ML20248G925

Testimony of C Sneider on Behalf of Jm Shannon,Atty General of Commonwealth of Ma Re JI-56 (Monitoring Rate).* Supporting Documentation Encl.Related Correspondence

ML20248G925
Person / Time
Site:	Seabrook
Issue date:	04/10/1989
From:	Sneider C MASSACHUSETTS, COMMONWEALTH OF
To:
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ML20248G923	List: ML20248G919 ML20248G925 ML20248G930 ML20248G934 ML20248G943 ML20248G946 ML20248G960 ML20248H161 ML20248H205 ML20248H267 ML20248H319 ML20248H661 ML20248H688
References
OL, NUDOCS 8904140006
Download: ML20248G925 (21)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .b9 APR 11 P5 58 l

ATOMIC SAFETY AND LICENSING BOARD cre j

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Before the Administrative Judges:

Ivan W. Smith, Chairman-Dr. Richard F. Cole 4 Kenneth A. McCollom {'

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In the Matter of )

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Docket Nos. 50-443-OL  ;

PUBLIC SERVICE COMPANY )

50-555-OL  ;

OF NEW HAMPSHIRE, _E_T A__L , ).

(Off-Site EP) I

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(Seabrook Station, Units 1 and 2) ) April 10, 1989

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a TESTIMONY OF CAROL SNEIDER ON BEHALF OF t JAMES M. SHANNON, ATTORNEY GENERAL FOR  !

THE COMMONWEALTH OF MASSACHUSETTS, l REGARDING JI-56 (Monitoring Rate) l 4

Jepartment of the Attorney General Nuclear Safety Unit l Public Protection Bureau l One Ashburton Place j Boston, Massachusetts 02108 '

(617) 727 2200 e904140006 890410 PDR ADOCK 05000443 T PDR

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 1 Before the Administrative Judges:  ;

Ivan W. Smith, Chairman l Dr. Richard F. Cole Kenneth A. McCollom i

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In the Matter of ) Docket Nos. 50-443-OL

) 50-555-OL I PUBLIC SERVICE COMPANY ) (Off-Site EP) f OF NEW HAMPSHIRE, EI AL. )

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l (Seabrook Station, Units 1 and 2) ) April 10, 1989 l

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TESTIMONY OF CAROL SNEIDER ON BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS, l REGARDING JI-56 (Monitorina Rate) l l

SUMMARY

OF TESTIMONY f s

l In this testimony Carol Sneider, an observer of the 1

monitoring drills at the North Andover Reception Center during  !

l the Exercise, describes the drills and the monitoring rates she observed. She then sets forth her reasons, based on her I

i observations, why the monitoring drills were not a fair test of I what the caoability of the ORO would likely be in a real l l

emergency. She concludes with a calculation of what a l l reasonable monitoring rate over 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> would be. It is a l

rate which, for two monitoring trailers with 14 monitoring I

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stations each, does not permit 20% of the total population to be monitored within 12. hours,.

Q.1. Would you please state your name and current position?

A.1. .My name is Carol Sneider, and I am currently an

-attorney in private practice with the firm of Becker & Glick in Boston.

Q.2. Were you previously an Assistant Attorney General in the Massachusetts Attorney General's office, and did you work on the Seabrook case?

A.2. Yes. I left the Attorney General's office at the end of January 1989.

l Q.3. Did you have an opportunity to observe'any part of I the June 1988 FEMA /NRC Graded Exercise for Seabrook?

A.3. Yes, I did. I was one of the observers the Massachusetts Attorney General's office sent to observe the Exercise on June 28 and 29, 1988. The Applicants had agreed to permit the Attorney General to have a limited number of observers present to observe portions of the Exercise. On Day i

1 of the Exercise (June 28), I was at the North Andover, 1

l Massachusetts, reception center along with another. Mass AG-l l observer, phoebe McKinnel, a law Student from Columbia .

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( University who was working.in the Attorney General's office l

last summer.  !

l Q.4. While you were there, did you have an opportunity to .

1 observe the activity at the Monitoring Trailer?

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A.4. .Yes. There was a single Monitoring Trailer parked just outside the Reception Center. We observed the trailer being readied for evacuees in the morning. lIn the' afternoon we observed two 20-minute monitoring ~dril'ls, one for the First  ;

Shift workers and then later, after a shift-change occurred, J

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one for the Second Shift workers.. Late in the day we were allowed inside the trailer to inspect it. -l

>l Q.5. Would you describe the monitoring drills you observed?

A.5. Certainly. While the Monitoring Trailer has fourteen (14) monitoring stations, I believe only seven(7) were staffed and used to conduct' monitoring activities for the drills.

Outside the trailer a group of about twenty NHY-ORO members were assembled. They acted as the " evacuees"'for the drill. I was able to hear their " briefing" before the drill, and they I

were told that the objective was to demonstrate a flow. rate j through the trailer of 55 people per hour per monitoring station. Controllers and evaluators were present to observe )

1 each drill. My intention was to count the flow of people l l

through the trailer myself to see if the 55/hr. rate was met.  ;

Unfortunately when the first drill started at 2:45, I was not in a position to start counting; but I did start my count 5 minutes later at 2:50. I counted the simulated evacuees as they entered the trailer for the remaining 15. minutes of the drill. (Once they had been monitored, they left the trailer through the rear' door, came around the trailer, and got in line f

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by the front door again.) Altogether, I counted 86 evacuees ,

entering the trailer in that 15-minute span. It was apparent, however, that the last few of the 86 had not been completely monitored before the drill ended, probably 83-84 had been completed during the 15 minutes period I observed.

This means that each of the seven monitoring stations monitored.(0 -

8A) about 12 people in 15 minutes. This 4

translates to a raic of about 48 people / hour, or about 1 person-every 75 seconds.

Later that afternoon a shift-change occurred, and at 5:02; p.m. the second shift monitoring personnel were also given the 20-minute drill to test'their rate'of monitoring individuals. ,

i This time I was able to count every individual who entered the ,

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trailer.for monitoring during the 20-minute test period. There l were 91 people who entered, although again the last people to enter could not have been monitored before time expired.

i probably 88-89 were completed. j 1

For this second-shift group, which again consisted of 7 i monitors, I believe, the monitoring rate was slower than the I first shift group. Each of the seven monitoring personnel was able to. monitor (88-81) g about 12.7 people in 20 minutes.

.This translates to a rate of about 38 people / hour per station, or about 1 person every 94.7 seconds.

Q.6. Are you sure that seven of the monitoring stations were in operation for each drills

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A A.6. While we were not allowed to be inside the trailer ,

l during the drill, we were able to look into the trailer from the outside. It appeared to me that there was a monitor l standing by each of the hand rails in the trailer. The trailer

- has seven such rails. See SPMC, IP 3.4, Attachment 4. So I believe there were seven monitoring stations which were i

operating for each drill.

Q.7. Were these drills fairly administered in order to demonstrate the monitoring rate that is likely to be achieved in a real emergency?

A 7. No, I do not believe they were. I have two kinds of ,

I observations on this point: (1) specific criticisms sbout the ,

fairness of these drills and (2) a general observation that -

drills of this nature are not useful in determining whether any particular monitoring rate can be maintained hour.after hour over a 12-hour period, j 1

As to my first point, there were a number of criticisms.I had about the way the tests were run. First, it was not fair to test monitoring rates using only 7 of the 14 monitoring stations in the trailer. When I toured the trailer later in the day I observed how cramped the trailer was. There is an extremely narrow aisle which evacuees must use as they enter the trailer and walk to a monitoring station. This same aisle is used by evacuees who are monitored and found contaminated; they use it to walk to the decontamination area at the end of 1

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the trailer. In the height of an emergency when the trailer is ,

1 fully staffed and evacuees are lined up to be monitored, there will be congestion along this walk-way that will impede evacuee ingress into the monitoring stations. Evacuees who are not sure they are contaminated will likely stop and not enter the j i

trailer until a contaminated person walks by and is well past. >

This will occur because it would be almost impossible to have {

two people walk past each other in opposite directions in this aisle without some brushing or touching occurring. If those awaiting decon grow to more than 2-3, back-ups will occur out into the monitoring arms, causing further congestion. For this 1 i l

teason alone, a test of only 7 monitoring stations is likely to j produce a much faster flow rate per station than would be i obtained if all stations were tested at once.

Second, the simulated evacuees were very compliant and l

easily monitored. They were all adults; there were no 1

children, elderly individuals, persons who were sick, or persons with physical or emotional disabilities. No one asked questions of the monitors. During a real emergency, the " mix" of evacueer, would be much broader, many questions would likely be asked, and a slower monitoring rate will likely result.

Third, the contamination " source" used for the drill, Coleman mantles, had to be hidden in evacuees pockets or in a fold of clothing; so the monitors did not need to be so careful in their monitoring of many parts of the body in order to

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Coleman mantle was placed on about every 5th simulated evacuee.)

Fourth, the simulated evacuees were carrying no suitcases or overnight bags; so they were able to be monitored at a 1

faster per person rate than if they had been carrying these personal items as well. The proceduras for those who were monitoring individuals indicate that these hand carried items are to be monitored as well. See IP 2.9, S 5.4.3(c). I would l

imagine that in a real emergency, many of the female evacuees would have their purses with them and that almost all of those who arrived on the transit-dependent buses would have a bag of .

1 clothes or a suitcase. It will take extra time to monitor I these personal items, and this time needs to be factored into the monitoring rate.

Fifth, during the 20-minute drills the monitors did not l take any breaks or even take time to check their dosimetry, let I alone to occasionally monitor themselves. Yet, the SpMC provides that the monitoti>g team leader in each trailer is to I set up a system whereby each monitor is to get a 10 minute break every hour. Ip 2.9, SS.2.9. I see no provision in the plans to have substitute monitors step in for those who are on break; so this break time needs to be factored into the hourly monitoring rate.

Sixth, the ORO personnel are instructed to check their dosimetry every 15 minutes, and FEMA has rec 1mmended that I

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monitors take the time to monitor themselves for contamination at " frequent intervals." Sg.e FEMA Exercise Report at 233.

. These activities did not occur during the 20-minute drills, and they, too, need to be factored into the monitoring rate.

Seventh, during the drill, the monitors did not hand out the " clean" tags called for in their procedures when a person is monitored and found to be free of contamination. This step would add at least a few seconds to the monitoring rate per person.

Eighth, in the event that contaminated individuals are identified by the monitors, the monitors will have to spend time, as their procedures require (see Ip 2.9, S5.2.14), wiping down the monitoring area (hand rail and floor in particular) to keep the area " clean" for those who arrive subsequently. This was not done during the 20-minute drills, but it'should be ]

I factored into any 12-hour monitoring rate. j Ninth, the drill was:so short that the fatigue factor did not play a role. But in an emergency which required the monitors to continuously monitor people for.50 minutes of every hour for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, fatigue would set in and become a factor. Some monitors might become less efficient, and their monitoring rates would slow down. For others, fatigue might lead to sloppy but more rapid movement of the probe over the body. Even during the short 20-minute drills I observed, the l

monitors had to be continually reminded to. keep the probe 1/2

inch'from the evacuee's body. Surely as fatigue sets in,'it , t would be more and more difficult to keep.the, probe only 1/2 inch.from the body while maintaining an efficient flow rate.

Moreover, if a shift-change were to. occur during a period when-evacuees were arriving, the monitoring rate during that hour _

would'dropfoff somewhat as the. fatigued first-shift worker took i

time to doca little "on-the-job" training with the second-shift.

workers arriving from Yankee Atomic. j Q.8. What is the general observation you have about.the usefullness of drills of this kind?

A.8. I do not believe that drills of the type I observed are particularly useful in determining whether any particular.

I monitoring rate can be maintained hour after hour over a 1

12-hour period. The reasons for-this view are as follows:

By far, the largest component of time in the process of 1

l monitoring individuals is the time it takes to " frisk" each person, i.e., to run the probe over and around the person, front and back. The other time components are small by comparison: time to walk'in and out ofLthe. monitoring station, time to monitor handbags, etc. As I understand it, a monitoring probe must be moved somewhat slowly over.and around the body in order to respond to relatively.small areas of contamination. Thus, it makes little sense to make judgments about an organization's monitoring rate by timing monitoring drills. Since those being drilled can move the probe at will

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faster or slower over the evacuees' bodies, with a little practice they can probably achieve any monitoring rate they desire (45 seconds per person, 60 seconds, or 75 seconds).

This is especially so when the contaminated packets they are i looking for can be bidden in only one or two obvious spots in a person's clothing. The point is, however, that some rates may be too fast for the instrumentation to achieve effective monitoring. Realizing this, FEMA has taken the sensible

" Agency position" that it will not judge monitoring capability on what is demonstrated at drills. Instead it applies a standard monitoring rate of 90 seconds per person. See Memorandum from Richard Donovan, dated February 18, 1988, regarding " Registration and Radiological Monitoring of Evacuees" (attached hereto as Attachment "A"). In this memorandum, the following is described as the " Agency's position that all FEMA Regions will use as policy, guidance, and review criteria to determine the adequacy of offsite preparedness for radiological monitoring":

Productivity of Monitors: FEMA assumes that an individual monitor will require 90 seconds (1.5 minutes) for monitoring each evacuee. FEMA will not consider any lower time estimate for monitoring with hand-held instruments to be appropriate; i.e., 90 seconds (1.5 minutes) is the lowest acceptable time than an organization can specify for the monitoring process of an individual (general public or Emergency Worker) with hand-held instruments. This 90-second standard does not include the time required to perform the documentation process. Therefore, FEMA assumes the minimum productivity to be 33 evacuees per hour, per monitor, at a monitoring

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station. It is assumed that one individual could work a 12-hour shift (maximum number of hours per shift is 12), and the above productivity figure assumes a 10-minute break every hour. The 10-minute break period is for meals and for personal convenience. FEMA w'ill allow an organization to assume a rate of maximum production of 40 persons per. hour; e.g., remove the 10-minute break from the calculations and the standard of 90 seconds per person does not change. However, if this maximum productivity figure is used by an orgar.ization, the organization should provide for supplemental staffing; i.e., a. higher number of staff than monitoring stations to allow meal and personal convenience breaks. If the monitor is responsible for the documentation (completion of forms, etc.) of the monitoring process, then a figure higher than 90 seconds as a productivity standard must be used (see discussion on documentation).

Based on the drills I observed, in which two different shifts of people exhibited two significantly different I

monitoring rates (75 seconds and 94 seconds), FEMA's approach {

l to evaluating the effective monitoring capability makes good j i

sense. What makes no sense is to use the average of the )

monitoring rates observed in the two drills or, alternatively, to use one or the other of those two observed rates as "the" rate to use to judge an organization's monitoring capability.

Human variability was the reason those two rates differed. In my opinion, based on what I saw during the Exercise, if a third 20-second drill had been conducted using a third group of ORO workers, a third and different rate would have been achieved.

In fact, that is just what happened at the Emergency Worker i Facility, where FEMA conducted a monitoring drill and found I

e that the average time to monitor the emergency workers was 79 seconds. Egg FEMA Exercise Report at 232.

While FEMA requires 90 seconds for monitoring each evacuee, I understand that the Applicants have sought to persuade FEMA to apply a lower rate for the ORO. I have seen a document labeled " Technical Justification" which was produced by the Applicants during discovery which indicates that the monitoring equipment used in the SpMC's monitoring trailers are effective for a 60 second frisk (3 inches per second) of an individual.

Clearly, an ORO member engaged in frisking with this equipment could mov2 the probe around evacuees' bodies much faster than this. But to do so much faster than 60 seconds apparently would not provide assurance that small areas of contamination could be identified. I do not know whether FEMA has agreed to modify its 90-second standard for the ORO based upon this

" technical justification." I do note, however, that the 60 second rate mentioned in the " technical justification" is simply the frisk rate, i.e., the time taken to move the probe around the body. It does not include the time it takes to have a person walk in and out of the frisking station, to hand out clean tags, and answer evacuees questions, to monitor personal belongings, to take hourly breaks, etc.

Thus, if FEMA were in fact willing to waive its standard 90-second monitoring rate here and sought to engage in a Seabrook-specific re-calculation of the ORO's canability to

monitor-20% (or any %) of the population within 12' hours,:it would have to engage in a fair and honest calculation.of the following sort: .First, you'would start with the average per q person frisking time (which may be 60 seconds.here), .and then to that you would add such addition time, averaged overfl'2 l

hours, as would'likely be consumed by all those-other thinos tha't happen at-the monitoring stations which consume time. I have listed many'of themLabove. The-first one is the t'ime to i move evacuees in and out of'a monitoring station. Five seconds in and five seconds out would appear to be a good estimate of this time, and its is the. time the Applicants used in their own

" Technical Justification." This time would permit a " clean tag" to be handed out as well as a few quick questions to be answered. A couple more seconds per person (on average) need to be built in to monitor personal items.

60 seconds ave, frisk of person 10 seconds ave. in/out time plus clean tag 3 seconda ave. time to frisk personal items i

73 seconds per person (average)

These times alone (and there would be others) add up to an average of'about 73 seconds per person. For purposes of determining monitoring caoability in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, one should simply assume that monitors can be trained to monitor at this' rate.

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Each' monitor in the SPMC monitoring trailers, however, is  !

given a 10-minute break per hour. Since no back-up staff appear to be available to step in and cover for the monitors j J

who are on break, the time available each hour to monitor l l

individuals needs to be reduced by 10 minutes. In addition, f

since the monitors must check their dosimetry and monitor I themselves " frequently," additional time is lot to each monitor each hour. If each monitor takes time only twice during each j l

50-minute shift (after 15 minutes and after 30 minuts) to check {

1 his/her dosimetry and to monitor himself/herself, then the time i I

available each hour to monitor people needs to be reduced by at 1 I

least 2 more minutes. In addition, over a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period i during which contaminated individuals, among others, were j

processed through the monitoring stations, it is reasonable to expect that each monitoring station will collect some residual I contamination and will have to be decontaminated or taped in the manner described in IP 2.9, S5.2.~14. Egg also IP 2.9, S5.4.3(D). Some time should be deducted from the available i

monitoring time each hour for these decontamination efforts.

One minute per hour does not seem unreasonable. '

Altogether, then, the 60 minutes in each hour reduces to 47 l

minuts of available monitoring time:

60 minutes minus:

10 min, for break l 2 min. for dosimetry check and self-frisk i

_1 min. for decon of monitoring station 13 minutes / hour

-11 j 47 minutes / hour available to monitor individuals at each {

station. l

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This leads to an effective monitoring rate'at'each station of. '

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38.6 people / hour: i 73 sec./ person for 47 min./hr. - 38.6. people / hour l t

At the rate of 38.6 people per hour, 14 monitoring stations I l

could monitor 540' people per hour, or 6480. people in 12. hours. 1 I

Two such trailers could monitor-(6480 x 2) 12,960. people in l 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a number which is significantly less thanL20% of what even the.SpMC states"is the total resident'and transient ~

population (82,994) in the Massachusetts portion of the EPZ.

SPMC, Table 3.6.1. I understand that.another witness for the Massachusetts Attorney General has submitted testimony.that the total Massachusetts population is actually significant1y' higher i than this.  ;

Q. Does this conclude-your testimony? 3 A. Yes, it does. l i

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ATTACilMENT A I

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FEMA RX/ NTH /RWD/876-239#2/3/7/88 I

l FEDERAL EMERGENCY MANAGEMENT AGENCY'S CURRENT REP OPERATIVE GUIDANCE MEMORANDUMS (Off-site Activities) l GM 20, 10/83 Foreign Language Translation of Public Education Brochures and Safety Messages. I GM 21" 2/84 Acceptance Criteria for Evacuation Plans.

l GM 22, 10/83 Recordkeeping Requirements for Public Meetings.

GM 24. 4/84 Radiological Emergency Preparedness for Handicapped Persons.

EX-1. 7/85 Remedial Exercises.

PR-1, 10/85 Policy on NUREG-0654/ FEMA-REP-1 and 44 CFR 350 Periodic Requirements.

GM EX-3** 2/26/88 Managing Pre-Exercise Activities and Post-Exercise Meetings.

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PI-1, 10/85 FEMA Action to Pilot Test Guidance on Public Information 1 Materials and Provide Technical Assistance on Its Use.

MS-1, 11/86 Medical Services.

1 EV-2, 11/86 Protective Actions for School Children.

l GM AN-1. 4/87 FEMA Action to Qualify Alert and Notification Systems Against NUREG 0654/PEMA-REP-1 REV 1 AND FEMA-REP-10.

GM IN-1, 2/26/88 The Ingestion Exposure Pathway GM-21 will be retitled GM EV-1 when it is revised to conform to new nomenclature.

• • GM EX-3 replaces GM 17.

Menos Clarifying Policy Issues (Copies Attached)

1. FEMA RX (2/18/88) - Registration and Radiological Monitoring of Evacuees.

2. FEMA (2/16/88) - Unannounced and Off-Hours REP Exercises.

3. F,EMA (2/9/88) - Clarification of Selected Provisions of Guidance Memorandum (GM) MS-1. Medical Services.

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Federal Emergency Management Agency

• g Region X Federal RegionalCenter Bothell, Washington 980219796 i 4

i February 18, 1988 .)

MEMORAND'JM FOR: Selected Distribution FROM:

& N Tmm Richard W. Conovan

. REP Program Officer 1 l

SUBJECT:

Registration and Radiological' Monitoring of Evacuees .

(NUREG-0654/ FEMA-REP-1, J.12)  !

1 At the Hood River setting last fall, there === a presentation by Washington DSHS on their assessment of the needs for radiological sonitors for the sonitoring of evacuees at Assistance / Relocation and Energency Worker Centers. Discussions were held on the appropriate standard to be used for the productivity of a radiological. >

monitor.

In order to assure consistency with other FEMA Regions, this subject was discussed between the Regions and FEMA Headquarters, and among the Regions. Following is the Agency's position that all FEMA Regions will use as policy, guidance, and review i criteria to determine the adequacy of offsite preparedness for radiological sonitoring and registration of evacuees:

Level of Preparedness: Offsite pir.ns should include provisions for 9 monitoring a minimum of 20 percent of the public (permanent and trcnaient I populations of the plume exposure EPZ) in approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The sonitoring should be done at Relocation Centers, which are called Assistance Centers in most Region X Plans. Preparedness should include trained personnel and equipment.

Productivity of Monitors: FEMA assumes that an individual sonitor will require 90 seconds (1.5 minutes) for monitoring each evacues. FEMA will not consider any lower time estimate for monitoring rith hand-held instruments to be appropriates i.e., 90 seconds (1.5 w',nutes) is the lowest acceptable time that an organization can specify for the monitoring process of as individual (general public or Energency Worker) with hand-held.

Instruments. This 90-second standard does not include the time required to  !

perform the documentation process. Therefore. FEMA assumes the minimum productivity to be 33 evacuees per hour, per sonitor, at a monitoring station. It is assumed"that one individual could work a 18-hour shift (manlaus number of hours per shif t is 12), and the above productivity figure assumes a 10-minute break every hour. The 10-minute break period is for meals and for persons 1 convenience. FEMA will allow an organization to assume a rate of maximum production of 40 persons per hours e.g., remove the 10-minute break from the calcu11tions and the standard of 90 seconde per person does not change. However, if this maximum productivity figure is used by an orga912ation. the organization should provide for supple-sental staffing: 1.3.. a higher number of staff than monitoring stations to

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2 allow seal and personal convenience breaks. If the sonitor is responsible for the documentation (completion of forms, etc.) of the sonitoring process, then a figure higher than 90 seconds as a productivity standard sust be used (see )

discussion on documentation). l Documentation of Monitoring Results: Please see the attached paper. " Ability to Manage and Control Dose Conaltment."- Although the subject of this paper is Emergency Worker dose commitment, it does address the administrative require-ments regarding record keeping and documentation that the sonitoring function aust address. . The above referenced FEMA standard assumes.that the sonitor s does not perfore the documentatica function. If an organization's approach to  !

personnel sonitoring is for the monitor to perform the documentation of the j sonitoring process. then a higher time factor than 90 seconds per person'eust

. j be used. Note. Ideally, the County's registration process would incorporate {

the documentation needs of the sonitoring and decontamination process, thus l eliminating redundancy between the two functions. l l

Demonstration of Capabilities: Activation of the Relocation / Assistance Center (s). and Energency Worker Center (s) are required at each biennial exercise evaluated by FEMA. Registration capabilities for the general public -

sust be demonstrated as well as radiological sonitoring capabilities for the general public and Energency Workers. FEKA will use the 20 percent of  ;

population (permanent and transient) as the planning base-line figure for l registration planning purposes. FEMA currently does not have a productivity  !

standard to review and evaluate arrangements (staff and process) for registration. The American Red Cross (ARC) has found that it takes between 1 ,

minute and 5 minutes for a family to complete the ARC shelter registration l form with the assistance of a registrar. Assuming the county uses a similar form and approach (register stations), the ARC experience should provide an adequate productivity standard to develop preparedness capabilities for the registration of evacunes. Organizations should provide sufficient staff to activate the Relocation / Assistance Center. Documentation should be provided that indicates adequate staffing arrangements for two shifts of personnel and evidence of adequate registration forms for*to percent of the population. The organizations must staff at least one sonitoring station at each appropriate center. Documentation must be provided that indicates, through a roster of trained personnel and an inventory of available survey instruments, the capability of the organization to monitor at least 20 percent of the population (permanent and transient). Once every six years, the organizations must demonstrate a shift change. Note, an actual physical shift change whereby the existing staff will be relieved by incoming staff.

Supplemental Assistance State and local governments should incorporate, via letters of agreement /sesorandums of understanding, arrangements for expanding registration and radiological monitoring capabilities. Federal assistance via the FRERP is one mechan 19s for radiological monitoring arrangements. As

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specified in FEMA RKP-2. Rev. 1. adequate non-federal resoerces should be identified in organization's Plans for a period of 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> e.g.. the organization should plan for, designate, train, and equip sufficient personnel for two shifts, Note, radiological sonitoring equipment is only required for.

one shift.

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3 Adequate Monitoring Instruments: FEMA's REP 2, Rev. 1. Identifies the types of acceptable gemaa exposure rate sensuring instrumentation for personnel monitoring; i.e., low-range gamma survey instrument (approximately 0.1 to 50 nr/hr).

Congregate Care Centers for Evacuees: Most organizations have made arrange-ments for the ARC or other volunteer organizations to staff and operate Congregate Care Centers (a mass shelter which is adequate to provide temporary shelter for groups of persons unable tc continue their living arrangements in their normal accommodations). The ARC criteria for shelters calls for safe and healthful facilities with space for sleeping, office, nursing and health.

Infirmary and storage. There must be an adequate supply of drinking water, toilet and bath facilities. Provisions for cooking. serving and storing food are required. The appropriate governments should provide fire and police protection. The Shelter Operators must provide for 24-hour shelter super-vision, nursing service and police protection. Other necessary arrangements should include communications to the risk governments and Relocation Center (s).

fire protection. and tran:pertetion/ parking arrangements. Special' allocations call for 40 square feet per bed and a maximum size of approximately 1.000 persons per Congregate Care Center. FEKA will not require the activation of '

Congregate Care Centers. FEMA will expect documen,tation provided to indicate that 20 percent of the population can be provided space in Congregate Care Centers. This documentation sust specify that sufficient staff is identified to manage and initially staff these centers for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of operation before supplemental assistance is provided. The documentation must include evidence that the appropriate letters of agreement with the facility owners and food service providers have been completed and that these agreements are current.

If you have any questions. please let se know.

Attachment Selected Distribution List Attached ec RAC RX J. Keller. INEL B. Salmonson. INEL R. Balnicky. ARC I

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.4 FEMA RX/RWD/814-D200-501/1-8-84 A3f t.17Y TO ItANACE AND CONTROL DO$g C080t171GJrr_

prepared by Althard W. Donovan. FEMA RI JAcxCRoVWD.

Af ter the energency phases of a suelear incident are over, there will be naar. studies and investigations directed towards assessing the Japact of the socident and sensurlag ]

i the effectiveness of the State's radiological energency plans and preparedness for see.

in improving future glans and guidance. Both these efforts w!!! lavolve reconstruct-ing the incident based upon the availabla data and both efforts will also involve the J q

calculations of the dose received and the dose saved by proper managestat of tsorgency worker (EW) dose control and exposure. j l

Consequently, it is japortant that data be docusented with the following aspects la sinds date, time locatloa, weather conditions, nessureseat readings, directions for '

dose control and exposure guidance, signatures of.personaal regarding decontseinstica process and results, and other pertinent information. All State and local plane should provide proprinted foras with specific directions for documenting appropriate I instructions. Protective Actions (i.e., take RI. record dose exposures, etc.) and aceitering results. ,

{

DOSg CCMMITMgNT MANAGEMENT SYSTgN Federsi criteria requires that response organizations provide desfeetry (permanent and self-reading) and RI to all toergency Workers. gve should be trained to understand the principles of radiatloa, espesure control and exposure Italte. Response organisa-tions should provide for the screening, detecties, and quantification nessurement) of the presence of betaped gemas contaminates se all eseagency persosse(l (gWs) and ,

equipuent leaving areas where protective Actions are laplemented (i.e. shelter er i' evacuation) after their alssloa. provielens shall be made to effect decontaminaties of personnel and equipment who are found to have contamination levels higher'than defined levels (i.e., saziava permissible conteafnation limit is an open sindes reading of 0.1 mR/hr above the preaccident background mR/h scale reading). The screening levels established by the State shall laclude as apper trigger level that l

would exposurecause the at and aptake toGN (see beNS scheduled 1). for medical esaalaation and evaluaties of rad '

i The ensite and offsite dose verificaties systems should provide inforestice to the offsite public andofficials that will assist then la sanaging and contre 111ag esposure to the to Eve. Attenties ebeeld be locations of the plume serial coverage (gives plume te identifylag locaties the locatiesIncatiese).

and forecasted and espected and any deposities that any be deposited (plume feetprint er ground shiae). The offsite authorities should stillae thle Jaformaties to develop a sanagenest strategy. intera  ;

6 and instreet gW on' dose espesure conditless and management strategf. and keep gW apprised of the radielegical conditions oncenatored la the field.

The gaargency Worker Center (RWC) should docuneat the doses received by gWs and for-ward this information to the appropriate authorities, ube then should use this informa-tion to determine future work assignments and missions for gWo. (i.e. take necessary 3 steps to effectively manage future dese espesure). If the IWC detects gross contamina- j tion, appropriate ateps should be taken to ensure that the person (s) are directed to appropriate bespitals for medical examination and evaluation of radiation exposure and uptake.

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