ML20234B357

Director'S Decision Per 10CFR2.206,denying Petitioner 861107 Request Re Emergency Planning Efforts or for Commission to Issue Order to Show Cause Why License Should Not Be Revoked

ML20234B357
Person / Time
Site:	Perry
Issue date:	09/14/1987
From:	Murley T Office of Nuclear Reactor Regulation
To:
Shared Package
ML20234B309	List: ML20234B305 ML20234B357 ML20234B394
References
2.206, DD-87-15, NUDOCS 8709180374
Download: ML20234B357 (14)

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00 15 i UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION i Thomas E. Murley, Director In'the Matter of ) DOCKET NOS. 50-440

) 50-441 .;

CLEVELAND ELECTRIC ILLUMINATING ) I COMPANY, ET AL. )

)

(Perry Nuclear Power Plant, ) ,

Units 1 & 2) )  !

DIRECTOR'S DECISION PURSUANT TO 10 CFR S2.206 INTRODUCTION On November 7, 1986, Terry J. Lodge, on behalf of Sunflower Alliance, Inc.

(Petitioner), submitted to the U.S. Nuclear Regulatory Commission (NRC) a Motion to reopen the record in the Perry Nuclear Power Plant (Perry) operating I license proceeding and consider new contentions related to emergency planning or, alternatively, for the Commission to issue an order to show cause why the facility's operating license should not be modified or revoked on the basis of 4

alleged offsite emergency planning deficiencies. The operating license for Unit 1 of the Perry facility was issued on November 13, 1986 to Cleveland Electric Illuminating Company (CEI), et al. (Licensees). On February 25, 1987, the NRC notified the Petitioner that the Motion would be considered as a Petition pursuant to 10 CFR 62.206.

The Petition raises a number of issues. The Petition alleges that certain

" care centers" that are to support emergency planning efforts for the Perry facility have inadequate provisions and arrangements to ensure that the centers I

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will perform adequately in the event of an emergency. The Petition also questions the adequacy of " commitments" with school districts for the provision of buses, personnel, equipment, .and facilities for use during an emergency.

The Petition notes that, in October .1986, the Northeast District of the Ohio Association of Public School Employees, American Federation of State, County and Municipal Employees, AFL-CIO (0 APSE),. voted not to participate in any drill or actual evacuation activities involving the. Perry facility. Finally, the Petition questions whether the personnel and facilities of the Ashtabula County Medical Center are adequate for the decontamination and treatment of exposed emergency workers.  :

On January 20, 1987, the Licensees submitted " Licensees' Response to $2.206 Petition of Sunflower Alliance" (Licensees' Response). On March 3, 1987, the NRC requested that the Federal Emergency Management Agency (FEMA) address the issues raised by the Petitioner. FEMA's Report on " Sunflower Alliance 2.206 Petition" dated July 14, 1987 (FEMA Report) is attached hereto as Exhibit A.

My final decision in this matter now follows.

BACKGROUND The Commission's regulations in 10 CFR 650.54(q) and (s) require the submis-sion and implementation of licensee and state and local governmental emergency plans that meet the standards in 10 CFR S50.47(b) and Appendix E to 10 CFR Part I

50. 1/ ' As described in the Memorandum of Understanding between FEMA and the NRC '(50 Fed. Reg. 15485, April 18, 1985), FFMA 'has lead responsibility for I assessing offsite radiological emergency response plans and prepare'dness. 2/

NRC assesses onsite emergency planning'and reviews FEMA's assessment of offsite plans for the purpose of making findings on the overall state of emergency preparedness. See 10 CFR $50.47(a). The NRC must find reasonable assurance that adequate protective measures can and will be taken in the event of a ra-1 diological emergency at a nuclear facility licensed pursuant to 10 CFR Part 50. i For nuclear ' power plants licensed to operate after the NRC final rule on ,

i emergency planning became effective (November 3,1980), the NRC bases its rea- I sonable assurance finding for each operating reactor on (1) a review of the I FEMA findings and determinations as to whether state and local plans are adequate and whether there is reasonable assurance that they can be imple-mented, (2) a review 'of the onsite plans by the NRC, (3) a comprehensive appraisal conducted by the NRC at the operating reactor site to verify the implementation of the licensee's plan, and (4) the evaluation of a joint exercise involving the licensee and state and local governmental organizations.

1/ NUREG-0654/ FEMA-REP-1, Revision 1, " Criteria - for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," provides guidance for the implementa-l; tion of the standards in 10 CFR 650.47.

I ll 2/ In addition to reviewing offsite emergency preparedness as requested by

[ the NRC with respect to nuclear facilities, FEMA has in place procedures set forth in 44 CFR Part 350 for the assessment of the offsite plans submitted by state and local governments.

.The Licensees' onsite emergency plan was submitted to.the NRC in May 1981. The emergency preparedness implementation appraisal of the Licensees' plan was conducted at Perry from February 25 to March 7,1985. Certain appraisal areas I

(52 specific items) were identified as requiring either correction or improve- l ment. All identified items were reviewed during subsequent inspections in 1985 l

and 1986 and found to be satisfactorily resolved. The Perry of fsite plan was l submitted in March 1983 by Ohio to FEMA for review and evaluation in accord- l ance with 44 CFR Part 350. M On March 1, 1984, FEMA provided an interim report to the NRC on the offsite emergency plans for Perry. FEMA concluded that, based on its review of the Ohio and Ashtabula, Geauga, and Lake Counties '

offsite radiological emergency preparedness plans, there was reasonable assur-ance thot the plans were adequate and capable of being implemented in the event of an accident at the Perry site. A full participation exercise involving the Licensees and state and local organizations was conducted on November 28, 1984.

The NRC and FEMA evaluated the implementation of the Licensees' onsite and offsite plans, respectively. The onsite portions of such exercises are ob-served by the NRC; the offsite portions are observed by FEMA and other members 3] The FEMA process for formal approval of offsite plans is set forth in 44 CFR Part 350. However, this formal process need not be completed for the purpose of NRC licensing reviews either for operating plants or plants being licensed. The fact that FEMA approval of offsite plans in accord-ance with 44 CFR Part 350 has not been received for a particular facility does not mean that an inadequate level of emergency preparedness exists.

During the approval process, FEMA may issue interim findings of reasonable assurance that adequate measures can be taken in the event of a radio-logical emergency that are based on reviews of emergency plans and exercise observations.

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1 of the Regional Assistance Committee (RAC). On January 31, 1985, FEMA pro-vided the NRC with its findings on the exercise. FEMA reported that there were no deficiencies affecting public health and safety; however, there were 22 other deficiencies of a lesser nature that required corrective action by the i

State of Ohio and Lake, Ashtabula, and Geauga Counties. On May 23, 1985, FEMA l reported that the State of Ohio had submitted an acceptable schedule of correc-l tive actions for all of the identified deficiencies. A partial participation exercise involving the Licensees and state and local organizations was con-ducted on April 15, 1986. On September 5, 1986, FEMA reported to the NRC that no deficiencies were found during the April 1986 exercise and that the 1984 exercise deficiencies had been corrected.

In addition, Atomic Safety and Licensing Board (ASLB) hearings were held on the Perry offsite plans, and contentions were litigated during the period April 9-12, 1985. The Petitioner was a party to this proceeding. The ASLB issued a Partial and Concluding Initial Decision on September 3,1985. E The 4_/ There exists in each of the 10 standard Federal regions a Regional Assis-tance Committee (RAC) (formerly the Regional Advisory Committee) chaired by a FEMA regional official and having members from the Nuclear Regulatory Commission, Department of Health and Human Services, Department of Energy, Department of Transportation, Environmental Protection Agency, Department of Agriculture, and Department of Commerce. The RACs assist state and local government officials in the development of their radiological emer-gency response plans and review plans and observe exercises to evaluate the adequacy of these plans and related preparedness. This assistance does not include the actual writing of state and local government plans by RAC members.

5/ Cleveland Electric Illuminating Company, et al. (Perry Nuclear Power Plant, Units 1 and 2), LBP-85-35, 22 NRC 514 (1985). The Atomic Safety and Licensing Appeal Board affirmed this decision. ALAB-841, 24 NRC 64 (1986).

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l ASLB authorized issuance of an operating license subject to the Licensees satisfying certain conditions related to offsite emergency planning.

In Supplement No. 7 to the Perry Safety Evaluation Report, 5 the NRC approved the Licensees' overall state of emergency preparedness subject to resolution of J

certain conditions of the September 3, 1985 ASLB Decision related to offsite

. emergency planning. On February 4, 1986, FEMA provided its supplemental

. findings on the offsite emergency preparedness conditions specified in the ASLB Decision. FEMA concluded that the emergency preparedness issues as specified in the ASLB Decision have been satisfactorily resolved.

1 On November 7,1986, the Nuclear Regulatory Commission voted 4-1 to authorize ,

the NRC to issue a full power operating license for Perry Nuclear Power Plant, Unit 1. In reaching its decision, the Commission explicitly considered and i

approved emergency planning for the Perry facility. 7/  :

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DISCUSSION )

l The Petition raises the following four specific issues calling into question  !

the adequacy of offsite emergency planning for the Perry facility:

(1) The adequacy of Geauga County reception / congregate care centers.

1/ NUREG-0887, " Safety Evaluation Report Related to the Operation of Perry Nuclear Power Plant, Units 1 and 2," Docket Nos. 50-440 and 50-441, Supplement No. 7, November 1985.

7/ Cleveland Electric Illuminating Co. , et al. (Perry Nuclear Power Plant, Units 1 and 2), CLI-86-22, 24 NRC 685 (1986).

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(2) The effect of the July 14, 1986, Jef ferson Area Local School District Superintendent's Letter.

(3) The effect of the Resolution of the Northeast District of 0 APSE.

(4) The adequacy of the Ashtabula County Medical Center.

With respect to the first issue, the claim raised by the Petitioner is based on the Affidavit by Mrs. Theresa M. Burling. Mrs. Burling cites a lack of stored food, clothing, cots, or bedding at the schools that will serve as reception /

congregate care centers in the event of an evacuation of the area near the Perry site. Mrs. Burling also raises the issue of failure of contact and/or discussion between the American Red Cross and school administrators. Finally, 1

Mrs. Burling's Affidavit specifies that 12,891 evacuees are proposed to be housed in these care centers. The FEMA Report indicates that an apparent misunderstanding exists on the part of Mrs. Burling in that there is no l

requirement that the supplies referred to be stored in these reception /

congregate care facilities in advance of an emergency at the Perry plant. FEMA stated that the current arrangements (i.e., a letter of agreement between the Red Cross and Geauga County specifying that the Red Cross will provide cots, blankets, and other items at the care centers and the use of the school food supply in addition to local purchase for feeding purposes) are similar to other arrangements around the country and that FEMA finds these arrangements to be adequate. All primary (four each) and alternate (six each) designated reception / congregate care centers other than Kent State University - Burton, a state operated institution designated as a reception center for about 200 people, have entered into an agreement with Geauga County and have copies of the Geauga County plan. These arrangements are satisfactory to FEMA. The Geauga County Emergency Operations Center'< Operation Group Staff includes the

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Geauga County School Superintendent and a liaison from the Red Cross. The Berkshire High School and West Geauga High School facilities were evaluated by Federal observers during the 1984 full participation and 1986 partial-participation exercises, respectively. The exercises confirmed the avail-ability and adequacy of these facilities as care centers. Regarding the capacity of the care centers, FEMA reports that the Geauga County plan notes that approximately 2,000 residents of Thompson Township (Geauga County) live within the 10-mile emergency planning zone (EPZ) of the Perry plant, The capacity of the 4 primary and 6 alternate care centers, as specified in the Geauga County plan, is 12,891, well in excess of the 2,000 Geauga residents within the 10-mile EPZ. On the basis of its review of the Geauga County plan, FEMA concluded that there was excess capacity in the Geauga County centers.

With respect to the second issue, the Petition bases its argument on the assertion that the NRC has required licensees to have in place before an operating license is issued written agreements or commitments from nearby school districts to provide facilities, personnel, and equipment, particularly .

l buses, in the event of an emergency. The Petition also included a July 14, l

1986, letter from the Superintendent of the Jefferson Area Local School District that the Petitioner alleges formally withdrew a previous commitment letter and indicated that there is a lack of authority to make commitments for buses, personnel, equipment, and facilities for use during an emergency. The Petitioner has mischaracterized the July 14, 1986 letter. In that letter, the Superintendent focused on his legal authori ty regarding facilities and personnel in the event of an emergency. In essence, the Superintendent noted that he was without legal authority to permit the use of school district

. resources in an emergency situation. The NRC recognizes this as the case, and has not in the past required legally binding documents to determine what response would be available in an emergency. Historically, public institutions have an outstanding record of response in emergencies. What is important is for the appropriate institutions to be aware of the role they may be called upon to play in an emergency and to formally recognize that likelihood. A legal contract is not needed. The Superintendent's letter reflects that a legal contract does not exist. In fact, subsequent to the July 14, 1986 letter, the Jefferson Area Local School District reaffirmed its willingness to assist in an emergency. See Paragraph 6 of the Hulbert Affidavit attached to the Licensees' Response. Also, FEMA contacted the Superintendent on March 2, 1987, to discuss the July 14, 1986, letter. According to FEMA, the Superinten-dent pointed out that his letter of July 14, 1986, was written to clarify a {

legal point and should not be taken to mean that the Jefferson Area Local School District would not cooperate in disaster planning in response to an accident at the Perry plant.

Regarding the remainder of commitment / agreement documents on file wherein the Petitioner alleges that facilities, personnel, and buses have not been committed in a legally recognizable fashion, as stated above, legal contracts are not required. It is the view of the HRC that the purpose of written  !

commitments is to reasonably determine and confirm the available resources and to assure that the providers are capable of providing those resources.

Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), l I i LBP-85-14, 21 NRC 1219, 1273 (1985). Historically, providers have responded l l

when called upon to do so. i

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f The issue of letters of agreement for school buses was first raised by the j i

Petitioner and litigated before the ASLB during the Perry emergency planning l hearings in April 1985. . In its decision of September 3,1985, LBP-85-35, the  !

i ASLB directed CEI to obtain letters of agreement from all school districts f regarding the supply of buses for evacuation purposes. On February 4,1986, FEMA notified the NRC that the State of Ohio had obtained letters of agreement from the 10 school districts identified in the Ashtabula County Radiological l

. Emergency Response Plan, the 8 educational institutions in Geauga County, and i

the 10 school districts participating in Lake County. FEMA concluded that these documents satisfied the terms of the ASLB decision. ,

In my view, the issue is not whether a particular institution believes it has legal authority to perform some aspect of planning and preparedness. The issue is whether the institution is likely to cooperate in disaster planning and i whether facilities, personnel, and buses will likely be available in the event of a radiological emergency. Based on the above discussion, it appears reasonable that the appropriate institutions, including the Jefferson Area Local School District, are prepared to do their part.

l With respect to the third issue, the Petitioner argues that the Resolution of the Northeast District of the 0 APSE calls into question the availability of emergency workers in the event of an emergency at the Perry facility. FEMA had previously investigated a similar resolution passed by the Northwest District of the 0 APSE in response to a petition pursuant to 10 CFR S2.206 related to the  !

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Davis-Besse Nuclear Power Station. S! In its letter of November 14, 1986, FEMA -

described that resolution as a nonbinding resolution and provided a status report. E FEMA also noted that the Ohio Disaster Services Agency (00SA) and the Toledo Edison Company were meeting with the involved school systems and union members to discuss the resolution and to schedule additional training.

In FEMA's view, the union members were willing to cooperate, attend meetings, l

l .and participate in tt aining related to their emergency duties. Based on these events, FEMA had not revised its position that there was reasonable assurance l

l that adequate protective measures can be taken in the event of a radiological l

l emergency at the Davis-Besse facility.

With regard to the instant Petition, based on a November 13, 1986 letter from the 00SA and a March 5,1987 training status report from CEI, FEMA reported that similar training of union members in their emergency duties had taken place around the Perry plant. According to the CEI status report, 12 bus driver training sessions involving 339 bus drivers had been conducted as part l of Perry offsite planning during 1986-1987. In addition, other training 1

sessions had been conducted for superintendents, transportation supervisors, building principals, teachers, and custodians. In FEMA's view, the union mem-bers are willing to cooperate, attend meetings, and participate in training related to their emergency duties. As of this time, FEMA has not changed its l

g/ Toledo Edison Company (Davis-Besse Nuclear Power Station, Unit 1),

00-86-17, 24 NRC 753 (1986).

9/ Memorandum from Richard W. Krimm, FEMA, to Edward L. Jordan, NRC, dated November 14, 1986.

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position that there is reasonable assurance that adequate _ protective measures can be taken in the event of a radiological emergency at the Perry facility.

With respect to the fourth issue, the Petition alleges that. the equipment, personnel, and facilities at Ashtabula County Medical Center (ACMC) fail to meet the requirements of the Joint Commission on Accreditation for Hospitals i

(JCAH). Specific problems alleged include a joint ventilation system for the  !

hospital and the emergency room area in which contamination victims would be

. treated; no isolated, designated area for holding of contamination victims; lack of adequate training of emergency room and other staff of ACMC in the care of. contaminated victims; and inadequate preparations for ambulance transport of contamination' victims from ACMC to. other hospitals in the event of a severe radioactive release from the Perry plant in the direction of Ashtabula.

The issue of the adequacy of medical services was litigated before'the ASLB in the operating license proceeding. The Petitioner there sponsored a contention asserting deficiencies in this area and presented evidence. The ASLB rejected l the contention and found that the training, personnel, and equipment at designated hospitals within the emergency planning zone (EPZ) as well as the medical resources available outside the EPZ were adequate. This finding j included arrangements for medical services of contaminated individuals. E The ASLB specifically noted that ACMC is accredited by the State of Ohio for j handling contaminated individuals. Furthermore, the Petitioner's assertion >

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M / LBP-85-35, supra, pp. 523-525 and 564-566.

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, that ACMC .is not accredited by the JCAH is simply incorrect. See Paragraph 9 of the Hulbert Affidavit attached to the Licensees' Response.

FEMA has also evaluated medical services in the event of an emergency at the Perry facility. According to the FEMA Report, the medical staff at ACMC demonstrated its capabilities and the adequacy of tne hospital during the November 28, 1984, full participation exercise. The one 1984 exercise defi-ciency at ACMC reported by FEMA - all equipment necessary to handle a con-taminated victim was not demonstrated - was resolved during the 1986 exercise.

FEMA concluded that ACMC is capable of treating victims of radiological accidents. FEMA also reported that training sessions were conducted for the staff at ACMC under the program, " Managing the Emergency Care of Radiation Accident Victims," on February 19-20, 1987. In addition, FEMA reported that, since ACMC is outside the Perry 10-mile EPZ, it is not necessary to make pre-parations for ambulance transport of contaminated victims from ACMC to other hospitals in the event of a severe radioactive release from the Perry plant in the direction of Ashtabula. The FEMA Report concluded that ACMC is capable of treating victims of a radiological accident. In light of these findings, I find the Petitioner's allegations to be without merit.

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CONCLUSION l l

The Petitioner seeks the institution of a show cause proceeding pursuant to 10 CFR 62.202 to modify or revoke the operating license for the Perry facility.

The institution of proceedings pursuant to 10 CFR S2.202 is appropriate only l

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i where substantial health and safety issues have been raised. See Consolidated Edison Company of New York (Indian Point, Units 1, 2, and 3), CLI-75-8, 2 NRC 173, 175 (1975) and Washington Public Power System (WPPS Nuclear Project No.2),

0D-84-7,19 NRC 899, 923 (1984). This is the standard which I have applied to

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the conurns raised by the Petitioner in this', decision to determine whether enforcement action is warranted.  !

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For the reasons discussed above, I find no substantial basis for taking the l

actions requested by the Petitioner. Rather, based upon the lengthy oversight l and review of emergency planning efforts at Perry by both the NRC and FEMA, including the consideration of issues raised in the present Petition, and the consideration given to the emergency planning area by the Commission and its i

Licensing and Appeal Boards, I continue to be of the view that emergency.

I planning and preparedness for the Perry facility are adequate. Accordingly, the Petitioner's request for action pursuant to 10 CFR S2.206 is denied. As l provided in 10 CFR 62.206(c), a copy of this Decision will be filed with the Secretary for the Commission's review. ,

FOR THE NUCLEAR REGULATORY COMMISSION T

Thomas E. Murley, Director l Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland, this 14th day of September 1987. I I

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EXHIBIT A AL.14 '? . ' . TI FEMA MSH FC C TR 2 P.02 l

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1 h[k Federal Emergency Management Agency i.$.3%y./

xy 3 I Wehington, D.C. 20472 i

l JUL l 41937 i MEMORANDLH TO: Frank J. Congel i Director, Division of Radiation Protection

• and Emergency Preparedness Office of Nuclear Reactor Regulation Nucicar Regulatory Cocimission {'

FROM: r Assistant Associate Director Office of Natural and Technological Hazards Programs

SUBJECT:

Sunflower Alliance 2.206 Petition i

This is in response to the March 3,1987, Office of Inspection and Enforcement, NucletM %)ulatory Comm (

requesting the Federal Emergency Management Ahnuy (FEMA) to review a motio ,

sub=itted by Mr. Terry J. Lodge, counsel for the Sunflower Alliance. The NRC under 10had CFR determined 2.206. that the motion should be treated as a petition filed 1

Reopen the Record and to Submit New Contentions o Applicant To Show Cause Why Its License Should Mt Be Modified e,or Deni d "

including the attached Af fidavit of Theress & Burling and the July 14 1986 letter Dictrict. from the Superintendent of the Jef ferson Area Loeml .,

School the Sunflower Alliance petition are reflected below. FEMA's review c 1.

Geaugs County Reception / Congregate Care Centers This filed bycontention Mrs. Burling. raised by the Sunflever Alliance is based on the Affidavit She states that she helped conduct a survey in the care facilities in Geauga County, Ohio.sumner of 1986, related to emerg systems surveyed do not have food, clothing, cots or bedding stored at schools.

This is en apparent misunderstanding on the part of M l congregate Power plant. care facilities in advance of an emergency at the Perry Nuclear j I

County, will provide cots, blankets, and other items s.

at the c j

The school for feeding food supply in addition to local purchase would be utilized purposes.

This is similar to other arrangements around the country for these types of supplies at reception / congregate care centers.

FEMA Region V finds these arrangements to be adequate.  !

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Mrs. Burling stated the purpose of the 1986 survey was to ascertain the availability and adequacy of care conter facilities referred to in the Geauga County Radiological Emergency Response Plan (RERP). The follow-ing places were questioned: The Notre Dame Academy, Cardinal High School, Kent ~ State University-Burton, and West Geauga Senior High School as

" Primary Care Centers"; and Cardinal Middle School, Berkshire High School, Newbury High School, West Geauga Junior High School, Kenston High School, and Konston Middle School as " alternate care centers." She stated thst 5 of the 7 administrations have had no discussions with the American Red Cross, which the plan states is to operate the centers. She also stated at least 4 of the school systems have never been contacted; only one 1 j

indicated that it had been contacted by the American Red Croso. 4 As previously sentioned, Geauga County has a signed " Statement of Under- I i

standing Between Geauga County and The American Red Cross." This can be found in Appendix 6 (Letters of Agreement) Page 6-1 of the Ceauga County , )

RERP dated March, 1986. l Page tv of the plan further states that copies I of the schools: Geauga County plan have been distributed to the following local k

Berkshire, Cardinal. Chardon. Kenston,14dgemont, Newbury, Notre Dame Academy, and West Geauga. Appendix 6 of the plan also shows 1 j

that Geauga County has letters of agreement with the following schools:

1 Berkshire Local School District, Cardinal Local School District, Chardon '

Local Schools, Kenston Local School District, Ledgemont Local School District. Newbury Local Schools, Notre Dame Academy, and the West ceauge Local Schools.  !

The Geauga County Emergency Operations Center's Operations Croup Staff include the Geauga County School Superintendent and a liaison from the American Red Cross. To date, two federally evaluated exercises have  !

concluded Geauga County can activate, staff and operate reception / con-gregate care centers.

l In the November 28, 1984, full participation  !

exercise, the Federal evaluati.on team evaluated the Berkshire Righ School  !

facility. In the 1986 partial participation exgreise the Federal evalua= '

tion team evaluated the West Geauga High School facility. Both exercises certified centers."

the availability and adequacy of these facilities as " care Mrs. Burling also states that 12,891 evacuees are proposed to be housed in the above care centers, according to the Geauga County RERP. Appendix 26 of the Giauga County RERP simply shows that the capeef ty of the four primary 12,891 spaces. and the six alternate care centers shown in that appendix total Appendix 20, Sector and Zone Designators for the Ferry Nuclear Power Plant, show a population of 90.110 people within ten miles of the Perry Nuclear Power Plant.

Appendia 21 shows that 90.867 permanent residents are within ten miles of the Perry Nuclear Power Plant. Appendix 20 also notes that alightly less than 2000 residents of Thompson Township (Gesuga County) live within the 10-a11e EP2 of the Perry Nuclear Power Plant. Although FEMA does not require a 100 percent congregate care espacity, it is obvious that the congregate care espacity for Geauga County is well in excess of the approutmately 2000 Ceauga residents within the 10-mile EFE of the Perry Nuclear Power Plant.

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According to a December 24, 1985, facility capacity in support of accidents at nuclestFEMA memorandum, e care the cong power facilities of the plume tP4 population.has been reviewed andeen is $usually

- 15%

cited in p This has been judged acceptable by TEMA.

The Ashtabula County plan identifies suf ficient space for 17,327 evacuees.!$ congregate care facilities with with sufficient space for another 18,064 evacuees.to the care facilities Thus, using the figures mentioned by FEMA in its 1985 memorand um, it is is also true for the congregate care centers . This in As Letters the aboveof agreement identified Geauga exist Countybetween schools. Ceauga County, American Red C e Counties.

ross and Ceauga congregate County EOC staf f exists to coordinate the use of thin addition, the care facilities. e Ceauga County

2. JLuly 14.1986 Letter defferson Area Local School District Su perintendent'_s On March 2,1987, a member of the FEMA Region V staff tel ephoned and discussed with Mr. E. Lloyd Behr, Superintendent School his letterDistrict, of Julyhis letter of July 14, 1986.

, Jefferson Area Local 14, 1986 Mr. Behr pointed out that should not be taken to mean that the Jef ferson oArea nt andLocal S hwas w has not nor would not cooperate in dissater planning c ool in District r

esponse to en accident or can-made.at the Perry Nuclear Power Plant or any other emerg ency, natural dated May 28, 1985 Mr. Behr pointed out that his letter to Michael Wheeler tiee. was in response to planning taking pl ace at that out Although not stated in Mr. Schr's July in the course of the telephone conversation 14, 1986 letter, he pointed that th e legal avenue to obtain Local Schoolassistance wouldif the District. However, beissue theisBoard that of Education e erson Aren of the J '

does not believe that he has the authority to do some athe Superintendent spect of the  !

by a formal legal opinion. planning and preparedness this supported could be cons !

3.

CAPSE Bus Driver Resolution This references the passage of a non-binding resolution b y the Ohio

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County, and Municipal Employees,onAFL-CIO of State, (01PSE

, not to participate

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I ststed in the FEMA prion V NovemberTEMA 12, 1986 Region V disagrees ee, as wi response to tne Susan A. Carter Petition. memorandum to FEMA HQ in This memorandus is a stscur Ohio in response to the Susan A. Cartere uPetition Commission.

atory to The summary of the memorandum states that "In spite of the school employees are willing to cooperate, atten in training related to their emergency duties (school bus drivers e

, food Nuclear Power Station."servlee, custodial, etc.) in the event of an eme Attachment conducted in 1986-87 Iaround to this memorandum is a status the Perry plant.

ant.

raining report The March 9, 1987 letter admintotered af ter Novemberfrom 13, 1986 the Ohio Disaster Services a n ng Agenc by the RPS Corporation for OSDA's use in the Davis Bessa areahac us further pointed out that due to their manpower constraints .

The ODSA

, these courses are currently 111uminating Compaty. beinF, conducted by personnel from the Cleveland rc Elect i 1

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Mr. D.D. Hulbert (CEI) in his status report of March 5 ,

1987 indicates drivers had been conducted duringtwelve bus e driverus training sess 1986-87 to date. i another training session took place at Chardon, Ohio on, 1987. April 3 FEMA has Mr. Hulbert's status report further training sessions conducted in previous years.

points out there were bus ver dri that other training sessions have been conducted for SuperintThe endents, report also Transportation cases, Custodians and Supervisors, PTA's. Building Principals. Teachers, m and in so e 4

Ashtabula County Medical Center The Sunflower Alliance alleged that the equipment, personnel , and l facilities at the Ashtabula County Medical Center, one ofospitals five h i designated exposed coergency in energency workers, plans for the decontamination and treatment of Commission on Accreditation for hospitals. fail to meet the requirements of the Jo! .

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This issue was first raised by the Sunflower Alliance as part of the Atomic

) Safety and L.icensing Board (ASLB) hearing for the Perry Nuclear Power Plant.

! The ASLB Heartagi. were held in the period from: April 9, 1985 to April 12, i

1985. In esuvuce, it has been litigated and a concluding Partial Initial Decision by the Perry AS!.E on September 3,1985, has been made that went against the allegation made by the Sunflower Alliance. As stated on page 14 of that document, the Ashtabula Hospital is accredited by the State and ';

has been licensed-by the NRC for handling contaminated individuals.

l FDIA does not have the authority to reesamine factual issues which have been '

settled by a final decision of an ASLB.

Yhe Sunflower Alliance does not' j bring forward new or changed facts which would justify a new investigation.  !

i On March 3, 1987, n' member of FEMA Region V discussed the Sunflower Alliance l petition with a member of Radiation Management Consultants (RMC) and learned that a training program entitled " Managing The Energency Care of Radiation Accident Victims" was conducted for staf f at the Ashtabula County Medical ,

Center February 19, 1987, at 11:00 A.M.-2:00 P.M. and again at 7:00 -10:00 P.M. This same training was again conducted February 20, 1987, from 7:00-10:00 P.M.

The Medical Center staff also demonstrated their competence and the adequacy of the hospital during the November 28, 1984 full-participation exercise.

The following is extracted from the FF.MA Region V report of that exercise.

" Medical Support

1. Communications i l

There was a demonstration of the capability to receive, treat and  !

decontaminate an injured contaminated individual at the Ashtabula 1

County Medical Center,'Ashtabula, Ohio. The Hos.pital Emergency Room staff was provided a written notification at approximately  !

0845 that a contaminated injured individual from the saybrook Decontamination Station was enroute to the hospital via ambulance  ;

and would arrive at approximately 0905. l

(

1 A member of the Hospital staff explained that the initial com- '

sunications regarding incoming patients would normally come from the ambulance crews via the two-way Hospital Emergency Ambulance Reporting Net which is located and monitored in the Hospital's Energency Room aren. Communications with the utility, the County EOC, congregate care facilities, radiological laboratories, etc.

is via commercial telephone.

2. Hospital Pacilities and Procedures The Hospital staff's tuergency Roon spokesperson was unaware of the availability of a health physicist. It was stated that the.

Hospital's Disaster Chairman is also the Hospital's Radiation Officer. The Emergency Roon staff were equipped with and demonstrated effective training in the use of geigher counter

.. ._ ____..__.___-)

JUL.14

,FEMAL _ .J ITR 2 P.07

.. (6) survey meters, TLD's -and self-reading dosimeters.

It was explained by Emergency Room apokespersons that items suchecct- as whole tuination trays and water retention barrels were unavailable and 1

means for completely segregating contaminated, injured patients !f the rest of the hospital's population are presently incomplete roci The staf f, through improvisation of unavailable itemspment' of equi '

.and explanations of procedures, accepted the incominEn injured a handling, decontamination and treatment of the pa ,

the issuance of dosimetry (TLD's and self-readin m dress, contaminated clothing and equipment and were aware),of theirthe dispos responsibilities.  !

D_eficioney: L.1.  !

stratevictim.

injured all of* the equipment necessary to handle a con Recommendation The State of Ohio abould meet with representatives of the Ashtabula County Medical Center to ascertain they availab of appropriate equipment for the handling of a contaminated victim. in 3.

Ambulance Facilities and Procedures i that the pctient went to the medicaln facility e, in the day earlie wo that the procedures at the hospital could be demonstrated .

2

{

Later during the exercise the same patient participated e in th demonstration person by ambulanceof procedures and handling of a ncontaminated crew. ured {

He was put on a ambulance cet and simulated being transported to the hospital.

De subulance crew was part of the Saybrook gency workers. which emer-Fi tactive correctly.

equipment clothing and they used their instruments ry and ld Once the patient had been given first aid  ;

he removed and was placed from theon the afabulance cot, wrapped in disposable!

area.

s The handlingambulance crew contaminated demonstrated prior training in the patients. of area i

i* The use of the term "Deficioney" in 1984 was to the current torn " Area Requiring Corrective Action ", in this case, equivalent July 1985, that it was defined as a more serious flew performance.

It was in eonly in xercise '

thisin to not be atext.

original danger to the public healthFooIn~o'te and safaty added,

)At the t l

I f

Jul' 14 'E7 to?! FEt1A mSH RED CTR 2 P.68 i

(7) 4.

Scenario (as it relates to medical support) i The scenario was sufficiently designed to drive the medical i support activities and thus allow an opportunity to demons: rete these procedures."

The FEMA report of the April 15,~1986 not demonstrated during the NovemberPower Plant exercise, 28, 1964 exercise are now available.

handling contaminated individuals consisted of a to County Medical Center (ACMC).

that the pa taminated hospital tients. has the necessary equipment to adequately treat c -

as deficient during the 1984 exercise.The equipment observed included equipm containers, faucet hoses, and a whole-body This included wach tray. waste water collection the tment trea facilities since the last exercise include non-absorbent paint ine thOther im and increased lighting in the hallway leading to the treatmen victims of a radiological accident.Given the above, FEHA concluded t injured contaminated individual to the ACMC. Fire Departm Since the ACMC is outside the Perry 10-mile EPZ it is not necessary to mak preparations for ambulance transport of contamination vieties from the l Nedical Center to other hospitals in the event of a severe radioactive {

release from the Perry Plant in the direction of Ashtabula.

1 hupe that this information is useful.  ;

feel free to contact me at 646-2671 If you have any questions, please i 1

or Robert 5. Wilkerson at 646-2861 . $

Att achmen ts 1 As Stated j 1

L__--____-___--_____ \

- . 71.*14 '87 14:37 FEMA LM5H FCD CTR 2 P.09 M:A.2! 'F lis ts rD% FC",Idi \' CHICAM l- F,CI

~'

l 87 ATE OF OW10 Ah.KnMT 08MCAAL4 OOMmetNT  !

--- setseasttaam m tanan e s ton.osso m na -

- DIESTER SERVICES ACgNcy ACOR.DS-RERP ,

March 9, 1987 Mr. Dan Basent FEE Ration V 600 South Wacker $uest Chicago, IL 60606

Dear Dan:

In response to questions concerning bus driver training conducted around the Perry Nuclear Power Plant, 2 se enclosing a sunesary of training conducted in 1986 87. All tratr.ing that was administrated after Never.ber 13, 1986 has used the guidelir.es devoicped by the RP5 Corporation for CDSA's use in the .

Davis.5 esse area. However, due to CDSA manpower constraints, ths8e courses are currently being conducted by personnel from Ctt.

If you require additional information, feel free to centset me.

k LA AY A. GROVE

- Nuclear Response Supervisor LAC:sje enti se 9

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