ML20247H135

Intervenor Exhibit I-MAG-91,consisting of Guidance Memo EV-2, Protective Actions for School Children

ML20247H135
Person / Time
Site:	Seabrook
Issue date:	05/17/1989
From:	Federal Emergency Management Agency
To:
References
RTR-NUREG-0654, RTR-NUREG-654 OL-I-MAG-091, OL-I-MAG-91, NUDOCS 8905310165
Download: ML20247H135 (14)

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00CKEi % A l %!CE GUIDANCE MEMORANDUM EV-2 BF.ANCH PROTECT!'/E ACTIONS FOR SC3OOI C3ILDREN Pur esa This Guidance Memorandum (GM) is' intended for Federal officials to aid them in evaluating emergency plans and preparedness for schoci children during a radiological..

emergency.

This guidarce is also intended for State and local government offic.als and administrators of public and private schools, including licensed and government supported pre-schocis. and day-care centers, for developing emergency response plans and preparedness for protecting the health and safety of students.

Eackerau-d The joint iederal Emergency Management Agency (FEMA) and Nuclear Regulatory Commission.(NRC) guidance document, :UREG-0654/TEMA-REP-1, provides criteria for protective actions f or.

. persons, including school children, within the plume exposure pathway emergency planning zone (EP3) in the event such protective actions are needed in response' to a radiological emergency at a commercial nuclear power plant. -The need :o address the issue of protective actions for school children stems from both she lack of detailed guidance on this issue and the expressed interest for such guidance from public

. interest groups, state and local government officials and

-Tederal Regional officials.

1 sana Guidance is provided in this GM'on school evacuation in two contexts:

for developing emergency response plans and for conducting and evaluating exercises. ' The primary mothed f::

protecting school children examined is evacuation to relocation centers.

This GM is a companion of the guidance on evacuation contained in GM 21, Acceptance Criteria for Evacuation Plans.

This specific guidance-related to school children is appropriate because of the interest and concern expressed about protecting the health and safety of school children during a radiological emergency at a commercial nuclear power plant.

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l children under ne con::nuous superv:s en of teachers and administ:sters from a sencel :o a relocation cen:e: 13 a viable and reasonable approach when conf ron=ed wi:n a radiological emergency.

The decision to implement a protective action :ecommendazion :o evacuate to a relocation cents: snould be tied to the nuclear power plant's eme:;ency

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ac: ion level : lass: fica:icn.

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Sece emergency, response plans include the protective action l

s::ategies of early evacuatice. and early dismissal.

If 5:2:e and local governments select one of these st:a:egies, : hen they ought to address it in their emergency response plan.

If. a State or local government elects to empicy early evacuation or early dismissal, this guidance is sufficiently flexible to cover.both strategies.

All of the general guidance for evacuation would apply with the addition of the special considerations for early protective actions at the end of this GM.

The recommendation to school officials to evacuate the scheel children to :elocation centers should specify the area (s) o be included in the evacuation.

For example, the evacuation could include schools within she two-mile radius of the plan and within three downwind sectors beyond the two-mile radius.

Prompt evacuation is not' advisable during exceptional situations such as having to drive through a radioactive 4

plume or into a severe blizzard.

Under these circumstances, the special population including school children, handicapped and/or immobile persons should be temporarily sheltered and subsequently evacuated, if need be, as soon as conditions permit.

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l School children and other special population evacuees (see also GM 25, RIP for Handicapped Persons) should be relocated outside the ten-mile E7Z in predesignated facilities :o 1

ensure that the accountability, s3fety and security of the evacuees can be maintained and to minimize vehicular traf fic andtelephoneusewithint.}eEPZ.

gangggi censideratiens.

For whatever protective action options are contained in e=ergency plans, the plans should include provision f or notifying parents and guardians ( e. g.,

through the Emergency Broadcast System (ESS)) of the status and locatica of their children during a radiological emergency.

Also, the plans should docu=ent the decision making process and criteria used for developing emergency peccedures for implementing protective action measures f or school children.

Acceptance criteria for developing and evaluating emergency planning and preparedness for school children are provided below.

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5 plin-ine standard and Evn12mtien Criterin J.

?-etective Resecame 911Nnine Standard A range of protective actions have been feveloped for :ne plume exposure pathway I?: f or emergency wor.<ers and :ne puclic.

Guidelines for :he enoice of protec::ve actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EP: appropriate to the locale have been developed.

(lCREG-065 4/TE tA-REP-1,

p. 59)

Evaluatien Criteria 1.14 Each State and local organi:ation shall establish a capability for implementing protective actions cased upon protective action guides and other criteria.

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shall be consis:ent wi:h the recommendations'of I?A regarding exposure resulting f:cm passage of radioactive airtorne pla=es (IPA-520/1-75-001), and with those of DEEW (OHHS)/FDA regarding radioactive contamination of hu=an food and animal f eeds as published in the Federal Re6ister of December iir if:Gr

+44 PR 56499t cetecer 22.1982 (47 IE 470731.*

2.11.

The organization's plans to implement pro:ective i

measures for the pla=e exposure pa:hway shall include:

1 J.10.a.

Maps showing evacuation routes, evacuation areas, preselected radiological sampling and monitoring i

points, relocation centers in host areas and shel:e:

areas (identification ~ of radiological sampling and monitoring points shall include the designator in Table J-1 or an equivalent uniform system described in the plan);

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J 10.5.

Maps showing population distribution around the nuclear facili:y.

This shall be by evacuation areas (licensees shall also pres'ent the information in a sector forma:);

J 10 e.

Meens for notifying all segments of the ::ansient and resident population; J.10 d.

Means for protecting those persons whose mobility may be impaired due to such factors as insti:utional or other confinement l

• Tor your inf ormation and ref erence, :ne 12/15/73, :EEE guidance has been superseded by the 10/22/92, guidance.

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Means of relocatient 3.10. h '.

Relocation centers in hos: areas whi:n are at leas:

five m les, and pref era:17 :en miles, 'revend :ne boundaries of :he plume exposure I?: (See K.3);

3.10.1.

Time escimates for evacua: ion of various sectors and distances cased on a dyna =ic analys:s / ime-=c:::n t

study under various condi:: ens) for :he plu=e exposure pa:hway I?" 'See Append:x 4;;

AT #Mdit L I'raeuatien 3 pg i g.,,

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.{" Execsure.?ar-way r erenney p13nn.. Aeeendix 4.!!.c. Srecial.Facilitv Peculation lL: An estimate for this special population group shall usually be done on an institution-by-institution basis. The means of transportation are also highly individuals:ed and shall'be described. Schocis shall be includ'ed in this segment (p. 4-3). 1 ~ l Arits g Review These evaluation criteria address the key planning -requirements concerning the evacuation of students fecm schools. The review unde'r these criteria is intended to ensure that adequate planning and preparedness capabilities exist to enable school officials to-evacuate students in :te event such a protective action is necessary during a radiological emergency. This guidance covers those actions from the :nitial notification to school officials of the need to evacuate the students to their arrival at r eleca: ion centers or other protective actions. In addition to these actions, the guidance also addresses time frames for accomplishing the protective. actions. For purposes of definition and re'forence to NURIG-0654/FIMA-REP-1, we are inc1Gding " schools" a=cng the types of institutions, the socility of whose population may be ' impaired during a radiological emergency, because most students are dependent on school officials for transportation to and from their residences. (See evaluation cri:erion J.10.d.) Also, " schools" are explicitly ref erenced in Appendix 4 on pages 4-2 and 4-3 as a type of "Special Facility Population" for which evacuation time f rames are needed on an institution-by-institution basis. The term, " schools," as used in this GM refers to public and private schocis, and licensed or government supported pre-schools and day-care centers. 4

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![ A e f 9 5 5 1.". C 9 C ? i t 9 f *_1 An emergency plan will y; cally oe acceptacle ander :nese evaluation cri:eria if it fully addresses une following emergency functions-for-the evacuation of, or c:ner appropriate pectective measures for, schoci chi *dren. y Local governments should take the initiative to identify and contac: all 2aglig and triva:9.senocl systems within the designa:ed plume exposure pa:nway EP:. :o assure tha: b e :.- public and private school officials address appropria:e planning f or protecting the health and safety of : heir students-f rom a commercial nuclear power plan: acciden. The planning of both the public and private school officials should be closely. coordinated with that of the local. government. Local governments should ensure that appropriate organi:ational officials assume responsibility for the emergency planning and preparedness for all.of.the identified schools. Local governments should also ensure that the emergency planning undertaken by these organizations is integrated within che larger offsite emergency nanagemen framework for the particular nuclear power plant site. In accordance with the guidance contained in GM 21, the - evacuation planning undertaken may be developed in three contexts: (1) Part of the existing radiological emergency preparedness plans, (2) A separate annex of an existing integrated emergency plan for many types of disasters and emergencies or (3) A m a pm e n

• a evacuation pi mm _Er all of the scheels it

- _ each'scheal t::.

• School officials should document in the plan the basis for determining the proper protective action (e. g., evacuation, early preparatory measures, early evacua ion, sheltering, early dismissal or combination) including:

Identification of the organization and officials responsible for both planning and effecting the protective action. Institution-specific information: - : tame and location of schoci; 4 - Type of school and a"ge grouping ( e. g., public j elementary school, grades kindergarten :nrough sixth): 5

o 4 e i - Total populati:n (students, facul:y and c:her employees); - Means for effecting peccective actions; - Specific resour:es alloca:ed for transportation and supporting le: ers of agree =en: if resour:es are provided from external scur:es and - Name and locati:n of reloca:icn center (s), and transport route (s), if applicable. If parts of the institution-specific information apply :o many or all schools, then the information may be presented generically. Timeframesforeffectingtheprotectiveactions./ Means for alerting and notifying appropriate persons and groups associated with the schools and the students including: - Identification of the organization responsible for providing emergency information to the schcols; .The method (e. g., siren and telephone calls) for contacting and providing emergency information on l recommended protective a'ctions to school officials; l - The method (e.g., siren, tone alert radios and telephone calls) for contacting and activating i designated dispatchers and school bus drivers; and - The method (e. g., E35 messages) for nocifying parents and guardians of the status and location of their children. 1 1 Plannine standard gad Evaluation criteria j N. Evereise and trills i plannine standard l Periodic exercises are (will be) conducted to evaluate =ajor portions of emergency response capabilities. Periodic drills are (will be) conducted to develop and maintain key skills. Inadequacies identified as a result of exercises or drills are (will be) corrected. (NUREG -06 5 4/FE M A-RE P-1, p. 71) f ~ 6 -.___n_-. _ _ _ _.. _ _ _ - _ - - - -

] i ? 6 ryn 2a-ien cri-er n N.1.1. An exercise is an' event tha: :es:s the. integrated capabill:y and a ma;c: pcrti:n of :he basic elemen:s existing w :hin emergency preparedness plans and organi:ations. The emergency preparedness exer::se shall simulate an sme:gency :ha: :esults in offs;:e-radiological releases vnien would require promp: response by offs::e authorities. Exercises sna11 :e conducted as se: f orth in MRC and TEMA :ules. N.I.b. An exercise shall include mobili:stion of State and local personnel resources adequate to verify the capability to respond to an accident scenario requiring response. The organization shall provide for a critique of the biennial exercise by rederal and State observers / evaluators. The scenario shocid be varied from exercise to exercise such that al' major elements of the plans and preparedness organizations are tested within a six-year period. Each organization should make provisions to start an exercise between 6:00 p.m. and 4:00 a.m. once every six years. Exercises should be conducted during different seasons of the year within a six-year period in order to provide fpr exercising under various weatper conditions.. Some exercises should :e unannounced 2.1. official observers from rederal, State or local governments will observe, critique and evaluate the required exe:cises. A. critique shall be scheduled at the cenclusion of the exercise to evaluate the ability of. organizations :o respond as called for in the plan. The critique'shall be conducted as soon as practica:1e af ter the exercise, and a formal evaluation should I result from the critique. l ALLLA 21 M* view These evaluation criteria address exercise-related requirements and their evaluation by Regional Assistance i Committee (RAC) staff. In additicn to identifying { capabilities for evacuating students or effect:ng early j dismissal as a " major element" of an organization's emergency response plan, suggestions are provided for conducting interviews with officials from schools during an exercise, i

• These provistens conform to the revis :n of evaluati:n c rite rion N.1.b.

of NUREG-0654/TEMA-REF-1 promulgated in GM~ PR-1, Policy on NUREG-0654/TEMA-REP-1 and 44 CTR 350 Periodic Requirements. ~ 7

e: K.L .s. Accettance Criteria Requ.:ements are set forth in TEMA (44 CTR 350.9) and MRC,.: CTR bO, Appendi x E.*V.F.1-5.) rules for conducting periodi: exercises and drills. "ndec these requiremen:s, organi:ations wi:h assigned responsibilities for protecting students are required :o demonstra:e throuen exercises : heir a=ill:y :o implement emergency procedures con:ained in their emergency :esponse plans. However, :he public 'e.g., seneci enildren).are not required :o participate in exer::ses. Further, the actual use of school vehicles is optional. The demonstration of each organization's capability o imple=en: t. these measures in exercises will be evaluated by TEMA and other rederal of ficials. The following functions should be demonstrated and evaluated in exercises-in which the evacuation of students is necessitated by events in the exerciso scenario: 1. Alerting and notification of appropriate school officials by local emergency. officials with respect to status of radiological emergency and need to implement protective actions, including evacuation: 2. The contacting and notification of dispatchers and schoci bus drivors, as appropriate, to inform them. of any potential or actual.need for them to transport students and 3. The provision of information to the parents and guardians, as appropriate. c.'ncerning the status an'd intended location or destinatten of the students. ' With respect to simulating the evacuation of school ch11dren in an exercise, the following guidelines are provided. 1. At the discretion of school officials, the bus driver.ay proceed to drive a schoci bus to a relocation center, as necessitated by the simulated exercise events. 2. An exercise evaluator will interview the relevant personnel at the EOC's, the Schcol Superintendent's office, the School Principal's office, and the Dispatcher's office, as well as the bus driver to determine their awareness of and preparedness for the evacuation of the school children. Pertinent questions for the exercise evaluator pertaining to the dispatcher and bus driver include E ereenev creratiens Center's) - II;gl One or more ICC's may be involved in decisionmaking to effect the evacuation of schools. For example, in some States, local school evacuation must be coordinated w:: 8 j

' y sta e officials..:n such :ases,' observers may need7:: L concurrently evaluate evacua: ion or othcr protec:ive l action decision = axing in toch 3:a:e and local IOC's. .1. Who made the decimien for evacuation or other protect ve acti:n of schools and when?- 2. What specifi: Ic:icns (evacua: ion, early dismissal :: shel:er) are.incorpora:ed in the decisien'anc wha specific sectors / schools are impactsd by this decision? '3. When and f rom whom did -the IOC receive informa:1:n abou:.this decision? 4.- When and whom did the ECC staff contact to implemen: this decision? '5. .Did ICC staff undertake actions to assist school evacuation or other protective action such as securing guides,. buses and assistance in traffic control? scheel superintendent's Office - 1. ~ han and f rom whom did the superintendent receive protective action instructions or recommendations? What specific instructions or recommendations did the superintendent receive? 2. -What actions did 'the superintendent take to imple=en: i these instructions or recommendations? Whom did the superintendent contact and when? Scheel prineisal's Office 1. When and feca whom did the principal receive protective. action instructions? Uhat specific instructions did the principal receive? 2. What means of communications (e.g,,, telephone, tone alert) were used to provide these instrue:1ons? Did this means of communication functica adequately to provide accurate and timely information? 3. What actions did the principal take to implement these instructions? Whom did' the principsi contact and when? Sineatcher 1. When and f:cm whom did :he dispatcher :eceive the ~ inse:uctions? What specific instructions were received? 9 1 9

g. r 4:. t-j 2. "t.a: eans Of ::: unications were used? ' Tere :ne com=unica:::ns te: ween :ne dispatener and n s/her supervisor and :he dispa::ner and the sus l driver adequate to convey appropriate and timely informati:n? 4. "7 hen did :he dispa:cner initiate notifica:i:n :: :us de: vers and guides to implement the evacua i:n r other pectective action plan? What specifi: instrue:i:ns were pr vided by the dispatcher? How l long did i: take to contac: the bus driver :o give the order to evacuate? igg Drivers /Guidag 1. When and from whom did the bus drivers and guides receive instructions? That instructions were received? 2. Then did the driver arrive at the school? 3. Did the driver have an adequate map or knowledge of the route? 4. Was the driver aware of any agreement between the drivers and local authorities for them' to provide their services in the event of a radiologi, cal ame rgency? 5. Nhat =eans of communications were used? Uere communications with the dispatcher adequa:e :o convey appropriate.and timely infor:ation? 6. Did the exercise play necessitate a change in instructions to bus drivers and guides? If so, wha: vere these new instructions? Mhat means of ccm=unications were us:J to contact the bus drivers and guides? Was this means of communication adequa:e? Fadiatien Monitorane gng proemetien e I 12s,m.4y..s Gute.en m iesi-na.a v, , g g g 1. Were bus drivers and guides provided with specific means for radiation =enitoring (e.g., desi=eters and film badges) and exposure centrol (e.g., potassium iodide, respiratory protection)? 2. Mere bus drivers and guides trained in the proper use of these instruments and materials? 3. Mere instructions provided to the bus drivers and guides for the authorica:;en and use of potassia: iodide? l t 0

Ai O ~ l s 4. During the exercise, were instructions'given :c al:e: evacuation /early dismissal rou:es in orde: :o aver: radiation exposure by bus drivers and guides? Peleestien centershteichborheeds h h dis-issait 1. When did :he :cses arrive a: the reloca: ion conce r (s ) /neighbo rnood (s ) ? 2. According to the exercise scenario events, did :he bus drivers go to the app:cgriate relocation centers / neighborhoods? Did they arrive in a timely manner to avert radiation exposure? Provision 21 Emereenev Instructions 12 Parents gnj Guardians 1. Was information provided to parents and quardians on the location of students, e.g.. relocation ' centers, early dismissal to residences or sheltering? When was-this inf o rmation provided? ~ 2. What means ( e. g., ISS messages and telephones) were used to provide this information? 3. Was this information provided in a timely and accurate manner according to the exercise scenario events? In'some cases, answers to the above questions will be secu:ed f rom direct observation of the simulated evacuation, thus Jobviating the interviews. 133g1g1 ceneiderations 12g Tmelementine Protective Actions In addition to the guidance above on school evacuation, the following special considerations are provided for.use when implementing other protective actions. IAKlg vreearaterv Measures. In order.to facilitate the implementation of procaccive actions, the following measu:es should be considered: a. Inventory resources for mobilization; e.g., school buses and drivers. b. Curtail extramural or extra curricular activicies so that school children are available for prompt evacuacion, if it becomes necessary. 11 )

c , + - y s 3-Select the method 'e. g., zI2 5 ) and the f:sf: message to notify paren:s and guardians'of the statusoo destination of their children if

:ecomes necessa ry to take protective actions.

d.. Assure tha: the :elocation cente: is available in the even: evacua:1on is necessary.

IA;ig Ivacuatien. Early evacuati:n'is accelerating the .implementa::en of protective -actions f or schoci children prior to the activation of protective actions'for the general public. For example,. if a plan calls for an evacuation of the public at :he " General Emergency"-level, then protect:ve 1 actions:for school children would~be initiated at.:he " Site Area' Imergency" level. In the event of a rapidly deteriorating situation, schoci children would be evacuated simultaneously with the general public. IAzig Dismissar. While. early dismissal of school children is addressed as an-evacua: ion option per se in NURIG-not 1 0654/TEMA-REP-1, it. is incorporated in this: GM as a method for accomplishing the intent of evaluation criteria under planning standard.J because of its use for other types cf emergencies such as imminent natural hazards (e.g., snowstorms). Hazards such as a school fire or boiler failure have a limited hazardous area, unlike an extended radiological plumer therefore, the early' dismissal of students to their parents and guardians may be prudent. The greater area affected by severe weather, such as a blizzard, usually does not jeopardize the health and safety of the school. children if they are dismissed early before the s:ccm or remain sheltered in the school. In contrast,-the radiological plume may make both the school and home undesirable shelters it.both are in the plume exposure pathway, or if a f ast moving event could escalate te while the children were in transit. Further, in the presence of unstable meteorological conditions it is difficul: to ;;o ect the movement of radiological celeases. Therefore, the uni ce L characteristics cf a radiological emergency place limits on

• La use of early dismiscal as a viable protective actica, particularly in beavily populated areas.

12amustin combings M IA;1g cismissal. ra:1y dismissal used in conjunction wi h evacuation as descri:ed above 3 provides another option. The school children who reside in a sector of the ten-mile EPZ not effected by the potential danger or octzide the ten-mile EPZ could be dismissed ently li' te their parants, guardians or other supervision while these L students whose homes are potentially in the path of a l radioactive plume would be evacuated to designated reloca:icn L centers. l ~ i l 12

p' r j,, 4 '- t ui 14' L

he prete::ed pro:ect:ve ac:icn -(e.g.,

when :here a:e S hel t e -i-e. Unde; certain circumstances sheltering,ay ce_. }; l hazardous : cad condi:icas or.:he possibility exists :ha: g evacuacion may resul: in ::ansporting s:udents :hrough :he plume), sheltering may be used as a primary or temporary pro:ective action depending upon :he cha:acteris:::s of :he radiological release and the status of wea:her and road conditions.- GM EV-2 is' issued subsequen: to :eview and concurrence bv ::RC staff who have determined : hat it provides clar:.fication and ~ interpre ation of existing NURIG-0654/FIMA-RIP-1 criteria

applicable to protective tctions for 'special populati

ns."

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