assigned to " Staging Area-Administration" do not themselves receive the training for " Traffic and Access Control." In addition to my knowledge, none of these personnel are certified as training instructors in accordance with NHY's.or the SpMC's training procedures, or.INPO's certification standards. Id., Table 6.3-1. Thus, there appears to be no assurance whatsoever that they can " train" the mutual aid responders in any meaningful sense of that term. To the extent that these second-shift Traffic Guides receive actual training at all, it may come in the field when they meet up with the first shift guide they are to replace.
This training, however, is extremely unlikely to achieve the desired results for the following reasons:
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- 1. This trainingDmay.'well have'to occur in the -
. Lmiddle 'of a- very -busy intersection under the most
- trying of circumstances. ' Traffic.could be all tied up and snarled at'the time, demanding _the first-shift worker's full attention. It m'ay be raining or.
- snowing, or at night, or terribly cold with sub-zero-
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wind chills. Conditions which do not permit both the s
trainer and trainee to focus their attention on'the-training task for a sustained period of' time'just'will-not result in effective training.
- 2. The first shift guide'may not a trained trainer. He or she has presumably received the two-hour training module for Traffic and-Access.
Control.and may have participated in~some drills and a
field exercises. But because the SpMC. calls for retraining only annually, the training Traffic Guides have received may or may not be fresh in their memories at the time they need'to train their replacements. While participation in the emergency itself may refresh their recollections, an evacuation PAR may not yet have been issues in which case the first-shift guides will still be sitting in their vehicles near their assigned intersections when the replacements arrive; so their instructions about what to do may well be from memory rather than from the
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experience' gained that day. To be effective the
' guides must both (1) remember the details of the training they received-and (2) be able to' explain it' carefully to their replacements, i.e., . train.them.
- There is no assurance that they will be able to do either, especially since this will by-definition occur when the first-shift guides have been on duty for a full shift of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or so and will likely be extremely fatigued and anxious to-leave the area.
- 3. The first shift guides have no objective standards to apply to determine if the mutual aid responder'has been sufficiently trained to perform the.
job. The standard prescribed by the SpMC is a purely subjective one. The tra'ffic guide procedures instruct the guides as follows: " Prior to departing, ensure the relief personnel are sufficiently trained, to your satisfaction, and that they are capable of performing their assigned duties." Appendix J at J-3 and J-7.
This, of course, is an inappropriate way to. measure training results,.because the person subjectively gauging the effectiveness of the training is the very i
person who just aave it. Worse yet, these first-shift Traffic Guides have an actual incentive to find that the training they have just provided was effective, i.e., they get to go home if they find the l
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- . "satisfact' ion" standard-is met. If it is not, they.
l have to stay on the job. longer, perhaps knowing that they will be increasing their exposure to radiation.
Q. Do you have an opinion regarding whether these second-shift Traffic Guides will'be able to perform their jobs effectively?-
A.- Yes,,I'do. There is no reasonable assurance that the 50 or more Yankee Atomic 'second-shift Traffic Guides'will be able to perform their emergency functions adequately.
Q. What. concerns'do you have in replacing the first-shift Monitoring / Decontamination Personnel at the-reception centers with a second-shift comprised of Yankee Atomic mutual aid responders?
A .Again,.I' foresee a number of serious concerns. According to the SPMC, the NHY-ORO plans on utilizing 60 Monitoring /
Decontamination Personnel at the two reception' centers per shift. SPMC, S2.1.1. -The Applicants have recently. advised the Interveners,-however, that they intend to add four additional monitoring stations at each of their reception centers; so it appears that they will need eight more Monitoring / Decontamination Personnel, bringing the totai to ;
68.
The Applicants have indicated in a table (see Attachment A hereto) attached to their responses to discovery requests (Interrogatory No. 51 of the Mass AG's-i first set) that they have recruited 75 Monitoring /
Decontamination personnel for the reception centers. This means that the NHY-ORO has only seven back-up Monitoring /
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Decontamination Personnel, only about 12% more than'they.
need for the first shift.
Thus, FEMA appears to be incorrect when it concluded in its Report that-the SPMC provides a 20% staffing cusion
- for all the' evacuation-specific positions. FEMA Report at-
'13.
In my opinion, a 12% staffing cushion is not large
.enough,-especially for an emergency response plan staffed by utility worker volunteers rather than state / local
" regulars," to provide reasonable assurance that the first shift of Monitoring / Decontamination Personnel will be staffed, let alone the second shift. For all its other I positions, the NHY-ORO;has a full'first shift, a full second shift, and a full third backup shift. This means that it has a 50% staffing cushion for all its other positions. In my opinion this is reasonable staffing, and is not excessive, for voluntary emergency response organizations in order to ensure the all positions in the organization will be staffed in the event of an emergency. l l
If this is the standard (50%) that the ORO has adopted as the staffing cushion for all its other positions, I see no reason to set a lower standard for the staffing cusion for the first-shift evacuation-specific positions. It appears, however, that the SPMC would tolerate a 20% staffing cushion for evacuation-specific positions. See SPMC, I
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$2.1.1. While that section attempts to' explain why the SPMC does not rely on two full alternateishifts for these positions,=it gives no explanation why a smaller percentage' o
of back-up personnel are needed to back-up the first-shift personnel in these positions.
So, in my opinion, there is a real concern here whether there will be full staffing of-the first-shift Monitoring /
Decontamination Personnel at the reception centers. In'my opinion, the plans for first-shift staffing for these positions is not adequate.
Thus, it appears that it would be prudent to assume that none of the seven ORO back-up Monitoring /
Decontamination Personnel will be available for second-shift duty. They may.all be stepping-in for first-shift workers who are ill, or out of the area, or otherwise unavailable at the time. This means, of course, that a full contingent of 68 Monitoring / Decontamination Personnel may have to be requested from Yankee Atomic through the mutual aid plan.
According to the SPMC, all the individuals from Yankee Atomic who are recruited for monitoring / decontamination duty are to report to the monitoring trailers at the two reception centers. SPMC, IP 1.1, p.37. At the monitoring trailers, the Yankee Atomic workers are to meet the first-shift Monitoring / Decontamination Leader just after he/she has been relieved of duty by a second-shift replacement.
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The proceduresifor'the. Monitoring / Decontaminate' ion-Leader read as follows:
L -If the shift-change involves replacement personnel-provided-through the activation of the Yankee ~ Mutual.
Aid Plan,. aft'er being relieved of your duties, provide the replacement personnel:
A. A discussion of the monitoring / decontamination of evacuees.
B. The status of the emergency.
C. Methods of decontamination of personnel and equipment.
D. Metlads of decontamination of personnel and equ.pment.
E. A detailed discussion of IP 2.8 [ Dosimetry and Exposure Control] and IP 2.9 [ Radiological Monitoring and Decontamination].
'F. Training on the operation of the trailer.
IP 3.'4, $5.1.15. Egg alan IP 2.9, S5.2.19.
Then each of the Yankee Atomic workers are assigned to one of the following specific tasks:
= Monitoring individuals Decontaminating individuals Monitoring vehicles Decontaminating vehicles Decontaminating articles In IP 2.8 there are procedures for each of these five positions. For all of these positions except " monitoring individuals," the procedures instruct the worker to
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'" thoroughly brief and train your replacement on your duties and operations. Egg IP 2.8, SSS.S.9, 5.6.6, 5 . 7 .' 6 , 5.8.6.
Inexplicably; there is no such procedure for those who are monitoring individuals. It is not clear whether this'is merely a' word processing oversight or whether there was a specific intent ot leave this procedure out for those who will be monitoring ~ individuals. But as the procedures now read (through Amendment 6 of the SPMC), those Yankee' Atomic workers who will.be monitoring individuals on the second sliif t will' not necessarily be " thoroughly" briefed and trained by'the first-shift workers they are replacing.
Even if all the second-shift Monitoring / Decontamination Personnel (including those who are monitoring individuals) were to receive a briefing and " training" from the first shift workers, however, there is no reasonable assurance that adequately trained monitoring / decontamination personnel will~ result from this cursory process. This two-step process (first a briefing and procedures discussion with the Monitoring / Decontamination Leader and, second, " training" provided by the actual worker being replaced) is frought with so many potential problems that it cannot be relied upon to produce monitoring /
decontamination personnel who can perform these taske adequately.
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I cannot stress enough that these are important public health and safety positions. They.are front line emergency workers who will interact directly with the public. Some of the evacuees will likely be highly agitated further
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adding stress to this critical position. For most individuals evacuating the EPZ, this is their one chance to be monitored for radiation. If monitoring / decontamination work is performed sloppily, it is a tragedy, because hundreds if not thousands of people can suffer unnecessary health consequences.
The NHY-ORO does provide a measure of training to its first-shift Monitoring / Decontamination Personnel. According to the SPMC's training plan, SPMC, S6, Table 6.3-1, Reception Center Monitoring / Decontamination Personnel are to receive the following six training modules:
Mgdu1e No. Title Approx. Time __{liLL1 1 EP Overview 4 6 Monitoring 2 Decontamination Operations 15 Procedure Checklists 1 16 Tabletop 1 20 Communications 1 21 Instrument Use __ 1 Total - 10 Hrs The approximate times listed for these modules come from the Applicants' answer to Interrogatory No. 47 of the Mass l
l l 4 L I I !
AG's first set. While I have some serious concerns about the adequacy of this training, at least the first-shift l
Reception Center Monitoring / Decontamination Personnel have received some training regarding their SPMC procedures. It appears, however, that the Yankee Atomic mutual aid responders will not receive any of the SPMC's formal training.
Given these circumstances, and the degree of knowledge and skill required of those performing monitoring and decontamination functions, it becomes imperative that the Yankee Atomic responders come with considerable knowledge of health physics, dosimetry, and monitoring / decontamination procedures. Without this, in my opinion, a brief overview of the procedures during an emergency cannot be adequate.
There is no assurance in the SPMC, or in the mutual aid agreement itself, that the recruits who arrive from Yankee Atomic to fill these second-shift Monitoring / Decontamination slots will be appropriately trained Yankee workers. The Yankee mutual assistance agreement (" Agreement")(provided by the Applicants during discovery) does list " Monitoring /
Decontamination / Dosimetry" as a function which can be performed by some of the personnel it can make available.
But as with all mutual aid agreements, there is no assurance on any given day how many responders can be mobilized. Thus, the number of responders and the
capability of.the workers who'actually respond on atv given day _ vary somewhat. ;Even though the Agreement lists the potential availability of 133 personnel with~ monitoring /
decontamination / dosimetry skills, the Agreement notes:
"Not all personnel would be expected'to' respond in support.
of the Yankee Emergency Mutual Assistance Agreement because of responsibility to their own facility." Agreement at
- 11. Since the ORO needs.68 of the Yankee responders to be second-shift monitoring / decontamination workers, at least half 1(50%) of'the. Agreement's monitoring /decon/ dosimetry.
workers must be capable of responding. Given my opinion.
that volunteer. emergency organizations need to have sizable back-ups, in the range of 50%, to ensure a full staffing of all positions, the SpMC appears to be less than adequate if I it'is counting on the mutual aid agreement'to provide the ORO with 68 trained monitoring /decco/ dosimetry personnel.
In fact, since I believe that'the ORO will not be able to field a full contingent of first-shift monitoring /
l.
l decontamination' workers, it appears that the ORO may really need 80-90 of the Yankee Atomic monitoring /decon/ dosimetry I
workers, perhaps 10-20 for the first shift and 68 for the second shift. This is probably more than can be prudently I
counted on to respond. The situation could get even worse j i
if we factor into this arthimetic the fact that ORO has an insufficient number of Dosimetry Recordkeepers to field a 1
7..
p full'second' shift. 'It needs 48 of these.per shift-but has a total.of only 60. 'So'it appears likely that in the event
.that all the first-shift evacuation-specific workers need' to.be relieved, some of the'133 " monitoring / decontamination /
dosimetry"1 workers potentially available through the Agreement may need to be assigned to this: task as well.
The upshot is that there appears to be no reasonable assurance that the Yankee Atomic mutual aid agreement can supply enough people with monitoring / decontamination; skills to fill the 68 second-shift monitoring /decon positions the NHY-ORO needs to fill.
Assuming, however, that'enough of the Yankee Atomic workers'from the " monitoring / decontamination / dosimetry" group do arrive at the ORO's monitoring trailers to relieve the entire first shift (all five categories) of Monitoring /
Decontamination Personnel, I still-have a. number of concerns.
First, there is no reasonable assurance of the adequacy of the monitoring and decontamination skills and experience of these workers. I note from the Agreement that among the other categories of personnel available from Yankee Atomic is " Radiation Protection." There are also a number of categories of technical support personnel which appear to contain Yankee workers with health physics backgrounds. It thus appears that those most knowledgeable
about healthLphysics:in each of the Yankee organization's nuclear plants may be in these technical support categories other-than'the " monitoring / decontamination / dosimetry"
~
group. This raises questions about what. kind-of personnel
'the Yankee' Atomic " monitoring / decontamination / dosimetry" personnel actually are (on their daily jobs), and what kind of training they'have received. This training-is simply a black box; we don't_know what it contain's, how it was given, or how recently it was given. With all these uncertainties, it would be imprudent to assume, and there is no reasonable assurance, that these Yankee Atomic workers come fully equipped with all the prior knowledge and skills they need to perform adequately.
Probably, like'all worker groups, some will be more skilled; others will be considerably less so. _Some may-have forgotten much of what they had been taught; others may remember all they were taught but were taught poorly.
But even for those who are reasonably familiar'with-basic monitoring and decontamination techniques, the specifics of the SpMC's procedures will need to be learned. The specific pieces of monitoring equipment used by the ORO may be foreign to these workers, and they will need to learn how to use all the equipment correctly. In addition the monitoring trailers themselves may well present a foreign environment to them.
'O >
In such circumstances, the issue.becomes whether.the.
NHY-ORO's briefings and cursory'overiew of procedures'on" l
the day of the. emergency are capable of taking all of the I a
, Yankee Atomic arrivals, including the least capable among j
. I them, and doing what is necessary to provide reasonable assurance that they will be able to perform adequately.the task of monitoring and decontaminating'the public, their-vehicles, and their_ belongings. In my opinion, however,.
the SPMC's' briefings and cursory overview of procedures'do not provide this assurance for the following reasons.
First, the briefing provided by the Monitoring /Decon Leader, which he presents after he has worked a full shift and may be quite fatigued, is likely to be quite brief and generic in nature, rather than detailed and job-specific.
This opinion stems from an analysis of the logistics of the effort and the mixed nature of the relief group, i.e., it is a group which will be subdivided further to perform different tasks. As to logistics, there simply is not enough room, and in the height of an evacuation there will be too much commotion, for the I.eader to conduct a briefing inside the monitoring trailer for the 34 second-shift Monitoring / Decontamination Personnel that will report to each Reception Center. This briefi'a ' vill have to occur either outside the trailer or inside the reception center.
Both locations are problematic. It could be dark outside i
_ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ __.._.._.__-._______.m_____ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ . _ _ _
3 9 I't- t o'
4 the trailer,1 raining,.or very? cold. Inside=the reception center there could well be a substantia 1' crowd and much.
commotion, and neither reception center is equipped with a' separate lecture room. There appears to be no reasonable assurance'that-these reception' centers will be suitable for L - lecture purposes (e.g., there' appear to be no chairs).: If.
the Yankee Atomic arrivals must stand ~for the~ briefing, or sit on'the floor, a lengthy overiew of the procedures and monitoring /decon techniques'is unlikely. Given the circumstances, the briefing provided by the Monitoring /
Decontamination Leader- may be quite brief, and the learning environment may be so inhospitable that numerous details will be difficult to communicate.
In addition, there are peculiarities and important details concerning the' procedures, equipment, ano trailers.
that are going to be difficult to' explain in a large group setting. Moreover, those who will be monitoring individuals do not necessarily need to know the all peculiarities and details about decontaminating vehicles, and vice versa. Thus, the overview / briefing provided by the Monitoring / Decor.tamination Leader is not likely to be a lengthy and detailed .' presentation of the different procedures and eqcipmen: each of the five categories of monitoring / decontamination workers will use.
k -<
.[: tQ Y O '. ,
Takelfor example, the important_ issue'of-the flo'w path' ofLpeople in the monitoring / decontamination trailers. It
'is important, obviously,,to set up'and maintain a flow path Lthat' avoids the potential for " clean / dirty" contacts to.
occur. . Because of the very limited floor space in these' trailers,.however, the chances for " clean" individuals to
' brush or come into contact with " dirty" individuals are quite highs The Monitoring Trailer Flow path diagram in the SpMC,
'Ip 3.4', Attachment 4, does not answer many questions:
How.does a~ contaminated individual at a monitoring station at the southern.end (rear) of the trailer walk past the 13 other stations to the Decon Area without brushing against and/or contacting other individuals when the. trailer is at the height of activity, with new arrivals constantly coming in the Entry Door?' Will there -
be some mechanism to regulate and entry to ensure that the contaminated persons' don't have to push through a crowd of new arrivals who are waiting-to be monitored?
How will-decontaminated individuals leave the trailer? Through the Exit Door or through the doorway by the Decon Area?
Where do contaminated' individuals go or stand while waiting their turn to be decontaminated if the Decon Area staff are currently working on as many people as the area can accommodate? Will they form a line that backs-up into the Controlled Area?
There are simply a plethora of potential flow-path problems like this that persons working in the trailer need to be able to resolve appropriately. Yet the procedures do not mention them. A briefing on the written procedures alone, j
)
therefore,.cannot adequately instill the. skills those~
- working in the, trailers will need. Nor would other members of the-full group, which includes those who will'be assigned to monitor and decontaminate vehicles,.need to
-'know this information.
Logistics,-efficiency and common sense suggests, therefore, that the briefing provided by the Monitori'ng/L Decontamination Leader will be one which is generic and not detailed and job-specific. The job-specific details will be left to be addressed, if at all, by the first-shift.
workers.
The overview provided by the first-shift Monitoring /
Decontamination Personnel themselves, as opposed to that provided by the Leader, is extremely unlikely to achieve the desired results for reasons similar to those detailed for the Traffic Guides:
- 1. The procedure review well have to occur during the height of monitoring /decon activity under the most.
trying of circumstances. For each of the.five categories d
of Monitoring / Decontamination Personnel, the work involved requies some degree of public contact and communication.
l^
If lines form, and back-ups occur, the crowd itself, and the demand for attention it will generate, will hamper the effectiveness of the procedure review. The first-shift worker cannot simultaneously talk to evacuees and explain l 1
l
a l'
points to a' replacement. As I noted -bef ore, conditions which do not permit both the "trainet" and " trainee" to focus their attention on the " training task" for a substantial period just will not result in effective learning.
- 2. As with the Traffic Guides, the first-shift workers may not be trained trainers. There is thus no assurance that they will know how to present a comprehensive and understandable procedures review without being trained themselves on how to conduct training for adults.
- 3. - with the Traffic Guides, the first-shift Monitoring / Decontamination Personnel have no objective standards to apply to determine if the Yankee Atomic responders have been sufficiently instructed to perform the job adequately. They, too, are instructed in this fashion: " Prior to being relieved, thoroughly brief and train'your replacement on your duties and operations."
This raises again all of the problems I described above for the Traffic Guides.
Q. Do you have an overall opinion regarding whether these second-shift Monitoring / Decontamination Personnel will be able to perform their jobs effectively?
A. Yes. There is no reasonable assurance that the Yankee ;
Atomic replacements will be able to perform these monitoring l decontamination functions adequately.
i L_________._____ _
lf '('_
O.,'Do your views differ.in any substantial. regard with respect to the second-shift replacements provided by Yankee Atomic
.for the^other evacuation-specific positions.
A. No, they do not. I-foresee similar. problems for:the Reception Center staff. 'The SPMC requires 34 such staff.
per shift, see Figure 2.1-1, but the.ORO has recruited only 52, see Attachment 2 attached hereto,_not enough to field a full second shift. Yankee Atomic workers are to fill the void, but~the problems with this second-shift stafting mechanism parallel those for Traffic Guides and Monitoring /Decont' amination Personnel. For Dosimetry-Recordkeepers and Route Guides, however, the problems may
.be even worse. Section 2.1.1 of.the SPMC states'as'follows:
For the [ evacuation-specific] positions of Monitoring / Decontamination Personnel, Reception Center Staff and Traffic Guide, additional manpower support will be requested from Yankee Atomic Electric Company through the Yankee Atomic Mutual Assistance Plan. This will ensure a second shift for these positions.
Thus, it appears that for the evacuation-specific positions of Dosimetry Recordkeepers and Route Guides (see SPMC, Figure 2.1-1), the Yankee Atomic mutual aid. responders are not the source of second-shift staffing. This is confirmed by reference to the call-up procedures, which direct the Assistant Offsite Response Director for Support Liaisons to contact Yankee Atomic, if necessary, and request personnel for only three positions: Traffic Guides, Monitoring /
Decontamination Personnel, and Reception Center Staff. IP
K n, I-i.
f . .
1.1, p.37. According.to the SpMC, the NHY-ORO needs, per shift, 48 Dosimetry Recordkeepers and 166' Route Guides.
SPMC, Figure 2.1-1. In responding to discovery requests,
'the Applicants indicated (see Attachment'2) that they have r:cruited-only 60 Dosimetry Recordkeepers (giving them a 30% staffing' cushion). There is no. indication'in the SpMC where a fu11' contingent of second-shift workers would come from. This appears to be wholly inadequate.
Q. What,-if anything,- does the SpMC provide with respect to providing a second shift for the drivers of all the manned vehicles?
A. Again, I see.nothing in the plans to address this issue. 'I note from my review of the ambulance company. procedures that the companies are contacted by ORO at the Alert level, and then the ambulance company dispatchers are to " initiate call up of all personnel" (emphasis supplied). The procedures then go on to prescribe that at a Site Area Emergency the "available. ambulances" are to drive to the Staging Area and await an assignment. I see no procedures for relieving the ambulance drivers batate the need to have the ambulances available expires. The concern is that after reporting to the Staging Area, it could be many hours j before an evacuation begins, and then many more hours before it ends. It is simply not prudent to expect that these drivers can perform their tasks adequately for more than about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, especially cince they may well have been called-up at the end of a long work day and are tired when they report to the Staging Area.
l , 4"'
r
[ -~. 2 The proce'dures are; similar' for' the' bus and- vari l
l-drivers, except that. they. are ' called up at:..the SAE-and report.to'their~ bus.yar.ds, where they' wait'fori-their~
- e. ,
') assignments. There is~no mechanism in.the'SPMC for
[
relieving the bus and van. drivers before the need for the-
!-r buses and vans ends, t In my opini'on', having no mechanism for" relieving' bus and van drivers will result'in steadily decreasing and, ultimately,.; inadequate performance. Prudent. planners'would-develop'some. mechanism.for relieving the drivers with a second shift.
Q. Do you have'~any further testimony?
A. Not-at thisStime.
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